    [From the U.S. Government Printing Office, www.gpo.gov]

               ARCTIC NATIONAL WILDLIFE REFUGE,
                                                                                                                                        ALAS KA,
                      C-            4TA -M                               -RIE-1116-l"(111 U-111ft                      SESSM ENT
                                                                 IN,

                                 _0
                                     BE

                                                                7

           5, a  -tj
                                                                                   -THIE                       SS`QF T14E V I
                                                                                                                                         M TED STATES

                                                                                                              tMPACT           STATE           ENT
                     rm",
                         7@i

                                                  N
                                                   k,
                                                   "
                                                   A- @F
                                                           k.,
                                                                                                                      APO, J,
                Vol,
                                                                                    -qp
                                                                                                                                  2p, -
                                         ME
                          'MA
                              w",                         oil
                              @jl e"I"I'l,

                                           w--Ze-
                                                         254%w
                                                   wt -

                                                                                                                                                                      4",

                                                                        kv
                                                                      A

                                                                               POX

                                                                                                                                                                   nv
            ts
                       *U   7
                    'k   w    -
                                                                 too

                                                                       0Wow, -

                              UNITED STATES

                      DEPARTMENT OF THE INTERIOR

             ARCTIC NATIONAL WILDLIFE REFUGE, ALASKA,

               COASTAL PLAIN RESOURCE ASSESSMENT

          REPORT AND RECOMMENDATION TO THE CONGRESS OF THE UNITED STATES

              AND FINAL LEGISLATIVE ENVIRONMENTAL IMPACT STATEMENT

                  APPENDIX--PUBLIC COMMENTS AND RESPONSES

     									  Property of CSC Library

          U.S. DEPARTMENT OF COMMERCE NOAA
          COASTAL SERVICES CENTER
          2234 SOUTH HOBSON AVENUE
          CHARLESTON, SC 29405-2413

                           APRIL. 1987

                     In accordance with Section 1002 of the

                  Alaska National Interest Lands Conservation Act,

                    and the National Environmental Policy Act

                 Prepared by the U.S. Fish and Wildlife Service

                   in cooperation with U.S. Geological Survey

                    and the Bureau of Land Management

                                                                                                                                                                     zi Zj%

                                                           ARCTIC NATIONAL WILDLIFE REFUGE, ALASKA,
                                                               COASTAL PLAIN RESOURCE ASSESSMENT

                                               Report and recommendation to the Congress of the United States
                                                      and final legislative environmental impact statement, 1987

                                                                                    Volume 1-Report
                                                        Volume 2-Appendix (Public comments and responses)

                                                                                   Copies are available from:

                                                 U.S. Fish and Wildlife Service                          U.S. Fish and Wildlife Service
                                                 Division of Refuge Management                           Division of Planning
                                                 18th & C Streets, NW., Room 2343                        1011 E. Tudor Road
                                                 Washington, D.C. 20240                                  Anchorage, Alaska 99503

                                                                                    Copies can be seen at:

                                               Anchorage Public Libraries-,,,. ,4_@TCA                 Arctic Village Community Llbrary-@ St
                                                                                                       Kenai Community Library
                                               Fairbanks Public Libraries
                                               Juneau Public Libraries                                 North Slope Borough School Library
                                                                          Arctic Slope Regional Corporation Library

                                                       Copies can also be seen at the following U.S. Geological Survey Libraries
                                                                                  and Public Inquiries Offices:

                                               USGS Libraries:
                                                 Reston, VA                       National Center, 12201 Sunrise Valley Drive
                                                 Flagstaff , AZ                   2255 North Gemini Drive
                                                 Menlo Park,    CA                345 Middlefield Road
                                                 Golden, CO                       1526 Cole Boulevard at West Colfax

                                               USGS Public    inquiries Offices:
                                                 Anchorage,    AK                 Room   101, 4230 University Drive
                                                 Los Angeles, CA                  Room 7638, Federal Building, 300 North Los Angeles Street
                                                 San Francisco, CA                Room   504, Customhouse, 555 Battery Street
                                                 Denver, CO                       Room   169, Federal Building, 1961 Stout Street
                                                 Dallas, TX                       Room   1045, Federal Building, 1100 Commerce Street
                                                 Salt Lake City, LIT              Room   8105, Federal Building, 125 South State Street
                                                 Spokane, WA                      Room 678, U.S. Courthouse, West 920 Riverside Avenue

                                               Recommended citation for this report shown          in Volume 1.

                                                                                  COVER PHOTOGRAPH

                                                                     A typical view southward across the coastal plain
                                                                         toward the foothills and the Brooks Range.

                                                            ARCTIC NATIONAL WILDLIFE REFUGE, ALASKAY
                                                               COASTAL PLAIN RESOURCE ASSESSMENT

                                                                                                APPE14DIX
                                                                        PUBLIC COMMENTS; AND RESPONSES

                                                                                                CONTENTS

                          Responses to proposed recommendation
                             in the draft LEIS     ................................................................1Wilderness review     ..........................................................8
                          Responses to comments             .....................................................2Compliance with Title VIII        .............................................8
                             Environmental issues           ........................................................2Oil and gas resource assessment. issues         .....................9
                               Caribou    ............................................................................2Marginal probabilities for commercial
                                 PCH core calving area        ...s ...........................................2      hydrocarbon occurrence          ............................................9
                                 PCH displacement vs. decrease in population                 ......    2          Small and unidentified prospects          .................................9
                                 Area of displacement         .................................................2  Probability distributions.'                         .......             9
                                 Mapping areas of PCH concentration              ..................... 3          Geologic risk    ...................................................................9
                                 Caribou insect relief      ...................................................3  Existence of the Ellesmerian sequence             ......................9
                               Polar bears     .....................................................................4Table 111-1 (OCS planning areas)       ................................. 10
                               Carrying capacity      ...........................................................4Figure 111-2 (prospect sizes)       .......................................... 10
                               Transboundary consequences             .....................................4      Data confidentiality     ......................................................... 10
                               Baseline report     ...............................................................4Oil prices ......................................................................... 11
                               Regulatory processes         ....................................................4 Oil price growth rate       ..................................................... 11
                               Mitigation   .........................................................................4Natural gas  ..................................................................... 11
                               Water availability and development          ..............................6        Economic scenarios         ...................................................... 11
                               Air quality   ........................................................................6National need issue  .......................................................... 12
                               Gravel   ..............................................................................7Marginal probabilities and the national need        ............. 12
                               Energy conservation          ......................................................7Otherissues   ....................................................................... 12
                               Use of "worst case" analysis         .......................................7      Consultation and coordination          ..................................... 12
                               Cumulative effects     ..............................  :1*---*****----- 8          Consultation with Canada          ............................................ 12
                               Oil spills  ..........................................................................8Public hearings  ............................................................... 13
                            Socioeconomic issues            ......................................................8Submerged lands       ........................................................... 13
                               Sociocultural concerns       ..................................................8   Arctic Refuge land exchange          ........................................ 13
                               Recreational use    ............................................I ................8Development and transportation scenarios              ................ 14

                                                            Public comments (categories separately- paginated)
                                                            Federal governments and agencies           ................................ F-1 through F-83
                                                            State and local governments         ........................................... S-1 through S-41
                                                            Organizations   ..........      .......                                0-1 through 0-481
                                                            Industry ............................................................................... 1-1 through 1-203
                                                            Private individuals  .............................................................. P-1 through P-118
                                                            General comment letters       .................................................. R-1 through R-39

                                                                                                       a

                                                                     b

                                                                                              APPENDIX

                                                                PUBLIC COMMENTS AND RESPONSES

                                 On November 24, 1986, the draft Arctic National                                Responses to proposed recommendation
                          Wildlife Refuge Coastal Plain Resource Assessment and                                                    in the draft LEIS.
                          legislative environmental impact statement (LEIS) were made
                          available for public review and comment.                       Originally
                          scheduled to close January 23, 1987, the comment period                               State/Country                    Yes           No           Total
                          was extended to February 6, 1987, at the request of the
                          Governor of Alaska and others. Public meetings were held
                          January 5, 1987, in Anchorage, Alaska; January 6, in                                  Alabama                           18               2            20
                          Kaktovik, Alaska; and January 9, in Washington, D.C.                                  Alaska                          1,311          407          1,718
                                                                                                                Arizona                           90            28            118
                                                                                                                Arkansas                          21               1            22
                                 More than 200 individuals participated in the                public            California                       564           839          1,403
                          meetings and submitted oral or written statements, or               both.             Colorado                         138            43            181
                                                                                                                Connecticut                       98            46            144
                          Transcripts   of these three hearings are available for             public            Delaware                          27               6            33
                          review in the following locations:                                                    District of Columbia              16               5            21
                                                                                                                Florida                          258           124            382
                                 U.S. Fish and Wildlife Service
                                 Division of Refuges                                                            Georgia                           42                            75
                                                                                                                Hawaii                               4             4              8
                                 Room 2343, Main Interior Building                                              Idaho                             13               7            20
                                 18th and C Streets, NW.                                                        Illinois                         230           130            360
                                 Washington, D.C. 20240                                                         Indiana                           86           140            226
                                                                                                                Iowa                              27            21              48
                                                and                                                             Kansas                           134               7          141
                                                                                                                Kentucky                          35               4            39
                                 U.S. Fish and Wildlife Service                                                 Louisiana                        181            21            202
                                 Alaska Regional Office - Planning                                              Maine                             13               9            22
                                 1011 East Tudor Road                                                           Maryland                          53            50            103
                                 Anchorage, Alaska 99503                                                        Massachusetts                     53           118            171
                                                                                                                Michigan                          62           105            167
                                 Copies of the draft report/LEIS were sent                    to all            Minnesota                         55            57            112
                          Federal, State, and local agencies with jurisdiction by             law or            Mississippi                       26               4            30
                                                                                                                Missouri                          94            46            140
                          special expertise, to the Government of Canada and the                                Montana                           84            33            117
                          Yukon and Northwest Territories, to conservation                                      Nebraska                          55               7            62
                                                                                                                Nevada                            21            11              32
                          organizations, oil and gas industry, selected libraries, the                          New Hampshire                     10            14              24
                          media, and others who requested copies             I.                                 New Jersey                       156            67            223
                                 During the com         ment period, 11,361 letters were                        New Mexico                        66            19              85
                                                                                                                New York                         169           289            458
                          received. The vast majority of these letters (11,244) were                            North Carolina                    41            28              69
                          generally a statement either that the area should be opened                           North Dakota                      42               1            43
                          to further oil and gas activity or that the area should be                            Ohio                             142            50            1192
                                                                                                                Oklahoma                         609            17            626
                          designated as wilderness. Of these letters, 7,491 favored                             Oregon                            34            44              78
                          leasing and 3,707 favored wilderness designation. Forty-six                           Pennysivania                     547           128            675
                          letters expressed no definite opinion. Statistical summaries                          Rhode Island                      13            12              25
                          by State and position are presented in the adjacent table.                            South Carolina                    15            48              63
                                                                                                                South Dakota                      18               2            20
                                 Many of the letters were the results of various mail-in                        Tennessee                         35            19              54
                          campaigns inspired by industry and conservation                                       Texas                           1,192           64          1,256
                                                                                                                Utah                              25               3            28
                          organizations.       A variety of these comment letters have                          Vermont                              4          34              38
                          been reproduced in this volume. They were selected at                                 Virginia                          90            41            131
                          random and represent examples of the pro and con                                      Washington                       128           422            550
                          statements, petitions, individually thought-out responses,                            West Virginia                    208               7          215
                          and mail-in campaigns. All these comment letters are                                  Wisconsin                         58            74            1.32
                          available for public review in the Washington Office of the                           Wyoming                           51               7            58
                          U.S. Fish and Wildlife Service, address provided above.                               Canada                               1             5              6
                          Included in the 11,244 letters were responses from 821
                          organizations, industries, associations, etc.; and 10,423                               Total                        7,491         3,707          11,198
                          private individuals.

                                 Substantive comments on the contents of the report                     The term "core" was used to identify areas
                          Itself were received from the remaining 117 respondents and             repeatedly used by large numbers of calving caribou
                          are published in their entirety in this volume, in the                  (density of at least 50 animals/square mile as described in
                          following categories:                                                   4he draft LEIS/report). Areas were identified as core calving
                                                                                                  areas in the draft report where surveys indicated
                                 Federal governments and agencies                                 concentrated use in at least 5 of the 14 years for which
                                 State and local governments                                      detailed observations have been made.                Information
                                 Industry                                                         received since the draft report was prepared added another
                                 Organizations                                                    year of calving distribution information to this  data base.
                                 Private individuals
                                                                                                        Data leave little doubt that there          are important
                                 If written testimony filed at the public meetings                birthing areas in spite of some broad variations from year
                          contained substantive comments, it has also been                        to year (fig. 11-5 and pl. 2A). Based on further review and
                          reproduced in this section.                                             consultations with Canada, it Is questionable to conclude
                                                                                                  that the repeatedly used concentrated calving habitat on
                                 -Each of the 117 letters was analyzed and substantive            the Jago River is "unique and irreplaceable on a national
                          issues or additional information were delineated.             Oral      basis or in the ecoregion" (Resource Category I
                          testimonies presented at the hearings and documented in                 designation, FWS mitigation policy), or that displacement
                          the transcripts were reviewed, and the concerns and issues              would be sufficient to threaten the viability of the PCH.
                          raised addressed in the report and responses as                         Accordingly, designations of a "core" 'calving area and
                          appropriate.                                                            Resource Category 1 habitat have been deleted from the
                                                                                                  final report.
                                 Over 1,650 individual comments are contained in the
                          117 letters.    These substantive comments have been                          We believe that the documentation         of PCH calving
                          summarized by major topic or issue, and detailed                        within the 1002 area and additions to the discussion of the
                          responses are included below. The final report/LE        IS was         importance of calving in the caribou life cycle adequately
                          modified as appropriate based on comments received.                     address this issue without usin,g strictly subjective
                                                                                                  measures for impact analysis.
                                 The substantive comment letters and the letters
                          concerning the overall issue oi whether or not to open the'             PCH   DISPLACEMENT VS. DECREASE IN POPULATION
                          coastal plain of the Arctic National Wildlife Refuge to further
                          oil and gas activity follow the "Responses to Comments"                        Several commenters, including those from Canada,
                          section in this appendix volume.                                        were   concerned with what seemed to be a 20 to 40
                                                                                                  percent projected population decline for the PCH.

                                    RESPONSES.TO            COMMENTS                                     The draft report did not predict a 20 to 40 percent
                                                                                                  decrease in herd size.        The percentage was related to
                                                                                                  distribution changes, but through an editing error in
                                          Environmental Issues                                    punctuation, the relationship was obscured. However, this
                                           (Chapters 11 and VI)
                                                                                                  prompted the FWS to conduct further analysis and
                                                    CARIBOU                                       consideration of concentrated calving patterns which has
                                                                                                  suggested that quantifying a percentage in change of
                                 The anticipated effects on the Porcupine caribou herd            distribution (that is, percent displaced) would be highly
                          (PCH) and, to a lesser extent, the Central Arctic Herd                  speculative. Therefore, such information has been dropped,
                          (CAH), generated more public comment than any other                     from the text and clarification provided.
                          aspect of possible oil and gas activity in the 1002 area.               AREA OF DISPLACEMENT
                          This topic has been extensively revised in both Chapters 11
                          and VI based on these comments. Additional information                         One of the more controversial aspects of the
                          has become available since the draft LEIS/report was                    environmental analysis for caribou concerned the
                          prepared, and has been reflected in the analysis in the                 assumption that caribou would be displaced 3 km out from
                          final. Although the comments were numerous, most were                   either side of development, roads, and associated facilities.
                          repetitive of a few major concerns, which have been                     The draft LEIS described this area as 2 miles (3 km = 1.86
                          summarized and responded to below.
                                                                                                  mi) in conformance with use of English units throughout the
                          PCH CORE CALVING AREA                                                   report.    However, all computer analyses of areas which
                                                                                                  would be affected on the basis of this displacement used 3
                                 On the basis of respondents' comments, it was                    km, as reported in the literature (Dau and Cameron, 1986).
                          obvious that the draft report's designation of a "core"                 Because several commenters expressed confusion over the
                          calving area was being misinterpreted as a very specific                use of 2 miles, the references and discussion in the final
                          area absolutely essential to the viability of the PCH.                  LEIS were changed to 3 km to be consistent with the
                                                                                                  literature.
                                                                                             2

                              The text has been modified to correct the implication                         For the years 1972-77, large-scale maps prepared by
                       that there would be a complete loss of habitat values within                 the original investigators were destroyed in a fire, leaving
                       this 3-km area. There would be a reduction in habitat                        only small-scale maps for use in preparing the draft report.
                       values in varying degrees throughout the area within 3 krn                   Working with the FWS, D. G. Roseneau, one of the field
                       of development, with significant declines most likely 2 km                   investigators working on the Arctic Refuge during the Arctic
                       outward from the development facilities. This is based on                    Gas studies, identified and corrected inaccuracies in the
                       the Dau and Cameron study which showed such                                  maps in the draft report for calving distribution for 1972-77.
                       decreases in use from disturbance levels much lower than                     Earlier inaccuracies resulted from the FWS interpretation and
                       are likely to occur under the full and limited leasing                       transformation of small-scale maps to a larger scale. The
                       scenarios.     Further information on the Dau and Cameron                    refinements are based upon Roseneau's field notes and
                       (1986) study, which was the basis for the 3-km                               recollection.
                       displacement zone, has been provided.
                                                                                                            The refined concentration areas are depicted in figure
                              Because of concerns over use of the Dau and.                          11-5 and plate 2A of the final LEIS and included in all
                       Cameron data, the Alaska Department of Fish and Game                         quantifications of calving areas.
                       (ADF&G) met with representatives of the oil Industry
                       February 13, 1987, to clarify data collection and analysis
                       procedures. Additional statistical tests were applied to the
                       data; reanalyses confirmed displacement, and consistently
                       supported the results and conclusions of the original Dau                    CARIBOU INSECT RELIEF
                       and Cameron report.          Oil industry, representatives agreed
                       that displacement of caribou from the Milne Point road had                           Numerous comments addressed the issue of insect
                       occurred even though the Dau and Cameron study was,                          relief, the areas and conditions sought by caribou for relief,
                       conducted during periods of very low traffic activity.             On        and the significance of insect avoidance behavior in relation
                       February 27, 1987, the ADF&G and oil industry                                to the effects of possible development. The report has
                       representatives presented the clarified data to FWS. The                     been revised to clarify or expand the discussion of insect
                       analysis in Chapter VI has been revised to reflect this                      relief phenomenon.
                       clarification.
                                                                                                            Insect relief is generally meant to include avoidance
                       MAPPING AREAS OF PCH CONCENTRATION                                           of both mosquitoes and oestrid flies. On the 1002 area
                                                                                                    oestrid flies are not believed to be the nuisance to the PCH
                              A few commenters suggested that the maps and                          that they are to the CAH. The majority of the PCH have
                       calculations concerning areas of concentration and densities                 generally left the area by peak oestrid fly emerge               'nce,
                       of PCH on their calving grounds did not reflect all available                although some flies may be present in early July.
                       information.                                                                 Generally, PCH movements to insect-relief habitats appear
                                                                                                    to be in response to mosquitoes.
                              Further information on the caribou densities in
                       observed concentration areas has been provided in the                                Evidence suggests that insects play a very strong
                       report, including the assumptions used to calculate                          role in influencing caribou behavior, activity and movements.
                       densities of between 46 and 128 caribou/square mile for                      The text in Chapter VI has been expanded to reflect this
                       each concentration area in 1983 and in 1984.                   Limited       fact.
                       measurements made in 1972 near the Jago River showed
                       densities ranging from 8.2 to 375 caribou/square mile.                               Some commenters suggested that use of coastal
                       Because the difference between high density concentrated                     areas for insect relief was inconsistent.                 The FWS
                       and low-density scattered calving areas is readily apparent,                 disagrees.     During the last 15 years, coastal insect relief
                       use of the term "concentrated" by previous observers was                     was used on the average of every other year by extremely
                       assumed to reflect densities of similar magnitude.                           large numbers of PCH caribou (Garner and Reynolds, 1982,
                                                                                                    1983, 1984, and 1985).
                              Since preparation of the draft report,              additional
                       information has been made available to the FWS concerning                            These and other commenters pointed out that the
                       the distribution of PCH calving.              This has permitted             main    oil pipeline should present no obstacle to PCH in
                       refinement in mapping and analyzing calving distributions in                 their   movements to coastal relief habitats, based on CAH
                       Alaska and Canada for 1972-81.                   Some of these               crossing success in the Prudhoe Bay area. Even large
                       refinements have been made possible through the recent                       groups (a few thousand) in the CAH that successfully
                       preparation of large-scale maps of calving distribution for                  negotiate pipelines, roads, and other developments are
                       the years 1978-81 by the Yukon Wildlife Branch. The                          much smaller than postcalving aggregations of the PCH (up
                       Yukon Wildlife Branch maps were based on field notes and                     to 80,000).      If these large groups of PCH caribou react
                       maps prepared by the original investigator, and are more                     negatively to disturbance as some observations suggest,
                       accurate than the -small-scale maps used by the FWS for                      there could be large-scale exclusion of caribou from coastal
                       preparation of the draft report.                                             areas.

                                                POLAR BEARS                                                           BASELINE REPORT

                                There were numerous comments that loss of the one                        A few organizations commented that the final baseline
                          or two bears known to den on the 1002 area each year did                report was unavailable at the time the draft report/LEIS was
                          not indicate a moderate impact to the Beaufort Sea polar                made public.     This was true due to printing difficulties;
                          bear population. This section in Chapter VI has been                    however, the final baseline was available by January 1987,
                          clarified. Figures presented in the text are for known dens,            allowing sufficient time for review. Despite its length, that
                          based on radio-telemetry studies of only a fraction of the              report provides updates and summaries of previous annual
                          total denning bears within the Beaufort Sea population.                 baseline reports published and publicly available since April
                          Only 5 to 20 percent of the approximately 150 females                   1982.   The reports were prepared by those who also
                          which den each year are radio tagged. Thus, there are                   contributed to the preparation of the 1002 report, so,
                          probably numerous other bears denning on the 1002 area                  inevitably, the report reflects information in all the baseline
                          which could also be adversely affected by development.                  studies. In fact, these baseline studies have provided the
                          These numbers are even more important when considering                  basis for the biological and socioeconomic portions of
                          that 10 of the 12 land dens found during the 1961-86 radio              Chapters 11 and VI, as they were intended to do.
                          -telemetry studies were located on the Arctic Refuge. Seven
                          of those dens were within the 1002 area.                                       The final report/LEIS also has been updated to
                                                                                                  include the 1985 baseline information. The 1985 baseline Is
                                            CARRYING CAPACITY                                     in press, and the entire baseline series will be available for
                                                                                                  the Congress and the public when the Congress begins
                                A few commenters noted that carrying capacities of                consideration of the report and the Secretary's
                          the Arctic Refuge coastal plain are not presented in the                recommendation.
                          Baseline Study, as was required by Section 1002(c)(b), or in
                          the draft LEIS/report.       Despite the extensive baseline
                          studies that have been conducted, current knowledge is                                  REGULATORY PROCESSES
                          inadequate to address the concept of carrying capacity on
                          the 1002 area for the various fish and wildlife species that                   The Environmental Protection Agency concluded that
                          seasonally occupy the coastal plain. This fact is noted In              the discussion of the regulatory process and its
                          the final Baseline Report and throughout Chapters 11 and VI             relationships to the alternatives needed to be expanded.
                          of the report.                                                          The focus of their comments was on:

                                The use of primary productivity (annual growth of                 0      The existing regulatory process Including examples of
                          vegetation) by the various secondary consumers                          how existing regulations are applied on the North Slope for
                          (herbivores) is not well documented for the Arctic. Similarly,          oil and gas development.
                          the role of interspecific and intraspecific competition of
                          herbivores in altering the biotic carrying capacity of the              0      The Section 404 program, in particular the success of
                          coastal plain of the Arctic Refuge has not been quantified.             Abbreviated Permit Process, designed to expedite oil, and
                          Also, nonhabitat factors (predation, disease, behavior,                 gas development on the North Slope.
                          weather, etc.) that can modify the carrying capacity of the
                          area are not well understood. Carrying capacity of tertiary             0      The poterifial applicability and use of the advanced
                          consumers (predators and omnivores) is dependent upon                   identification process for advanced planning.
                          the distribution and abundance of their prey species.
                          Therefore, carrying capacity of tertiary consumers can only                    Department of the Army Section 10/404 permits are
                          be established after the carrying capacity of their prey has            the primary basis for current FWS Involvement In existing
                          been established. Until data are available to address these             North Slope oil and    .gas developments. The FWS does not
                          information gaps, valid estimates of carrying capacity of the           believe that the effectiveness of this process has been
                          1002 area are not possible.                                             Impaired by development of the Abbreviated Permit Process.
                                                                                                  Also, the FWS has supported the advanced Identification
                                                                                                  process, and considers it to be useful for making concerns
                                    TRANSBOUNDARY CONSEQUENCES                                    known early In the decislonmaking process.

                                 The Government of the Yukon felt that there was
                          inadequate treatment of the transboundary consequences of                                        MITIGATION
                          those direct impacts on wildlife that use the coastal plain
                          and Canadian habitats or are important constituents of a                       Comments       relevant to mitigation, ranging from
                          larger regional population. This point Is well taken, and               criticism that ameliorative measures were too stringent to
                          Chapters 11 and VI have been expanded to address the                    complaints that they were totally Inadequate, revolved
                          effects on transboundary wildlife species: caribou, waterfowl,          generally around the following Issues:
                          and marine mammals.

                                                                                             4

                             Some reviewers criticized the FWS mitigation policy                     3.        A number of comments expressed concern that, in
                             and Its habitat-based evaluation system.                  They                    evaluating potential impacts of oil development in the
                             contended that animal populations in the Arctic have                              1002 area, the report relied too heavily on mitigation
                             not been shown to be regulated by habitat                                         techniques used in the Prudhoe Bay area,                  The
                             availability.  They further contended that the most                               general theme of these comments was that serious
                             biologically effective approach to assessing and                                  Impacts have occurred at Prudhoe Bay, in spite of
                             mitigating effects is to determine how oil development                            mitigation measures, and that impacts of similar
                             will adversely affect given populations and then apply                            activities might be greater in the 1002 area.
                             mitigative measures that avoid or minimize impacts.
                                                                                                               Experience gained at Prudhoe Bay has been relied
                             Animal populations     are considered by many experts                             on as a basis for evaluating impacts where
                             to provide an unreliable basis for evaluating fish and                            appropriate.    Parallels relative to certain types of
                             wildlife Impacts. Sampling errors, cyclic fluctuations                            activities are obvious-, that Is, many studies contain
                             of populations and the lack of time-series data all                               conclusive evidence of impacts that will occur under
                             contribute to the problem. Therefore, FWS feels that                              certain conditions or circumstances, regardless of
                             determining habitat value provides a better basis for                             location.  On the other hand, there are dangers in
                             developing mitigation recommendations. But the use                                drawing analogies where conditions, potential
                             of population Information is not foreclosed. In fact,                             scenarios, or habits of affected species are
                             concern for potential population losses led to the                                significantly different.    The text In Chapter VI has
                             formulation of the general policy to seek to mitigate                             been modified to emphasize this point and to more
                             all losses to fish, wildlife, their habitat, and uses                             clearly explain the rationale for the use of FWS
                             thereof.. The FWS believes that mitigation of potential                           mitigation policy as a means for determining potential
                             population losses is a necessary aspect               .of this                    loss of habitat values as a basis for impact
                             policy.                                                                           measurement and evaluation.

                             The FWS mitigation policy mirrors the consideration                               It Is unrealistic to expect that all impacts will be
                             of mitigation as required by the CEO regulations (40                              ameliorated or that there may not be unavoidable
                             CFR 1502A4, 1502.16, 1505.2(c) and 1508.20). It                                   impacts having significant adverse effects.                 For
                             sets out goals and planning guidance for the                                      example, potential impact on wilderness values is
                             development of FWS mitigation recommendations,                                    perhaps the most significant adverse impact likely to
                             The policy does not require absolute strict adherence                             occur, as well as the least possible to effectively
                             to a required standard..                                                          mitigate.

                             The discussion of mitigation in Chapter VI has been                               Section 1002(h) of ANILCA does not require "no
                             revised and expanded to clarity the use of the FWS                                significant adverse impact," as a standard for further
                             mitigation policy In establishing mitigation goals and                            oil exploration and development, as was used in the
                             developing mitigation recommendations.                                            previous seismic exploration program on the 1002
                                                                                                               area. It does require "an evaluation of the adverse
                    2.       Concern was expressed that many, mitigation                                       effects that the carrying out of further exploration for,
                             measures Imposed on Industry at Prudhoe Bay were                                  and the development and production of, oil and gas
                             found to be unnecessary, ineffective, or, in some                                 within such areas will have on the resources."
                             cases, detrimental to the environment.                  Blanket                   Although there is a risk of significant population
                             restrictions were viewed as inefficient and less                                  declines for PCH caribou and muskoxen, the
                             desirable than mitigation measures based on case-by-                              likelihood of these "catastrophic consequences' Is
                             case evaluations.                                                                 very low. AJso, such consequences would not be
                                                                                                               permanent, because most perturbations would
                             Some mitigation measures originally imposed on                                    disappear with depletion and shutdown of oil
                             frontier oil and gas development activities at Prudhoe                            activities and the restoration of the coastal plain
                             Bay either have been Ineffective or have been found                               (primarily removal of infrastructure).
                             to be unwarranted.           Preventive techniques are
                             continually being Improved with advances In state-of-                     4.      A number of respondents felt that the draft report did
                             the-art technology and additional biological           data on                    not adequately acknowledge the mitigative effects of
                             the effects to fish and wildlife from                  various                    existing regulatory programs of Federal, State, and
                             development activities In the Alaskan Arctic.                                     local governments having jurisdiction over the 1002
                             Mitigation measures must be viewed in the light of                                area.
                             past experience and present technology.                Flexibility
                             should also be maintained to rescind or add                                       We believe that the Importance of these controls Is
                             mitigative measures as determined necessary on the                                adequately recognized In the report, although some
                             basis of day-to-day experience, This approach was                                 additional Information has been provided.                    We
                             reflected In the draft report/LEIS and is reaffirmed in                           generally believe It (1) unnecessary to belabor well-
                             the final.                                                            5           known regulatory processes and (2) more Important

                                to focus on areas where additional mitigation may be                        regulatory structure is designed to assess the
                                necessary to ensure that refuge resources are not                           potential effects of oil development on air quality
                                subject to unnecessary adverse effects.                                     once such critical variables are known.          Under this
                                                                                                            structure, the State of Alaska Department of
                         5.     Although a number of comments were            critical of the               Environmental Conservation must grant permits prior
                                draft LEIS/report in not adequately acknowledging the                       to any construction on the 1002 area. For significant
                                mitigative effects of existing regulatory programs, an                      activities, permits require that major sources of
                                almost equal number voiced concern that existing                            pollution apply best available control technology, that
                                regulations, standards, and stipulations are                                minor sources apply new source performance
                                inadequate to ensure mitigation.                                            standards, and that Alaska's control requirements be
                                                                                                            written into State implementation plans.
                                As stated in Chapter 1, more than 36 Federal laws, 5
                                State of Alaska laws, and 111 separate regulations                   2.     Several commenters suggested that the final LEIS
                                currently apply to oil and gas activities in Alaska.                        include results from modeling emissions estimates foe
                                The FWS believes that these laws and regulations                            the 1002 area.
                                provide ample guarantee for protection of the
                                resources of the 1002 area. Laws such as ANILCA                             The Department does not believe that current
                                and the National Wildlife Refuge System                                     information permits reliable modeling of the impact of
                                Administration Act give additional controls to FWS                          1002 area oil development on air quality. Moreover,
                                which are lacking on nonrefuge lands.                                       given that the current regulatory structure and the
                                                                                                            mitigation measures that it requires are adequate,
                                                                                                            such modeling is unnecessary at this time. Air-
                                WATER AVAILABILITY AND DEVELOPMENT                                          quality modeling would be an important component of
                                                                                                            subsequent deliberations by the State on whether to
                                A variety of comments were received regarding 1002                          grant permits for activities in the 1002 area.
                         area water supplies large enough to support oil and gas
                         exploration and development. The following information is                  3.      Several commenters expressed concern about the
                         expanded on in the final report.                                                   potential contribution of oil development on the 1002
                                                                                                            area to a buildup of carbon dioxide (C02)
                                The limited availability of fresh water on the Arctic                       concentration levels in the Earth's atmosphere.
                         coastal plain is not unique to the 1002 area, nor has it
                         precluded development.           Sources used and methods                          Development in the 1002 area would not lead to a
                         developed to satisfy water requirements in other areas in                          significant increase in the C02 concentration in the
                         the Arctic would apply to activities in the 1002 area.                             atmosphere, which could, in turn, via the
                         Solutions to providing/obtaining water would be considered                          greenhouse effect," raise the earth's temperature.
                         on a site-by-site basis.        Sources and methods used to                        This is true for several reasons.               First, C02
                         obtain winter water supplies in earlier exploratory                                concentration is a global phenomenon. The potential
                         development and production activities in Arctic Alaska are                         resources an the 1002 area, though sizable, are
                         discussed in Chapter 11 of the report.                                             relatively insignificant in relation to worldwide fossil
                                                                                                            fuel consumption.        Second, if the 1002 area's oil
                                                                                                            resources are not developed, it is likely that other
                                                  AIR QUALITY                                               fossil fuel resources would be developed in their
                                                                                                            place.    Some fossil fuels, such as coal, can have
                                Many commenters criticized         the lack of information                  greater air-quality impacts than oil. Third, fossil fuel
                         and analysis of effects regarding         air quality in the draft                 combustion is only one of the ways which
                         report. Additional information has       been made available to                    contributes to C02 buildup. Fourth, C02 is only one
                         the Department, and expanded discussions have been                                 of several gases contributing to the "greenhouse
                         included in Chapters 11 and VI, Several issues were raised:                        effect." Some investigators believe that, over the next
                                                                                                            50 years, these other gases may play an equally
                         1.     One commenter indicated that the draft LEIS should                          important role in C02 buildup.            Finally, there is
                                include a discussion of the process for regulating air                      substantial uncertainty about the likelihood of global
                                quality in the 1002 area.            Another commenter                      warming.
                                expressed confidence in the current process for
                                regulating air quality in Alaska and suggested that                  4.     Some com,menters expressed concern that the impact
                                changes were not needed in the regulatory                                   of oil production on ambient ozone concentrations
                                framework.                                                                  could be significant and that it should be dealt with
                                                                                                            in the final report.
                                It is difficult to predict the impacts on air quality in
                                the 1002 area without knowing the scope, timing, and                        Ozone is formed by a complex series of atmospheric
                                location of oil development. However. the existing                          reactions between volatile organic compounds and

                                                                                                 6

                              nitrogen oxides in the presence of sunlight.                                 Leasing and development, from field exploration
                              Generally, ozone formation is not expected to be                      through oil production, transportation, rehabilitation and
                              significant in Alaska, and especially in the 1002 area,               abandonment, would be sequential on the 1002 area. For
                              because the intensity of sunlight and temperatures-                   purposes of impact assessment, it was assumed that
                              two critical factors in the formation of ozone-is quite               Blocks A, C, and D (for Alternative A) were leased and that
                              low.                                                                  exploration was successful.       It was further assumed that
                                                                                                    each of these blocks, plus Block B which would be
                       5.     There was some concern that there could be                            crossed by the main pipeline, would at some point in time
                              significant effects from acid rain and that this issue                have some concurrent activity, whether it be winter seismic
                              was ignored in the draft LEIS.                                        work; exploration and development well drilling-, construction
                                                                                                    of airstrips, port developments, pipelines; or rehabilitation.
                              Chapter    VI deals with this issue explicitly.        Sulfate        If some of the currently prospective areas that were
                              deposition is expected to be relatively low even under                assessed contain no economically recoverable oil (of which
                              the 5-percent-probability case.       Moreover, data from             there is an 81-percent chance),. then predicted impacts
                              the Prudhoe Bay vicinity, where the FWS has been                      would be substantially less, probably limited to those
                              measuring pH values of ponds and lakes since 1983,                    associated only with exploratory well drilling and cleanup.
                              show that these surface waters are neutral or                         This would be particularly true if delineated prospects in
                              alkaline.                                                             Blocks C and D produced "dry holes." Not only would
                                                                                                    development of the fields not occur, but the main pipeline
                                                   GRAVEL                                           could be shortened by a significant amount, and the Pokok
                                                                                                    port site would be u6n.ecessary.              Such speculation,
                              Several commenters found the implied shortage of                      however, precludes meaningful analysis,
                       gravel in the 1002 area to be somewhat overstated in light
                       of the difficulties encountered with gravel in drilling seismic                     Therefore, as required by the Council on
                       shotholes during the 1983 exploration season.                   Also         Environmental Quality (CEQ) regulations (40 CFR 1502.22)
                       pointed out was the fact that shothole logs and samples                      for, purposes of impact assessment, oil-related activities
                       from the entire area were made available to the Department.
                       The drillers' logs are not adequate for a detailed                           reasonably foreseeable at some point in time in the 1002
                       geotechnical analysis, but they do indicate the presence of                  area were assessed.
                       widespread, thick upland and channel gravel deposits.                               The lands unde     r consideration are National Wildlife
                       Even though the gravel may not be optimally located for all                  Refuge System lands, lands that by their designation and
                       possible developments in the 1002 area, generalizations                      through the legislative history have been deserving of
                       about gravel shortages are inappropriate.             The text has           special resource protection.             Therefore, the impact
                       been revised accordingly.                                                    assessment must.'cleady provide the'Secretary of the
                                         ENERGY CONSERVATION                                        Interior the information necessary for his decision as to the
                                                                                                    recommendation to the Congress.                Through such an
                                                                                                    analysis he can understand and answer the question,
                              Many comments noted the importance of                                 "What is the most that can reasonably be expected to
                       conservation in meeting national energy goals.                    The        happen if the 1002 area is opened to further oil and gas
                       Department of Energy is responsible for the development of                   activity; what natural resource risks and tradeoffs are
                       national energy policy, including means of achieving                         involved?"     It does not present analysis and probable
                       conservation. The Department of the Interior's role in this                  conclusions as to what is the worst that can happen, The
                       energy policy is to comply with its legal mandate to manage                  text has been clarified accordingly.
                       the development of energy resources -on Federal lands in
                       an environmentally acceptable manner. The focus of this
                                                                                                           As further required by the CEQ's regulatory
                       report/LEIS is to respond to the statutory questions about
                                                                                                    amendments (40 CFR 1502.22(b)(3) and (4)), Chapter VI
                       the potential petroleum and biological resources in the 1002                 summarizes existing credible scientific evidence relevant to
                       area, not to review the full scope of national energy policy.
                                                                                                    evaluating reasonably foreseeable significant adverse
                       Nonetheless, a discussion of alternative energy resources,                   impacts, based upon theoretical approaches or research
                       including energy conservation, has been added to Chapters                    methods generally accepted in the scientific community.
                       'V and VI, to give the reader a better idea of the impacts if                There is substantial uncertainty about the ability of wildlife
                       energy development is forgone on the 1002 area.                              in the 1002 area to adapt to oil activity or to seek out other
                       Conservation and increased domestic production are, of                       appropriate' habitats. In the report, the FWS has taken
                       course, complementary components of a broader nat               .ional       special care to identify areas of biological uncertainty.
                       energy policy.                                                               Biological conclusions that can not be drawn with certainty
                                   USE OF "WORST CASE" ANALYSIS                                     have been noted as speculative.

                              Many commenters, especially those from industry,                             The report also recognizes, and in fact places some
                       criticized the FWS for using a "worst case" analysis in                      assurance on, the ability and willingness of the oil industry
                       determining environmental effects.                                           to work with State and Federal regulatory and management

                                                                                               7

                         agencies in consolidating facilities and developing other                        Canadian government entities and some villages were
                         mitigating technology and techniques for environmentally                  concerned that the potential impacts on Canadian Native
                         acceptable Alaska North Slope operations. Even with this                  subsistence opportunities had not been adequately
                         assurance it cannot be assumed that oil and gas activities                considered.      The discussions have been expanded in
                         on the 1002 area will not result in population declines,                  Chapters 11 and VI.
                         changes in distribution, or behavioral changes in certain
                         wildlife species which use the 1002 area for critical
                         segments of their life cycles.                                                                RECREATIONAL USE

                                                                                                          A few commenters wanted precise statistics
                                           CUMULATIVE EFFECTS                                      concerning recreational use of the area. Precise data on
                                                                                                   the average number of recreational visits to the 1002 area
                                A number of individuals commented that        the potential        are not available.    Best estimates for recreational use are
                         cumulative effects of oil and gas leasing and other                       presented in Chapter 11. As stated in the report, data on
                         development activities within the Canadian           and Alaskan          the number of unguided recreational users is not available.
                         Arctic regions had not been fully addressed. In response                  A comparison with other areas of the State would have little
                         to these concerns, a section on cumulative effects has                    meaning.      Special-use permits are issued only for
                         been added to Chapter VI. The discussion of this issue is                 commercial activities or "nonprogram" uses (50 CFR 27.97
                         brief, because the programmatic LEIS/report is intended to                and 29.3). They do not reflect the number of recreational
                         focus on the 1002 area and the specific natural resource                  users visiting the coastal plain, because recreational
                         questions raised by the Congress. The issue of cumulative                 hunters, fishermen, backpackers, hikers, rafters, etc., do not
                         effects would be addressed in detail as part of the                       need permits. A summary of the number of permits issued
                         comprehensive environmental reviews that would be                         per year would be a poor index to the actual recreational
                         required if the Congress authorizes the leasing of oil                    use of the 1002 area.
                         resources within the 1002 area.

                                                  OIL SPILLS                                                          WILDERNESS REVIEW

                                The Alaska Oil and Gas Association, by telegram,                          A few commenters were concerned about a perceived
                         expressed its concern about the 23,000 oil spills referenced              lack of wilderness review as a part of the report/LEIS.
                         in the draft report.    They contended that this number of
                         spills appeared to be erroneously attributed to the North                        Section 1002(h) does not require a wilderness review
                         Slope alone, and asked that the information in Chapter VI                 pursuant to the Wilderness Act. The public land order that
                         be verified.      The figure was obtained through staff                   established the Arctic National Wildlife Range recognized
                         communications between the FWS and the Alaska                             the wilderness values of the range, including the 1002 area.
                         Department of Environmental Conservation, which advises                   The Congress recognized this again in 1980 when it
                         now that the information cannot be verified without                       passed ANILCA, as well as recognizing the possibility that
                         extensive record reviews. Therefore, the reference to 23,000              large quantities of oil and gas may exist on the 1002 area.
                         spills has been removed from the final report, and the                    It excluded the coastal plain from the area within the Arctic
                         discussion clarified.                                                     Refuge that it did designate as wilderness, pending
                                                                                                   consideration of the 1002 area study and further
                                                                                                   congressional action.         Nonetheless, this report/LEIS
                                                                                                   evaluates a wilderness alternative to comply with NEPA.

                                         Socioeconomic Issues
                         :L                (Chapters 11 and VI)                                                  COMPLIANCE WITH TITLE VIII

                                         SO CIOCULTURAL CONCERNS                                          Section 810 of ANILCA requires, prior to any Federal
                                                                                                   agenc     determination to withdraw, reserve, lease, or
                                Concerns that the sociocultural issues were ignored                otherwise permit the use, occupancy, or disposition of
                         in the draft have been addressed.                 A section on            public lands under any of the provisions of the law
                         "Sociocultural System" has been added to Chapters 11 and                  authorizing such actions, that the head of the Federal
                         VI, and the "Socioeconomic" environment has been retitled                 agency evaluate the effects on subsistence uses and
                         the "Human" environment.           The importance of cultural             needs.     Although subsistence uses and needs were
                         values from activities such as subsistence; accelerating                  identified, and the impacts assessed as part of the draft
                         changes to traditional Native activities, and potential benefits          LEIS/report, the Department of the Interior did not conduct
                         of increasing social services are discussed in the new                    a formal 810 evaluation.
                         sections.

                               This final LEIS/report represents recommendations for                        With respect to unidentified prospects (stratigraphic
                        legislative action, rather than a determination under existing              traps and structures smaller than the seismic grid), the text
                        provisions of law. Formal procedural requirements pursuant                  has been expanded to emphasize the concept that the
                        to Section 810 are not required to be met at this point in                  recoverable estimate represents an "Identified minimum"
                        time. If, however, the Congress decides to open all or part                 volume.
                        of the 1002 area to oil and gas leasing, formal 810
                        Evaluations and Findings would be conducted. The statute                            The PRESTO model does include resources from
                        requires that if such an evaluation resulted in a finding of                small,  apparently subeconomic, prospects on those Monte
                        significant restriction to subsistence uses and needs, public               Carlo simulation passes where optimum values for
                        hearings would be conducted in the vicinity of the 1002                     volumetric parameters are sampled from the distributions.
                        area.   It further determination is made that the significant               Naturally, this occurs less often for smaller prospects, and
                        restriction is necessary, the statute requires that the                     so their relative contribution to the aggregate area resource
                        minimum amount of public lands must be considered, and                      is less than for larger prospects. Also, the "most favorable
                        steps to minimize adverse impacts to subsistence must be                    case" economic scenario (table 111-3) provides some idea of
                        assured.                                                                    the effect of lower costs and lower minimum field sizes.

                                                                                                                   PROBABILITY DISTRIBUTIONS
                        Oil and Gas Resource Assessment Issues
                                         (Chapters III and VII)                                             Some   comments indicate a lack of understanding of
                            MARGINAL PROBABILITIES FOR COMMERCIAL                                   the manner     in which both the in-place and recoverable
                                     HYDROCARBON OCCURRENCE                                         resource estimates are presented.
                               Several comments indicated a misunderstanding of                             Owing to the uncertainty inherent in all oil and gas
                        the term marginal probability, as defined as an output of                   resource estimates, current and almost universal practice is
                        the PRESTO model. The text of Chapter III has been                          to use ranges of values for many of the input variables
                        revised and expanded at several points to clarify the                       which affect the volume of resources in a geologic play or
                        definition generally, and the derivation and significance of                prospect, and to report the results as a range of values
                        the marginal probability reported for the 1002 area.             The        with an associated probability distribution.
                        effect of the minimum economic field size on the marginal                           Three "m  easures of central tendency" are associated
                        probabilities of occurrence generated by the PRESTO model                   with probability distributions. These are the mode, the
                        cannot be overemphasized, particularly for remote, high-cost                median, and the mean. For the purposes of characterizing
                        frontier areas such as the 1002 area.                                       a resource distribution curve, the mean is considered most
                               As noted in the revised text, the reported 19 percent                appropriate, because it takes into account the size, as well
                        or a "one in five" chance for the 1002 area can hardly be                   as frequency of occurrence, of values in the range.
                        characterized'as a "high risk" when viewed in the context'                  Technically, the "most likely" value, or mode, is the value
                        of the statistical success rates for discoveries of significant             which occurs most frequently in the range, not the lowest
                        size, to say nothing of the field sizes expected in the 1002                value as suggested by one commenter. The median is
                        area. The statement that there is a 19-percent chance of                    simply the midpoint in the range.
                        finding recoverable oil in the 1002 area needs to be
                        interpreted in the context of past experience in oil                                               GEOLOGIC RISK
                        exploration and resource assessment. Generally speaking,
                        the chance of oil's being present will be lower, the smaller                        The discussion of area, prospect, and zone risk
                        the unexplored area being considered.              The 19-percent           factors used for the Recoverable Resource analysis has
                        chance for the 1.5-million-acre 1002 area thus indicates a                  been revised and expanded, as has the discussion of
                        very high potential when compared to the 27-percent                         marginal probabilities. This will clarify the crucial differences
                        chance for the 37-million-acre Navarin Basin or the 22-                     between prospect and area risk factors, and between input
                        percent chance for the 70-million-acre St. George Basin                     risk factors and output marginal probabilities.
                        (table 111-1).

                               The text in Chapter III has been revised to include                      EXISTENCE OF THE ELLESMERIAN SEQUENCE
                        references to probability of occurrence where appropriate.
                                                                                                            A number of comments focused on the question of
                                                                                                    the presence or absence of Ellesmerian sequence rocks,
                                SMALL AND UNIDENTIFIED PROSPECTS                                    particularly the Ivishak Formation, in the subsurface in the
                                                                                                    1002 area. Certainly, as has been pointed out by several
                               Several commenters expressed concern that the                        commenters, the seismic data alone cannot conclusively
                        economically recoverable resource estimate does not                         resolve this question.      Nevertheless, the data do provide
                        adequately account for potential resources in unidentified                  some basis for considering the possibility in a more
                        prospects, and in the smaller identified prospects.                         favorable light than in the 1980 resource assessment.
                                                                                              9

                               As noted in the description of structure in Chapter               5.     Planning areas are different sizes; the larger the area,
                        111, the only horizon which can be mapped with any                              the greater the likelihood that hydrocarbons will be
                        semblance of continuity across the entire 1002 area is the                      present.
                        top of the pre-Mississippian basement complex. In many
                        parts of the area, parallel and locally continuous reflectors
                        are associated with the mapped horizon, indicating                                    FIGURE 111-2 (PROSPECT SIZES)
                        substantial thicknesses of stratified rocks which have
                        different structural characteristics from the overlying,                        A number of comments indicate some confusion
                        intensely deformed Brooklan rocks.               Some limited            about the intent and proper interpretation of the graphic
                        reprocessing and detailed analyses of seismic data from the              field size comparisons shown in figure 111-2.
                        eastern part of the 1002 area indicate a similarity in
                        character to reflectors known to be associated with                             Figure 111-2 is not intended to imply that undrilled
                        Ellesmerian rocks west of the Canning River.                             prospects in the Arctic Refuge are directly comparable to
                                                                                                 proven fields. The purpose of figure 111-2 is to illustrate the
                               Uncertainty about the existence of the Ellesmerian                range of possibl prospect resources in terms of known
                        sequence was accounted for in risk factors applied to                    quantities that a layman can relate to. The caption for the
                        pertinent play and prospect attributes.       Uncertainty about          illustration has been revised to reflect probabilities
                        quantitative attributes was accounted for in the ranges of               associated with the 1002 prospect resources.
                        values used for volumetric parameters, and reflected in the
                        range of resource estimates.                                                    Some commenters apparently have equated the solid
                                                                                                 black pattern (95-percent probability range) for the 1002
                                                                                                 prospects with the same pattern for proven fields. The
                                  TABLE 111-1 (OCS PLANNING AREAS)                               pattern has been changed to avoid this confusion.

                               Several comments suggested that marginal                                 The text discussion of prospects shown In figure 111-2
                        probabilities for commercial hydrocarbon occurrences for                 has also been revised to reflect probabilities of occurrence.
                        OCS planning areas and for the 1002 area be added to
                        table 111-1.    The table has been modified to show
                        conditional resource estimates for unleased areas only, and                               DATA CONFIDENTIALITY
                        the marginal probabilities have been added. The source for
                        OCS estimates is Cooke (1985).
                                                                                                        A few commenters were concerned by what they
                                                                                                 perceived to be a failure to release for public review and
                               The information in table 111-1, as revised, may be                comment the geologic information critical to the assessment
                        subject to misinterpretation unless certain considerations               process. The subsurface seismic information was collected
                        are kept in mind:                                                        by a permittee-Geophysical Service Inc. (GSI)--and
                                                                                                 submitted to the U.S. Government under 50 CFR Part 37.
                        1.     For areas where a commercial discovery has                        It is protected under the these regulations which require
                               occurred, no matter how small, the marginal                       the Government to hold confidential or proprietary the
                               probability for occurrence of commercial                          geologic data collected by a permittee on the 1002 area.
                               hydrocarbons is by definition 100 percent.
                        2.     For OCS planning        areas, some of the reported                      Analysis in the report is based on government-
                                                                                                 processed data resulting from processing industry's raw
                               marginal probabilities may be based on the                        data (seismic tapes). The Department will make raw data
                               probability of occurrence of commercial gas                       available to the public after the report is formally submitted
                               accumulations.     For the 1002 area, only oil was                to the Congress, pursuant to regulations (50 CFR Part
                               considered.                                                       37.54). Industry-processed, analyzed, and interpreted data
                                                                                                 obtained as a result of exploration activities by the
                        3.     The relatively high marginal probability for the                  permittee or a third party will not be released.to the public
                               Beaufort Sea planning area may be a consequence of                until 10 years after the submission of such data or
                               a "potentially commercial accumulation" at Seal Island            information, or until 2 years after any lease sale, whichever
                               (Cooke, 1985, p. 33), which extends into the planning             period is longer, in accordance with the regulations.
                               area. If the planning area were subdivided, it is very
                               unlikely that the eastern Beaufort Sea offshore from                     The volume of geologic data and the proprietary
                               the 1002 area would have such a high probability for              nature of the seismic data precluded including all data in
                               commercial hydrocarbons.
                                                                                                 the Chapter III summary of the geology of the 1002 area.
                                                                                                 Scientists of the GS and BLM reviewed all the data to
                        4.     In making comparisons between the areas shown in                  present this condensed report for the government and the
                               table 111-1, both the volume of resource and the                  public.  A more comprehensive technical report (USGS
                               probability of occurrence should be considered (see               Bulletin 1778) will follow later this year.
                               Cooke, 1985, p. 13).

                                                                                           10

                              Conversely, GSI's comments focused on what they                                          NATURAL GAS
                       perceived to be a breach of the regulations concerning
                       some of the data and level of detail in Chapter III and the                      Comments on     the subject of natural gas resources in
                       accompanying plates. Because of continued concern from                    the 1002 area fall into two categories:
                       members of the GSI participant group, the Department
                       thoroughly reviewed its data confidentiality policy during                1.     Section 1002, NEPA, and CEQ require an assessment
                       1986, and the regulations implementing the exploration                           of the environmental effects of exploration for and
                       program (50 CFR Part 37). The review led the Department                          development of natural gas, as well as oil.
                       to reaffirm its previous decision that the government-
                       processed data (government seismic record sections) are                   2.     The potential significance and future value of natural
                       not required to be withheld pursuant to 50 CFR 37.54(a).                         gas deposits are not adequately addressed.
                       Data in the report are based entirely on government-
                       acquired information, and raw data (seismic tapes) acquired                      With respect to the first concern, exploratory wells in
                       by GSI.                                                                   the 1002 area could encounter dry gas, oil, oil with
                                                                                                 associated gas, or water.        The impacts of exploratory
                                                                                                 drilling would be the same regardless of what is found.
                                               OIL PRICES                                        The effects of natural. gas development and production
                                                                                                 would be somewhat less intensive than for oil, due to wider
                              Many commenters questioned the assumptions                         well spacing and smaller production facilities, but would
                       regarding oil prices used for economic analyses which are                 involve virtually the same surface area.        That is, for the
                       the basis for the minimum economic field size estimates in                purposes of impact analysis, the same prospects would be
                       Chapter III.                                                              considered. In the unlikely event that only gas would be
                                                                                                 produced from the 1002 area, impacts associated with a
                              Oil price assumptions used in the economically                     trunk pipeline would likewise be less, inasmuch as *hot
                       recoverable resource analysis, were developed for the year                oil"/permafrost engineering problems would not be a factor.
                       2000 and beyond, when crude oil production from the 1002                  It might be possible to bury a gas pipeline over most of its
                       area was forecast to begin. Therefore, these prices are not               length. Concurrent development and production of oil and
                       directly comparable to current crude oil prices. The $33                  gas from the same prospect and the area would have
                       per barrel (1984 dollars) oil price assumed in the most likely            roughly the same impacts as for oil alone, as was pointed
                       case analysis for 1002 area crude oil was set at an                       out in the draft report.
                       intermediate level from the range of future oil prices
                       projected in numerous price forecasts.          These forecasts                  With respect to the second concern, the method
                       were conducted by the Department of Energy (DOE);                         used   for the estimation of economically recoverable
                       private research firms, such as Data Resources                            resources In the 1002 area requires the estimation of a
                       Incorporated; and several oil companies such as Chevron                   minimum economic field size for each prospect, which in
                       Corporation, Texaco, Conoco, and Ashland Oil, and were                    turn, requires demonstration of a positive net present value.
                       the latest available at the time the analysis was completed.              Given the cunrent economics of North Slope natural gas,
                       Recent, unpublished DOE projections indicate an 8-percent                 and the immense proven gas reserve base elsewhere,
                       reduction from DOE estimates available at the time the                    natural gas from the 1002 area simply cannot be
                       analysis was completed,                                                   demonstrated as having any present economic value using
                                                                                                 standard discounted cash flow procedures. See Young
                              A complete and thorough discussion of the sources                  and Hauser (1986) for a complete discussion of natural gas
                       of oil price forecasts and related assumptions is included in             economics for the 1002 area.
                       Young and Hauser (1986).

                                                                                                                   ECONOMIC SCENARIOS

                                       OIL PRICE GROWTH RATE
                                                                                                        Several commenters expressed the opinion that a
                              Several comments suggest that the rate of increase                  pessimistic" or low-side recoverable resource assessment
                       in oil prices used In    .the report should be the same as                should be included based on lower oil prices, as well as
                       used by the U.S. Minerals Management Service (MMS).                       the "optimistic" or "most favorable" case.
                              In the recently published MMS 5-year Outer                                Sensitivity analyses were conducted to determine
                       Continental Shelf Oil and Gas Leasing Program for 1987,                   effects of variations in several economic parameters,
                       the starting oil prices ranged from $9 to $34, in 1987                    including oil prices, on the economics of "typical"
                       dollars. The year 2000 prices ranged from $10 to $45, in                  prospects in the western and eastern parts of the 1002
                       1987 dollars. The $33/barrel price (1984 dollars) used in                 area. The lowest oil price modeled was $22/barrel (year
                       this LEIS clearly falls within that range when the MMS                    2000 price, 1984 dollars). The minimum economic field size
                       figures are adjusted to 1984 dollars.          The figures used           for the eastern 1002 area prospect using this price is over
                       herein are thus consistent with the MMS figures.                          2 billion barrels (recoverable). For the western 1002 area

                         prospect, the minimum field size would be about 1.4 billion,                scenarios, described In this LEIS represent very broad
                         barrels. Minimum field' sizes for actual prospects in the                   assumptions that were made as a basis for identifying
                         1002 area, using this price, were not estir6ated, but it Is                 characteristic activities and any resulting environmental
                         likely that the minimum for the area would be close to that                 effects. These assumptions do not, represent a Department
                         for the "typical* western prospect (1.4 BBO). All else being                of the Interior recommendation, preference, or endorsement
                         equal, the effect of this would be to lower the marginal                    of any facility, site, or development plan. Local control of
                         probability for commercial hydrocarbons from the 19-percent                 events may be exercised through planning, zoning, land
                         .most likely" case.                                                         ownership, and applicable State and local laws and
                                                                                                     regulations.

                                         National Need Issue                                                If the area is eventually made available for further
                                                (Chapter VII)                                        exploration or leasing, site-specific NEPA compliance, and
                                                                                                     compliance with -sections of ANILCA and numerous other
                                                                                                     Federal, State and local requirements, would ensure full
                                      MARGINAL PROBABILITIES AND                                     coordination with all entities that would be affected.
                                            THE NATIONAL NEED
                                                                                                                   CONSULTATION WITH CANADA
                                Many commenters; suggested that the          National Need
                         ana Ilysis In Chapter VII is misleading, and        that projected                 The Canadian Government was concerned that
                         economic benefits are overstated, because the analyses are                  consultations had not been adequate.                The following
                         based on conditional recoverable resource estimates.                        information leads the Department of the Interior to conclude
                                                                                                     differently:
                                The economic and domestic supply benefits                                   The Canadian Wildlife Service (CWS) and          . its Yukon
                         described In Chapter VII (and the environmental
                         consequences of development described In Chapter VI            .) are       Wildlife Branch Independently conducted studies of              .;.  the
                                                                                                    .,Porcupine caribou herd (PCH). during 1978-81' relative4o
                         conditional on the discovery of commercial quantities of oil
                                                                                                     potential oil and' gas developments In the Yukon: Ternt'or''
                                                                                                                                                                         y
                         In the 1002  area.
                                                                                                     and Northwest Territories.        In conducting the studies. for.@.
                                The -purpose of estimating economically recoverable                  preparation of the baseline reports and the Report ito
                                                                                                     Congress, the FWS; worked closely with biologists from the,..
                         hydrocarbon resources was to provide a basis for
                         assessing p    .ossible environmental and socioeconomic                     CWS, and the State of Alaska as well.
                         effects of development, and 'for projecting potential                              Before assessing the effects of oil and gas
                         economic benefits- of developing. For the 1002 area, the                    development, production, and transportation In the 1002
                         Congress specifically -requires an evaluation of how the                    area, the FM conducted a Caribou Impact Analysis
                         potential resources of the area relate to. domestic oil and                 Workshop, as explained In Chapter VI of both the draft and
                         gas supp@y-and-demand projects. None of these types of                      final LEIS/reports. Canadian biologists participated at FWS
                         analyses can be conducted using risked resource                             invitation. The forum provided the opportunity for FWS
                         estimates.                                                                  biologists to compare research results and gain valuable
                                                                                                     information on what Impacts.1he, Canadian's own
                                                Otherissues,*                                        transportation and exp     -loration activities.may have had In
                                                                                                     and near the PCH's migration routes and concentrated
                                   CONSULTATION AND COORDINATION                                     calving and wintering areas.
                                The North Slope Borough and a few other                                     In addition to the technical consultations that have
                         commenters expressed concern that there appeared to be                      occurred Independent of the 1002 process, representatives
                         no specific mechanisms outlined In the report to ensure                     of the FWS and CWS had been negotiating a PCH
                         public, Involvement in Federal decisionmaking concerning                    agreement for the past several years. This agreement calls
                         development of the 1002 area.
                                                                                                     for both countries to take appropriate steps to ensure
                                Chapters 1, IV, V, and VI recognize the existing                     International cooperation and coordination of actions that
                         statutes that require coordination and consideration during                 may affect this Internationally shared resource, In order to
                         the various stages of development, If the 1002 area Is                      conserve the species and its habitat. The agreement would
                         opened for oil leasing. It would be premature to outline                    establish an advisory board to assist in management. Such
                                                                                                     an agreement will enhance consultation on. future activities.
                         specific measures at this point In the process. The final
                         LEIS/report provides a broad, programmatic discussion of                           Once the draft 1002(h) LEIS/report was made
                         management options for the Congress to consider.                            available to the Congress and the public for review, the
                                This report is not intended to be, nor should it be                  Assistant Secretary of the Interior for Fish and Wildlife and
                         used as, a local planning document by potentially affected                  Parks sent the Embassy of Canada a letter of Invitation to
                                                                                                     consult on the draft report.         To date, three consultation
                         communities.       The facility locations and transportation

                                                                                               12

                      sessions have been held--two in Ottawa and one In                       interests on the 1002 area for Native and State owned
                      Washington, D.C. The Government of Canada submitted                     Inholdings within other National Wildlife Refuges In Alaska.
                      written comments on the report. The consultations have                  Of primary concern was the lack of discussion of an
                      further provided both countries the opportunity to discuss              exchange and Its associated environmental and economic
                      the biological and geological data upon which the                       impacts in the draft report.
                      assessments are based, and to address the assessment of
                      potential impacts on the PCH and other internationally                         The determination as to whether the Department
                      .shared wildlife resources from possible development                    would propose such an exchange could not be made until
                      activities. Either country may Initiate further consultations.          after the Secretary had decided upon his recommendation
                                                                                              to the Congress regarding future management of the 1002
                                          PUBLIC HEARINGS                                     area. A discussion of the exchange was not included in
                                                                                              the draft or final reports. Exploration and development of
                             The Department was criticized for the number of                  State or private oil and gas interests within the 1002 area
                      public hearings scheduled.        As noted elsewhere In this            would be subject to the same regulations and
                      section, public hearings were held In Anchorage and                     environmental controls as Federal lands In the area, and so
                      Kaktovik, Alaska, and Washington, D.C. The hearings                     the draft and final reports do In effect describe the potential
                      satisfied the requirements of the National Environmental                impacts of such operations on Arctic Refuge resources and
                      Policy Act, and the court's order In Trustees for Alaska, el            subsistence use.
                      al., v. Donald P. Hodel that public hearings be held in
                      Alaska and elsewhere. Furthermore, the report was widely                       Although    s,ection 910 of ANILCA exempts land
                      distributed and received International media coverage. Most             exchanges. with    Alaska Natives from compliance with the
                      of the media used Interior-prepared press releases and.                 National Environmental Policy Act, the FWS ascettainment
                      emphasis was placed on the fact that oral testimony and                 reports which would accompany any exchange proposal
                      letters of comment submitted through the mail were given                that may be submitted to the Congress would specifically
                      equal consideration.                                                    address impacts of any land exchange on the 1002 lands,
                                                                                              as well as on the refuge Inholdings to be acquired, and
                             Because the concerns expressed at the three                      would discuss the economic effects of exchanging limited
                      hearings were comprehensive and substantially the same as               1002 area oil and gas.interests. The ascertainment reports
                      written comments received, additional hearings would have               would also discuss other options considered and the
                      provided a forum for people to express their opinions, but              rationale for selecting a land exchange as the means of
                      probably would not have raised any new matters warranting               acquiring Alaska refuge inholdings.
                      further revision of the report. The Department believes, as
                      was its intent with an LEIS, that the proper forum for this                    The Department's efforts related to a possible land
                      debate Is the Congress.        The Congress will make the               exchange have been independent of those aimed at
                      actual decision, after the Secretary's role of analysis and             preparing and submitting the 1002 report, and have
                      recommendation. There will be ample opportunity for public              therefore, not compromised the objectivity of the report or
                      Input during congressional consideration of this report.                the Secretary's recommendation. An exchange agreement
                                                                                              will be submitted to the Congress only If the Secretary
                                         SUBMERGED LANDS------------,                         determines the exchange to be In the public Interest.
                                                                                              Furthermore, implementation of a land exchange will be
                             The State of Alaska criticized the report for not                contingent upon Congress opening the 1002 area to oil and
                      addressing the ownership status of the beds of nontidal                 gas exploration, development, and production, and upon
                      inavigable waters. The State asserts ownership of the                   congressional approval of any exchange agreement.
                      submerged lands Underlying the Alchilik, Jago. Okpilak,
                      Hulahula, Sadlerochit, Staines, and Canning Rivers within                      Although an exchange of this nature *would -create
                      the 1002 area. The FWS. does not recognize the State of                 private Interests on the Arctic Refuge, it would actually
                      Alaska's claim to these submerged lands. Although the                   result in a net reduction of private Inholdings on Alaska
                      State usually has      ownership status for the. beds of                refuges due to the multiple return expected for each acre
                      navigable v;aterways, the Federal Government claims lands               exchanged on the 1002 area. Also, only subsurface oil and
                      submerged under navigable waters that were reserved to                  gas Interests In the Arctic Refuge would be exchanged
                      ,,the Federal Government prior to statehood (January 3,                 Surface ownership and-control would remain vested In the
                      '1959). The Arctic Refuge lands were w      Ithdrawn for military       Federal Government.        Any exchange agreement would
                                                                               9;1
                                       to this date (Public Land Order 82, 1                  contain such surface use provisions as are necessary to
                      purposes prior
                                                                                              ensure protection of refuge resources and maintain the
                                                           _b(CHANGE                          integrity of the area.
                                 ARCTIC REFUGE

                             Several commenters expressed concern about the
                      Department's participation in negotiations with the State of
                      Alaska and with a number of Alaska Native corporations,
                      regarding   the possible exchange of limited oil              gis

                          DEVELOPMENT AND TRANSPORTATION SCENARIOS
                                               (CHAPTER M

                               Much of the original (draft) description of facilities,
                         equipment, procedures, and practices included in Chapter
                         IV was obtained through consultation with oil companies,
                         from trade publications, or from exploration and
                         development plans and proposals. Most of the comments
                         received on Chapter IV are likewise from oil companies or
                         trade associations and concem recent advancements in
                         technology or altemative technological approaches not
                         considered In the dmft LEIS. These comments, have been
                         accommodated by minor changes In the text. However,
                         where there is some question as to the universal
                         applicability of an Improved or aftemative technology cited
                         from the Prudhoe Bay area, the technology Is
                         acknowledged In the text as a possibility, but not
                         necessarily endorsed as being applicable for the 1002 area.

                                                                                       14

                                                         Comments from Federal Governments and Agencies (F)

                                                                                                                                                     Page

                                                       Government of Canada           .................................................................................... F- 1

                                                         .Northwest Territories      ..................................................................................... 16

                                                         Yukon Territory      ............................................................................................... 20

                                                       U.S. Army Corps of Engineers            ....................................................................... 50

                                                       Environmental Protection Agency            .................................................................... 59

                                                       Marine Mammal Commission              .......................................................................... 62

                                                       Minerals Management Service            ......................................................................... 66

                                                       N ational Park Service, Denver, CO           ................................................................ 80

                                                       National Park Service, Washington, D.C            . ...................................................... 81

           POSITION PAPER.                              EXPOSt DE POSITION

                   OF                                               OU                                                               TABLE OF CONTENTS

                                                                                                                   Introduction                                  P- I

                                                                                                                   Transboundary Resources                       p. 2

                                                                                                                   Subsistence Needs                             P- 2

                                                                                                                   Cumulative Effects                            P. 3
                                   CANADA                                                                          Oil and Gas Estimates                         p. 4
                                                                                                                   The Prudhoe Say Comparison                    P. 5
       -T1     ON THE                                              SUR
                                                                                                                   Water and Gravel                              P. 5

            .UNITED STATES DEPARTMENT OF THE INTERIOR'S DRAFT                                                      Consultations                                 P. 6

                       "ARCTIC NATIONAL WILDLIFE REFUGE,                                                           'Conclusion                                   P. 63

                                                                                                                   Technical Appendix:
                                                                                                                   Review of Wildlife Aspects
               ALASKA COASTAL PLAIN RESOURCE ASSESSMENT"

                                         OTTAWA

           FEBRUARY 3, 1987                                 LE 3 FEVRIER 1987

                                                                                                                                              2

                                                                                                            mark the international and regional significance of the area by
                                    POSITION PAPER OF THE
                                                                                                            undertaking to twin the protected areas on both sides of.the
                                    GOVERNMENT OF  CANADA                                                   border.

                                              ON
                                                                                                                       The following analysis which underpins   Canada's. vie,--V
                    THE DRAFT "ARCTIC:NATIONAL   WILDLIFE REFUGE, ALASKA
                                                                                                            addresses  these major themes: the nature of the     wildlife
                             COASTAL PLAIN RESOURCE ASSESSMENT"                                             resources  which will be affected and their importance for
                                                                                                            Canadians; the hydrocarbon potential; and identified and
                                                                                                            unidentified risks. it is the conclusion of the Government-of
                         The Government  of CanadIahas reviewed in.detail the                               Canada that in this case the risks associated with opening the
               content and recommendations of the  draft "Arctic National                                   coastal plain to development far outweigh the potential
               Wildlife Refuge, Alaska,' Coastal Plain Resource Assessment"                                 benefits. The core of the Canadian position is the inter-
               prepared by the U.S. Department of  the Interior. Within the                                 national significance of developments on   'shared transboundary
               time constraints imposed, the draft  Environmental Impact State-                             wildlife resources. A separate technical appendix on this
               ment (ElS) has been closely studied  by Canadian territorial                                 subject is attached. This Canadian position paper concludes
               governments, native groups, the Canadian Porcupine Caribou                                   with some notes on the consultative process.
               Management Board and federal government agencies. On the
               strength of this analysis, the Government of Canada firmly                                              Transboundary Rescurcess The wildlife species
       -n      believes and urges that the 1002 lands should be given wilder-                               along the Alaska/Yukon border and the fragile ecosystem upon
               ness designation and dedicated to those primary values    for                                which these resources depend are important resources which.are
               which the Alaska National Interest Lands Conservation Act                                    shared by Canada and the United States. The draft EIS,
               (1980) (ANILCA) was passed:   "to preserve for the benefit, use,                             however, does not address the fact that the most heavily
               education, and inspiration of present and future generations                                 affected species are shared resources. A significant reduction
               certain lands and waters in the State of Alaska that contain                                 in shared wildlife migratory resources such as caribou, Lesser
               nationally significant natural, scenic. historic. archeo-                                    Snow Geese, Polar Bears, fish or marine mammals, occasioned by
               logical, geological, scientific, wilderness, cultural,                                       developments envisaged in the 1002 area, would entail unaccept-
               recreational, and wildlife values          The measures which.the                            able damage to Canada. The attached technical appendix on
               U.S. has taken to protect complete arctic ecosystems have                                    wildlife resources addresses in detail the Canadian   .concerns.
               helped convince Canadians to proceed with complementary
               protection mechanisms including the three million,acre North                                            Subsistence needes The shared resources in
               Yukon National Park. It would indeed be regrettable if these                                 question are critical to the well-being of certain Canadians in
               advances were lost, based upon an incomplete understanding of                                the communities of Dawson City, Mayo, and Old Crow in the
               the total spectrum of the values of the region. Accordingly,                                 Yukon, and Fort McPherson,.Arctic Red River, Alkavik, Inuvik,
               in addition to urging that the lands.in question be given                                    and Tuktoyatuk in the Northwest Territories, and their ability
               wilderness designation, Canada proposes that both governments                                to maintain a traditional way of life. Caribou, waterfowl and
                                                                                                            other transboundary wildlife species are essential to the
                                                                                                            subsistence economies of certain groups of native Canadians.

                                                                            2

                                                                                                                                                                           3

                                                3                                                                                            4

             The principal concern here is for the caribou. For instance,                                     measures are without any lasting result  a when negated by
             the 1002 area contains some 78% of the core calving grounds of                                   detrimental activities elsewhere in the region.
             the Porcupine Caribou Herd (PCH). The draft EIS predicts that
             full leasing "could result in a major population decline and a                                             oil and gas estimatess Since the full technical
             change in distribution of 20-40 percent" of the PCH. A                                           data set is not available to Canadian geoscientists, it has not
             population decline of this magnitude and the likely prospect of                                  been possible to undertake a comprehensive hydrocarbon assess-
             a disruption of traditional migratory patterns would mean the                                    ment for the area. Canada questions some of the assumptions
             principal source of the subsistence enonomy would be unavail-                                    upon which the assessment is based. These assumptions have
             able. Subsistence users of caribou are principally located in                                    lead to an optimistic view of the resource potential of the
             Canada. The estimated annual harvest of the PCH is approxi-                                      area, which has directly influenced the recommendations.
             mately 5,000 which varies with the movement of the herd. In
             some years 80 percent of the harvest is in Canada. Canadian                                                The 1002 area is largely undrilled and should be
             caribou-using communities depend heavily on these animals., The                                  regarded as rank wildcat territory. As a consequence, the
             draft EIS largely underestimates the significance of develop-                                    assessment is based on the extension of geological trends from
             ment to Canadian subsistence users. The EIS does not mention                                     outcrop and well control located to the west and south. Funda-
             the possible impact from the loss of caribou to the Mackenzie                                    mental to the assessment is the comparison with the geology and
             Delta communities such as Fort MacPherson, Arctic Red River and                                  discovered pools in the Prudhoe Bay area.     In Canada's view,
             Aklavik which are now the largest users of the herd. In                                          the critical assumptions are as follows.
      -.n    addition, the Alaskan community of Kaktovik may have access to
             the Central Arctic herd, but the residents of old Crow have no                                             The primary reservoir unit at Prudhoe Bay has been
             alternative and they and the communities in the Northwest                                        assumed to underlie a portion of the area.     Since a significant
             Territories may not be able to harvest enough to meet their                                      fraction of the oil potential is ascribed to this reservoir
             needs if the predicted impacts on population and distribution                                    section. the risk of its absence is critical. Further, most of
             occur.                                                                                           the potential in the unit is assumed to be contained in a few
                                                                                                              very large structures. However, the seismic data indicate that
                        Cumulative effects: Canada notes that the draft                                       these features are internally structured, leading to a qreater
             EIS does hot provide for an assessment of the cumulative                                         uncertainty in the identification of the key seismic reflectors
             effects of development on 1002 lands with other regional                                         and the possibility that each feature could consist in fact of
             developments. Any decision to proceed with 1002 development,                                     smaller pools rather than one large feature. This observation
             through the availability of infrastructure and services, will                                    of complex structuring also applies to other plays in the
             make development on the Outer Continental Shelf more likely.                                     assessment. Finally, the pool size distribution predicts four
             Equally true is that offshore development will render 1002                                       large pools, each roughly one-third of the size of Prudhoe Bay.
             development more probable.    Until the cumulative impacts of                                    While the possibility of large pools in the range exist, the
             Various development proposals have been fully studied and                                        likelihood of several in this size range is remote.
             understood great caution must be exercised if major and perhaps
             irreversible damage is to be avoided. Site-specific mitigative
                                                                                                                                                                               5

                                                                            4

    -5-

    In summary, each of these assumptions has led to an
    optimistic assessment of the oil and gas potential of the area,
    which has directly influenced the overall recommendation.

    The Prudhoe Bay comparison:  Canada notes that
    while the draft EIS attempts to extrapolate the experience
    acquired in Prudhoe Bay to the 1002 areas, there are serious
    inconsistencies between the Recommendations (p. 169-170) and
    the content of the preceeding parts of the document.  These
    contradictions are outlined in greater detail in the attached
    technical appendix.  The Recommendation puts great emphasis on
    the situation at Prudhoe Bay noting that despite petroleum
    development "the fish and wildlife resources of the Prudhoe Bay
    area remain extremely healthy" and that "the Central Arctic
    caribou hard (CAH) has increased substantially during the
    period that development has occurred within the heart of its
    range" (p. 169).  In constrast, the preceeding sections of the
    assessment stress that the CAH has increased because of lighter
    hunting and greater calf survival.  In addition, "movements,
    density, and traditions of the PCH differ from those of the
    CAH" (p. 106).

    Nothing in the Prudhoe Bay experience provides a
    basis for evaluating or mitigating the effects of oil and gas
    activities on staging Snow Geese.  Clearly, the Prudhoe Bay
    experience should not diminish Canadian or U.S. concern for this
    wildlife resources of the 1002 area.

    Water and Gravel:  The report acknowledges that
    specific locations and sources of water and gravel for explora-
    tion and development activities have not been identified
    (p. 75).  It further states that these resources are not
    readily available on the 1002 area.  It should be expected that
    the acquisition and transport of adequate water and gravel
    supplies and their subsequent storage will further exacerbate

    									...6

    -6-

    problems associated with degradation of habitat and disturbance
    to wildlife.

    Consultations:  Section 1005 of ANILCA directs
    the Secretary of the Interior to work with various U.S.
    interests in preparation of the EIS.  The same section
    continues "In addition the Secretary shall consult with the
    appropriate agencies of the Government of Canada in evaluating
    such impacts particularly with respect to the Porcupine Caribou
    Herd".  There was no consultation with the Government of Canada
    prior to the release of the draft EIS.  Neigther the ongoing
    negotiations with respect to the Agreement on the Conservation
    of the Porcupine Caribou Herd which predate ANILCA, nor the
    opportunity afforded Canadian territorial governments and
    agencies to comment on the draft EIS, can be construed as
    responding to the U.S. legislative requirement for consultation
    with a sovereign neighbour and friend.  Had consultation taken
    place prior to the release of the draft EIS it is to be hoped
    that the document would have dealt with the serious Canadian
    concerns identified in this paper.

    Canada welcomes the establishment of this dialogue
    and looks forward to its continuation.  In particular, Canada
    would seek further consultations with the United States before
    the EIS is finalized particularly if the Secretary of the
    Interior's final recommendation to Congress is to propose any
    of those options which will have negative impact on Canada and
    Canadians.

    Conclusion:  Mr. Justice Thomas R. Berger, former
    Judge of the Supreme Court of British Columbia, in submitting
    his Report on the Mackenzie Valley Pipeline Inquiry to the
    Canadian Government made the following point:

    								...7

                                                7                                                                                            8

                his Report on  the Mackenzie Valley Pipeline Inquiry to the                                   Canadian calving grounds of  the PCH. Similar conservation
                Canadian Government made the following points                                                     A
                                                                                                              measures are being negotiated for lands south of the Yukon
                                                                                                              North Slope.
                           "There is a myth that terms and conditions that will
                           protect the environment can be imposed, no matter how                                        "Long-term losses in fish and wildlife resources,
                           large a project is proposed. There is a feeling                                    subsistence uses, and wilderness values would be the inevit-
                           that., with enough studies and reports, and once                                   ableIconsequence of a long-term commitment to oil and gas
                           enough evidence is accumulated, somehow all will be                                development in the area" (p. 143). A decision to    develop
                           well. it is an assumption that implies the choice we                               commits the 1002 area to petroleum operations for   a period of
                           intend to make. It is an assumption that does not                                  30-90 years, to pressure to use this area as a base to service
                           hold in the North                                                                  exploration and development of the Beaufort Sea, and to
                                                                                                              pressure to open adjacent areas designated as wilderness to oil
                           We should recognize that in the North, land use                                    and gas exploration.
                           regulations..based on the concept of multiple use,
                           will not always protect environmental values, and                                            The Government  of Canada, following careful analysis
                           they will never fully protect wilderness values.                                   of the EIS, has concluded that the risks of oil and gas
                           Withdrawal of land from any industrial use will be                                 development far outweigh the benefits. Canadian native people
                           necessary in some instances to preserve wilderness,                                are working to develop local economies sustained by renewable
         -n                wildlife species and.crftical habitat." (pp. xi-xii),
         2.                                       11 @                                                        resources. Canada regrets the general lack of appreciation of
         01                                                                                                   the immense value of Por cupine Caribou to northern native
                           Canada commends to the attention of the United States"-
                                                                                                              cultures.
                Government the impressive body of evidence collected by the
                U.S. Fish and Wildlife Service which demonstrates serious                                               Canada urges the United States Government to
                deleterious effects on the quality of the habitat of the area                                 recognize the serious implications for Canada of development of
                and on shared transboundary wildlife resources. Canada urges-,                                the 1002 lands, and to adopt Option E - Wilderness Designation.
                that the United States recall that the Arctic National Wildlife                               Canada further proposes that both our governments mark..the
                Range was established "for the purpose of preserving unique                                   regional and international importance of this area by@.,
                wildlife,,wilderness, and  recreational values" and that ANILCA                               considering a twinning of  protected areas on both sides-of    our
                established the Arctic National Wildlife Refuge primarily "to                                 border.
                conserve fish and wildlife populations in their natural
                diversity ..." Canada has set aside lands for conservation to
                meet the same goals. Specifically, the Yukon North Slope (the
                Arctic watershed) falls under a special conservation regime
                whose dominant purpose is the conservation of wildlife, habitat
                and'traditional native use. Within that regime, the Northern
                Yukon National Park has been established to include the

                                                                                8

                                                                                                              Canadian Government Review of the Wildlife Aspects
                                                                                                                          of the November 1986 Draft
                                                                                                                  "Arctic National Wildlife Refuge, Alaska,
                                                                                                                      Coastal Plain Resource Assessment"

                     Canadian Government Review of the Wildlife Aspects
                                 of the November 1986 Draft                                               'The wildlife resources of the Arctic symbolize our common
                         "Arctic National Wildlife Refuge, Alaska,                                         heritage.  Their preservation, being a matter of deep
                             Coastal Plain Resource Assessment"                                            concern to both nations, provides a challenge and hopefully
                                                                                                           an opportunity for co-operation"... James Smith,
                                                                                                           Commissioner of Yukon, 1970.

                                                                                                      Introduction
                                     Technical Appendix

                                                                                                           Northeastern Alaska and the adjacent northern Yukon are
                                                                                                      unique in North America in the high diversity of fauna and flora
                                                                                                      that they support in relatively undisturbed ecosystems. The
                                                                                                      close proximity of mountains to ocean with an intervening coastal
                                                                                                      plain produces an impressive variety of habitats on both
                                                                                                      unglaciated and glaciated terrain. The flora and fauna of the
                                                                                                      area are an unique mixture of species which survived the last
                                                                                                      glaciation essentially in situ and those that have invaded from
                                                                                                      the south and east since deglaciation. Many of the resultant
                                                                                                      ecosystems are truly unique and irreplaceable. The value of the
                                                                                                      area has long been recognized and led to the establishment of the
                                                                                                      Arctic National Wildlife Range in 1960 and to the recommendation
                                                                                                      of Justice Thomas Berger in his 1977 Report of the Mackenzie
                                                                                                      Valley Pipeline Inquiry that all of northern Yukon be set aside
                                                                                                      as-a wilderness park.

                                                                                                                                                                     2

                                               2

                  Justice Berger also urged that the Governments of Canada
            and the United States of America establish an International
            Wilderness Park in recognition of the    international importance of
            those lands in northern Yukon and northeastern Alaska. Many of
            the species of wildlife using the area are shared pop     ulations                                                        Beaufort Sea
            that depend on habitats in both countries.

                  Since the U.S. creation of the.Arctic   National  Wildlife
            Range and Justice Thomas Berger's Report, Canada has put in place
            the following measures in order to better protect thenorthern
            renewableresources shared with the United States:

                  All lands in the Yukon Territory.north of    the Porcupine and
            Bell Rivers were withdrawn from development in     1978 by the                                  4      CX
            Government of Canada;

         -,n      a) The 3,000,000  acre Northern. Yukon National Park (Z  one I
            iin attached Figure) was established   by the @Western Arctic                                                                                Territories
            (Inuvialuit) Final Agreement and Claims Sett   lement. Act" of   1984
            with preservation of the wildlife and wildernesscharacter       of the
            park for present and future its primary goal.                                                                     'A
                                                                                                                              it                     1A

                  b) East of Northern..Yukon National Park on the north slope
            are lands included in the Inuvialuit Final Agreement (Zone 2).                                     Yukon
            The lands all fall undera "special conservation regime whose
            dominant purpose is the conservation of wildlife, habitat and
            traditional native use".

                  c) Zone 3a is proposed for addition to the existing National
            Park.

                  Although all of the Northeastern Alaska and adjacent
            northern Yukon areas are important for wildlife, some are more
            critical than others. One of these areas lies, in part, within
            the lands designated under Section,1002 of the A    laska National

                                                                                 3
                                                                                                                                      Beaufort Sea

                                             3                                                                                             4

            Interest Lands Conservation Act.                                                                   The maj ority of wildlife species using the 1002 area also
                                                                                                         depend on Canadian habitats to some degree, but this review will
                 The southeastern portion of  the area, Block D and parts of                             concentrate on three shared key species of particular importance
            ,Blocks B and C, which is about 19% of the 1002 area, contains the                           to Canada:. the Porcupine Caribou Herd, Western Arctic    .Lesser
            core calving area of the Porcupine Caribou Herd and much of the                              Snow Geese and Beaufort Sea Polar Bears.    These would suffer
            critical feeding area for Lesser Snow  Geese. As noted in the                                major or moderate effects should oil   Iand gas activity pr.oceed as
            draft Arctic National Wildlife,Refuge, Alaska, Coastal Plain
                                                                                                         proposed. Throughout these comments reference is made to the
            Resource Assessment (hereinafter referred to as the EIS or 1002
                                                                                                         pages of the EIS. In preparing the report, the U.S. Fish and
            Assessment):  "The Porcupine Caribou Herd (PCH) core calving area                            Wildlife Service has done an excellent job of reviewing the
            is considered unique and irreplaceable.   Habitat in this area has                           information available and in estimating the potential effects      of
            been designated Resource Category I because of its high fish and                             petroleum development.
            wildlife values, particularly for PCH caribou. The U.S. Fish and
            Wildlife Service normally recommends that all losses of Resource                             Caribou
            Category 1 habitat be prevented, as these one-of-a-kind areas
            cannot be replaced" (p 98).                                                                           Caribou are the deer of the North.    Shaped by the snows
                                                                                                                 of millennia, they are completely at home in the country
         _n     Knowledge of wildlife in northeastern Alaska and northern                                        of winter. Theirs.are the lands so recently emerged from
        Cb  Yukon may be the most comprehensive of any equivalent size area                                      beneath the snow and glaciers of the great ice age: the
            in the North.  In the 1970s, extensive studies were conducted in                                     windswept tundra, the "land of little sticks" where the
            relation to a proposed gas pipeline across the area. Studies                                         stunted trees of the boreal forest cease their northward
            conducted since T981 to assess the impact of petroleum                                               march, the ice-hung cordilleras.    Over these meagre lands
            activities on the wildlife resources of the 1002 area are                                            they travel, obeying the commands of the seasons:      the
            thorough and add Isubstantially to the body of knowledge.    In                                      melting of snow, th@ budding of plants, the hatching of
            addition, studies on Lesser Snow Geese, Polar Bears and the                                          mosquitos, the freeze-up of lakes and rivers.     Like the
            Porcupine Caribou Herd have been conducted since the early 1970s                                     wind that passes.ovet the tundra wilderness and is gone,
            cooperatively between Canada and the United States.    Knowledge of                                  caribou are forever on the move. They appear on one
            the impact of petroleum activities on wildlife is adequate due to                                    distant horizon and vanish on the other. And it is their
            work done in the Mackenzie Delta area and to the extensive                                           comings and goings that set the cadence of life on the
            studies done at Prudhoe Bay.  Possible mitigative measures are                                       barren-lands ...... George Calef 1981.
            known and their efficacies have been evaluated. We now know
            that the degree of impact of an activity and the efficacy of                                      The Porcupine Caribou@Herd (PCH) is one of the    largest
            a mitigative measure are time and area dependent; they vary                                  caribou populations in the'world and it is critical    to the
            throughout the annual cycle of a species and among populations                               well-being of a number of  communities in Alaska, Yukon and the
            of the same species.                                                                         Northwest Territories.

                                                                             4

                                                5                                                                                                6

                  The 1002 area is critical to the long-term well-being of the                                overall movement patterns of the PCH would, therefore, be
             PCH as it contains 78% of the core calving area, is used for                                     affected such that, at a minimum, the majority of the PCH would
             calving by up to 82% of the cows and supports 80,000 or more                                     not return to Canada until late August or September, and,
             caribou in postcalving aggregations (p 28-29).      Full leasing  of                             possibly, such that overall migration patterns of the PCH are
             the 1002 area could result in a major effect on the PCH even      with                           altered, thereby reducing or eliminating its availability for
             the mitigation measures proposed (p 112).     Loss  of habitat values                            harvest to some of the communities that depend on the PCH.
             on 32% of the core calving area and reduced use     or avoidance  of
             29% of the insect-relief habitat are considered     to be unavoidable
             impacts (p 105-112, 131-132). 'These changes ... could result in
             a major population decline and change in distribution of 20-46                                   Lesser Snow Geese
             percent"of the PCH (p 112, 132).

                                                                                                                   The Western Arctic population of Lesser Snow Geese consists
                  The estimates of impact on the PCH given in the EIS                                         of over half a million individuals that nest primarily in Canada
             are conservative because the effects of reduced use of                                           on Banks Island and in the Mackenzie Delta region and winter
             aggregation and insect-relief habitats were evaluated only from a                                primarily in central California and New Mexico. The commitment
             short-term energetic point of view (p 109-110).       Posicalving                                of both countries to this share@ resource was made through the
             aggregations of the PCH form even in the absence of insects,                                     Miqratorv Birds Convention in 1916,and reiterated in 1986 in the
         CO  although less dramatically, and likely also serve a social                                       signing of the North American Waterfowl Management Plan. Work on
             function. Disruption of this linking of the nursery bands with                                   this population by both countries is presently the focus of the
             the other segments of the herd could conceivably fracture the                                    Arctic Goose Joint Venture being carried out under the Plan.
             herd. In addition, the-strategies employed by the post-calving
             aggregations to avoid insects are important.     Bands of caribou                                     Four large Canadian Arctic Migratory Bird Sanctuaries
             usually either travel north to the coastal insect@relief areas or                                demonstrate Canada's concern and commitment to this shared
             south to insect relief areas in the foothills of the Brooks                                      resource.   Ninety-nine percent of the 1002 area is classified as
             Range. Caribou that move south usually remain in the southern                                    wetlands, a habitat type considered critical for breeding,-
             Brooks Range throughout the period of severe insect harassment                                   staging and migrating waterfowl such as the Snow Geese and other
             (July and early August) whereas the majority of the PCH moves to                                 shared migratory birds.    A major goal of the North American
             the coast and then moves rapidly east to the Richardson Mountains                                Waterfowl Management Plan is wetland conservation, and protection
             for the period of severe insect harassment.                                                      of the 1002 area would contribute a valuable addition to that

                                                                                                              goal.
                  The Richardson Mountains provide the best insect-relief
             habitat within the entire range of the PCH.     It is possible that                                   Major economic and cultural benefits of these      Snow Geese
             if caribou were prevented from-reaching coastal insect-relief                                    flow to a large number of residents of both Canada      and the United
             habitat in the 1002 area the majority of the PCH would seek the                                  States.   The 1002 area is critical to the long-term wellbeing of
             less favourable insect-relief habitat of the Brooks Range.       The                             Snow Geese as it contains preferred staging habitat used by an

                                                                                 6                                                                                           . . . 7

                                                7

             average of 105,000 birds per year, approximately 15-20% of the                                   Polar  Bears
             Western Arctic population (p 35). "Staging Lesser Snow Geese
             congregate on the Arctic Refuge c6astal plain in mid-August and                                        The Beaufort Sea population of Polar Bears is estimated to
             may remain through late September.      IStaging geese move up to                                be 2,000 individuals And, while harvest of bears may be small in
             225 miles west of their southward migration corridor on the                                      the U.S., the combined Canada/U.S. harvest and mortality may be
             Mackenzie River  in order to take advantage of the food resources                                at the sustainable limit now.     Harvest of Beaufort Sea Polar
             on the Yukon and coastal plain of the Arctic Refuge. The geese                                   Bears is important to the wellbeing of a number of coastal
             feed heavily to accumulate fat reserves for the fall migration                                   communities in both'Canada and Alaska.      Both countries have shown
             flight" (p 35). when fall staging grounds are unavailable on                                     their commitment to the conservation of this population through
             account of snow cover, the coastal plain of the Arctic Refuge can                                participation in the International Agreement for the Conservation
             be vital to the welfare of these geese.     In some years, Lesser                                of Polar Bears (1976) and cooperation in research and
             Snow Geese stay on the coastal plain as late as mid-October                                      management.
             feeding and ridding themselves of internal parasites before
             making the migration south to the United States.                                                       It is projected that 12-13% of the adult females in this
                                                                                                              population  den on land and Polar Bears are known to be
                  The distribution of staging Lesser Snow Geese is highly                                     particularly sensitive to human activities during the denning
             variable and the geese shift preferred areas annually, likely in                                 period (p 33, 117-118).    Disturbance can cause premature
         0   response to overgrazed vegetation caused by heavy feeding in                                     abandonment leading to the death of the cubs.
             previous years. Over half of the Western Arctic Lesser Snow
             Goose population have used the 1002 area in a single year                                              The Beaufort Sea Polar Bears are the only population of
             (p 121).  Full leasing of the 1002 area could result in a major                                  bears in which the majority of the females appear to have their
             effect on Lesser Snow Geese (p 122).     Loss of habitat values on                               maternity dens on sea ice rather than on land.       It may be that
             up to 45% of the preferred staging area that is used by                                          this behavior developed on the northern Alaskan coast because the
             approximately 75% of the Lesser Snow Geese using the 1002 area        in                         females that showed fidelity to denning areas on land in earlier
             any given year is considered to be an unavoidable impact of                                      years were shot.    Since then, females in dens have been protected
             petroleum development (p 121,132). That could result in a                                        for part of the time and, since the enactment of the U.S. Marine
             reduction or change in distribution of an average of 5-10% of the                                Mammals Protection Act of 1972, have been hunted less (though not
             Western Arctic Lesser Snow Goose population, although the effect                                 protected) because there was no market for the hides.        It could
             could be much greater in some years (p 122). In addition, Lesser                                 be that the female bears whose dens have been located      on land
             Snow Geese are extremely sensitive to aircraft sound disturbance                                 along the coast recently are, in effect, recolonizing      that
             when on the tundra feeding grounds in the fall. A major decline                                  habitat.   If so, it could be important and steps should most
             in the Western Arctic Lesser Snow Goose population would have a                                  certainly be taken to minimize disturbance.      The only significant
             direct, widespread economic and cultural impact on both the U.S.                                 onshore denning area is on, and adjacent to, 1002 land, and both
             and Canada.                                                                                      proposed marine ports sites (Camden and Pokok) are confirmed
                                                                                                             @denning areas, especially Pokok on the east side of 1002 lands.

                                                                                   8
                                                                                                                                                                                   9

                                                                                                                                         10

                                             9

                 Leasing of 1002 land for petroleum development could result                                Coastal waters of the Beaufort Sea in Alaska are reported to
            in a moderate effect on the Beaufort Sea population (p 118,                                contain sixty-two marine and anadromous fish species, including
            136). Probable loss of the eastern portion of the 1002 area as                             Arctic Charr and Arctic Cisco.   Near shore waters and the brackish
            denning habitat is considered to be an unavoidable impact under                            lagoon systems which provide migration corridors and feeding areas
            either development alternative (p 118, 131, 136, 139).    Because                          and are important spawning, rearing and over-wintering areas for
            of the importance of the area for denning, the adverse effects                             some fish, are vulnerable to degradation resulting from coastal
            are mainly associated with the proposed port facilities (p 118,                            plain development. The effect upon the fisheries resources which
            136). The most prudent course of action for the.conservation of                            are shared by Alaska and Canada have not been determined.
            Beaufort Sea Polar Bears would be the designation of the 1002
            area as wilderness.                                                                             Thirteen species of marine mammals may occur off the coast of
                                                                                                       the Arctic Refuge. The four species of significance to Canada are
                                                                                                       Ringed Seal, Bearded Seal, Beluga Whale and Bowhead Whale. Most,
                                                                                                       if not all, constitute shared resources which are important in the
                                                                                                       subsistence economies of both countries.
        -,n Fish and Marine Maimnals
                                                                                                            The EIS concludes that marine mammals are not unduly affected
                 Should development on the coastal plain proceed, itis likely                          by high levels of marine traffic and disturbance from oil and gas
            that associated marine transportation and coastal development will                         activity. However, the studies which relate are from site-
            impact the marine resources. Any future offshore development will                          specific research conducted at exploratory sites and may not be
            compound these effects. Development of port facilities and near                            representative of the.effects of full-scale development and
            shore artificial islands would affect inshore migratory patterns                           exploitation.  -If such development occurs, this may become one of
            of fishes and could change salinity patterns. Additionally, the                            the most congested sea coasts in the Arctic with year-round open
            15 million gallons of fresh water required for development of each                         water transportation corridors. Beluga and Bowhead Whales migrate
            well will have some effect on the marine resources, both inshore                           through these areas. Any impact and consequential reduction in the
            @and offshore. The effects upon shared fishery resources have not                          availability of Bowhead in Alaska would result in a compensatory
            been assessed. However, it is known that five species of white-                            increase in Beluga take which would adversely affect the Canadian
            fish such as the Arctic Cisco migrate along the Alaska/Canada coast                        harvest.
            seasonally and are important subsistence food resources in both
            countries.

                                                                      . . .  10

                                                                                                                                                  12

             Contradictions in the Report
                                                                                                              for and develop the                      has been documented" (p 107)
                  In reading the 1002 Assessment, the Canadian government                                     hydrocarbon potential of the             and
             is struck by the contradictions and inconsistencies between the                                  1002 area without                          "The apparent herd
             Secretary's Recommendation (p 169-170) and the content of the                                    significant deleterious                  increase has been attributed
             preceeding parts of the document.                                                                effects on the unit's                    to high calf production and
                                                                                                              wildlife resources" (p 170).             survival as well as
                    The Secretary's                        Impact as Forecast                                                                          relatively light.hunting
                     Recommendation                            in the EIS                                                                              pressure" (p 106).
                                        The CAH Comparison
             The Recommendation puts                  In contrast, the preceeding                                                                      The EIS continues:
             great emphasis on the                    sections of the EIS stress:                                                                        'Because some habituation
             situation at Prudhoe Bay                   "Analogies comparing the                                                                       would presumably have
             noting that despite                      effects of current oil                                                                           occurred, animals in the CAH
             petroleum development                    development on the CAH                                                                           may be more likely to cross
               "the fish and wildlife                 (Central Arctic Herdl and                                                                        an oil-field development
             resources of the Prudhoe   Bay           effects of potential 1002                                                                        than the PCH which would
             area remain extremely                    area development on the PCH                                                                      encounter such developments
             healthy" and that                        must be drawn with caution.                                                                      for only 2 or 3 months each
               *the Central Arctic                    Movements, density, and                                                                          year" (p 109).
             caribou herd has increased               traditions of the PCH differ
            .substantially during   the               from those of the CAH.                                                                  Mitigation
             period that development has              Because of the greater                                  The Recommendation states                This is clearly not the case
             occurred within the heart of             density of PCH on their                                 that "most adverse                       for the three key
             its range' (p 169).                      calving grounds, the PCH                                environmental effects would              international species using
                                                      would interact with oil                                 be minimized or eliminated               the 1002 area. The SIS
             The Recommendation    concludes          development much more                                   through mitigation"                      notes that -Mitigation of
             that                                     extensively and intensively                             (p 170).                                 the loss of caribou habitat
               -Although circumstances                than the CAH has interacted                                                                      in Resource Category 1
             within the 1002 area may be              with oil development in the                                                                      (242,000 acres of core
             somewhat different, the                  Prudhoe Bay area" (p 106).                                                                       calving area) is not
             evidence derived from the                  "Displacement of the CAH                                                                       possible" (p 111) and that
             Prudhoe Bay experience leads             from historic calving                                                                            "even with effective
             one to be quite optimistic               grounds in response to oil                                                                       mitigation, herd
             about the ability to explore             development at Prudhoe Bay                                                                       displacement or reduction
                                                                                                                                                       could be as great as 20-40
                                                                                   12                                                                  percent" (p 144).
                                                                                                                                                                                 . . . 13

                                                                                                                                                   14
                                                13

                                                                                                                                                           *Loss of habitat values
                                                     No specific mitigation                                                                              from between 162,000 and
                                                     measures are suggested for                                                                          236,000 acres of snow goose
                                                     staging Snow Geese despite      a                                                                   preferred staging habitat
                                                     predicted major impact for                                                                          within the 1002 area.".
                                                     that species. Nothing in
                                                     the Prudhoe Bay experience                                                               Compensation
                                                     provides any basis for                                    It is further noted    in the             Given the previous list of
                                                     evaluating or mitigating the                              Recommendation that    the                *unavoidable" losses of
                                                     effects of the proposed                                   leasing program                           habitat quality, it is
                                                     activities on staging Snow                                  'must ensure that    any                difficult to see how one
                                                     Geese.                                                    unavoidable habitat    losses             could fully compensate for
                                                                                                               are fully compensated"                    the long-term loss of up to
                                                     The single most important                                 (p 170).                                  72,000 Porcupine Caribou and
                                                     mitigation measure for Polar                                                                        60,000 Snow Geese.     it is
                                                     Rears, withdrawal of the                                                                            even more difficult to see
          p                                          Pokok port site, is not                                                                             how one could fully
          CA)                                        proposed.                                                                                           compensate for the loss of
                                                                                                                                                         almost one third of the core
                                            Habitat  Quality                                                                                             calving area since the
           The Recommendation states                 This statement is clearly at                                                                        E.I.S. earlier notes that:
           that:    "Development would               odds with the list on p 131,                                                                        *The Porcupine Caribou Herd
           proceed with the goal of no               132 of 'Unavoidable Impacts"                                                                        (PCH) core ca  lving area is
           net loss of habitat quality,              which includes:                                                                                     considered unique and
           and unnecessary adverse                                                                                                                       irreplaceable" (p 98).
           effects would not be allowed                "Loss of habitat values on
           to occur" (p 170).                        approximately 78,000 acres                                  'The FWS normally recommends that all losses of Resource
                                                     of caribou core calving                                   Category I habitat be prevented, as these one-of-a-kind areas
                                                     habitat.... cannot be replaced".                                                   Since the goal of "no net loss of habitat
                                                       "Reduced use or avoidance                               quality" cannot be met, the 'unnecessary adverse effects" should
                                                     of approximately 72,000                                   "not be allowed to occur*.      The recommendation for full leasing
                                                     acres of insect relief                                    of the 1002 area appears to be based on several false assumptions
                                                     habitat for caribou.";                                    of its likely impact on wildlife resources.        From the EIS's own
                                                       "Probable loss of the                                   observations, it appears impossible to achieve the goal of no net
                                                     eastern part of the 1002                                  loss of habitat.
                                                     area as denning habitat for
                                                     polar bears."; and,                                                                                                               15

                                                                                . . .  14

                                            15

           Conclusion

                The migratory wildl.ife populations that range between Canada
           and the United States are a special category of resource. They
           are not owned exclusively by either countryl they are held in
           common by both. Each country, therefore, has obligations to
           conserve these stocks and their habitats so that the value of the
           wildlife to the other country is not unacceptably reduced.

                This principle has guided cooperation in migratory bird
           management by Canada and the United States for 70 years,
           resulting in great economic and cultural benefits to both
           countries. The same principle applies to migratory caribou and
           shared stocks of Polar Bears, and fish.

                On the evidence produced by the U.S. in the 1002 Assessment,
           petroleum development in that area of northeastern Alaska will
           cause major damage to migratory wildlife that range over that
           area and northwestern Canada. This damage could continue for.90
           years. Canadian citizens have major and continuing subsistence,
           cultural and economic interests in these wildlife.

                Petroleum development of the 1002 area will cause
           significant damage to major wildlife resources that Canada shares
           with the United States with unavoidable repercussions.for
           subsistence users in Canada. These are the primary
           considerations which lead the Government of Canada to urge the
           Government of the United States to protect the 1002 area by
           establishing it as wilderness.

                                                                                                                                         2

                               Canada-U.S. Consultations on the
                             U.S. Department of the Interior's Draft
                           "Arctic National Wildlife Refuge, Alaska                                                                              Resource Evaluation,
                                                                                                         /4r. Graham Campbell, Director General,
                             Coastal Plain Resources Assessment"                                         Canada.Oil and Gas Lands Administration
                                             Ottawa
                                        February 3. 1987                                                 Mr.. Tony Clarke, Director General, Canadian Wildlife Service
               U.S. Delegation                                                                           Mr. David Lohnes, Natural Resources Division, National Parks,
                                                                                                         Environment Canada
               Mr. William Horn, Assistant Secretary, Fish and Wildlife and                              Ms Da  ielle Wetherup, Director General, Natural Resources and
               Parks, U.S. Department of interior (Head of Delegation)                                   Ec@nomic Development, Department of Indian Affairs and
               Ms. Susan Recce, Deputy Assistant Secretary,                                              Northern Development
               U.S. Department of the Interior                                                           Dr. J.D. McTaggart-Cowan, Director, office of Environmental
               Mr. Robert Gilmore, Regional Director, U.S. Fish and Wildlife,                            Affairs, Energy, Mines and Resources
               Alaska                                                                                    Mr. Tony Keith, Director@.Wildlife Toxi4@@logy and Surveys
               Mr. William Siefken, First Secretary, U.S. Embassy, Ottawa                                Branch, Canadian Wildlife.Service
                                                                                                         Mr. Don Russell, Wildlife Biologist, Canadian Wildlife Service
               Canadian Delegation                                                                       Ms. Janet Davies, First secretary; Canadian Embassy,
               Madame Lorette Goulet, Assistant Deputy Minister,                                         Washington, D.C.
               Environment Canada (Head of Delegation)                                                   Mr. Terrence Cormier, U.S. Transboundary Division
               Mr. William Klassen, Deputy Minister, Renewable Resources,                                Department of External Affairs
               Yukon

               Ms. Eloise Spitzer. Deputy Minister, Executive Council office,
               Yukon

            _-Mr. David Brackett, Assistant Deputy  Minister,
               Renewable Resources, Northwest Territories
               ,Mr. Victor Mitander. Chairperson, Canadian Porcupine Caribou
               Management Board

               Mr. Richard Sidney, Vice-Chairperson, Council of Yukon Indians

             _,Mr. Stanley Njootli, Band Council, Old Crow

               Mr. Brian Crane, Advisor, Dene-Metis, Northwest Territories

             ,!Ir. Fred Benne*, Inuvialuit Game Council

               Mr. John Noble, Director General, U.S. Relations Bureau,
               Department of External Affairs

                                                                              2

                                                                                                                                     The polar bears inhabiting the Arctic National Wildlife Refuge and adjacent
                                                                                                                                     waters represent another significant resource shared by our countries and
                 Northwest                                                                                                           the need for cooperative management is recognized in the International
                     Territories Renewable Resources                                                                                 Agreement for the Conservation of Polar Bears. We believe that the report
                                                                                                                                     does not fully explore the possible impacts on-polar bear denning habitat
                                                                                                                                     die to oil spills, port and harbour development or related offshore
                                                                                                                                     developments.
                                                                   30 January 1987                                                   Finally, the report overlooks the importance of the coastal plain area as
                                                                                                                                     a primary fall staging area for one-fifth of the total snow goose population
                                                                                                                                     which breeds on Banks Island. Northwest Territories. Given our shared
                                                                                                                                     management obligations for waterfowl, as defined in the Migratory Birds
                                                                                                                                     Convention and the North American Waterfowl Management Plan, we believe
                     U.S. Fish and Wildlife Service,                                                                                 this constitutes a serious oversight in the assessment process.
                     Division of Refuges.
                     Department of Interior,                                                                                         Recognizing the Beaufort coastal zone as a common ecological unit. we
                     Room 2343,                                                                                                      welcome further opportunities to communicate our concerns and work
                     Main Interior Building,                                                                                         together towards the long term protection of our shared wildlife resources.
                     Washington, D.C.,
                     U.S.A.     20240

                     Arctic National Wildlife Refuge, Alaska
                     Coastal Plain Resource Assessment

                     Our government appreciates the opportunity to comment on the environ-
         ,n          mental impact assessment report on proposed hydrocarbon developments                                                                                          J. W. Bourqde,
                     affecting the Arctic National Wildlife Refuge.       We have several concerns                                                                                 Deputy Minister
                     and suggestions which are described in the enclosed "Statement by the
                     Government of the Northwest Territories on the Arctic National Wildlife                                         Enclosure.
                     Refuge, Alaska Coastal Plain, Resource Assessment".

                     We acknow ledge the importance of Arctic oil development in contributing
                     to the safeguarding of national interests for future energy supplies.
                     However. we believe that the scenario put forward for full scale hydro-
                     carbon development within the national wildlife refuge poses serious
                     international risks which have not been adequately addressed in the
                     assessment report.

                     Our greatest concern relates to the pre    dicted major impact on the Por-
                     cupine Caribou Herd due to disruption of key calving and insect-relief
                     habitats. This is intolerable given the importance of this herd for
                     domestic use by residents of the western Northwest Territories. Proposed
                     development in the 1002 area would. therefore, seriously prejudice
                     our government's management responsibilities as outlined in the U.S./Canada
                     Porcupine Caribou Management Agreement initialled in December 1986.

                                                                                                ... 12

                            d of It WCOU'c-st 10,fdu.ts Yelk.&n.tc., NW IX, X.1 A 219 10(,-, (31 4Y,2h

                                                                                                                                  G.N.W.T. STATEMENT IN RESPONSE TO THE ARCTIC NATIONAL WILDLIFE REFUGE,
                                                                                                                                  ALASKA COASTAL PLAIN RESOURCE ASSESSMENT

                                                                                                                                  1.    INTRODUCTION

                                                                                                                                        the Department of Renewable Resources, Government of the Northwest
                                                                                                                                        Territories has responsibility for the management of wildlife
                                                                                                                                        under the authority of the N.W.T. Wildlife Act and pollution. control
                                                                                                                                        under authority of the N.W.T. Environmental Protection Act. Actions
                                                                                                                                        by this department directly influence, and are influenced, by
                                                                                                                                        a large number of northern communities which are striving to
                                                                                                                                        maintain a viable renewable resource based economy.         Maintenance
                                                                                                                                        of renewable resources is vital to the welfare of          Dene, Inuit,
                                                    Statement by the                                                                    Inuvi.aluit, Metis and non-native people throughout the    noIrth.
                                                                                                                                        Departmental staff are charged with the responsibility of enforcing
                                                                                                                                        the Environmental Protection Act and managing wildlife populations
                                                                                                                                        and habitat, including caribou, muskoxen, and polar bear.              In
                                        GOVERNMENT OF THE NORTHWEST TERRITORIES                                                         addition, government staff have played a major role in the developm-
                                                                                                                                        ent of the North American Waterfowl Management Plan, and have
                                                          on the                                                                        contributed to the management and research of geese.
                                                                                                                                        The native peoples maintain special bonds to the land, and to
          -.n                    ARCTIC NATIONAL WILDLIFE REFUGE, ALASKA COASTAL PLAIN                                                  the wildlife which derive their existence from the land.           People
                                                                                                                                        who pursue traditional life-styles place high value on 'he opportun-
                                RESOURCE ASSESSMENT AND DRAFT LEGISLATIVE ENVIRONMENTAL                                                 ity utilize indigenous animal and plant life, life-styles which
          -4                                         IMPACT STATEMENT                                                                   allow the reaffirmation of personal and community identity.          Such
                                                                                                                                        opportunity allows the maintenance of traditional skills, provides
                                                                                                                                        for an important social and educational exchange between young
                                                       submitted to                                                                     and old, and perpetuates a sense of self reliance.
                                                                                                                                        Everything in this world is connected to everything else. and
                                                                                                                                        the action taken by one party can affect many other parties.
                                 U.S. Fish and Wildlife Service. Division of Refuges,                                                   Wildlife are distributed over the land in response to their biologi-
                                               DEPARTMENT OF THE INTERIOR                                                               cal needs; they pay little attention to political boundaries.
                                                                                                                                        The wildlife resources of the North Slope are a shared resource.
                                       GOVERI(ME141 OF THE UNITED STATES OF AMERICA                                                     The management actions implemented by one country will unquestionab-
                                                                                                                                        ly affect the other country.

                                                                                                                                        The Arctic National Wildlife Refuge represents a significant part
                                                                                                                                        of the arctic ecosystem and currently supports major wildlife
                                                   Yellowknife. N.W.T                                                                   resources shared by the United States and Canada.        The alteration
                                                      January 1987

                                                                                                                                                                                                           ... 12

                                                                   2 -                                                                                                              3 -

                             of this area, whether abrupt or incremental, could adversely affect                                           2.3   WILDLIFE CONCERNS
                             the peoples of Alaska, the Yukon, and the Northwest Territories.
                             Clearly, the issue at hand is a transboundary one.         The transbounda-                                         We are distressed to read the statement on page 112 of the report
                             ry issues have not been adequately addressed by the Environmental                                                   concerning the Porcupine Caribou Herd           stating that changes in
                             Impact Statement.                                                                                                   habitat avai)ability and value, combined with increased harvest
                                                                                                                                                 could result in a major population decline and change in distributi-
                       2.    CONCERNS                                                                                                            on of 20 to 40 percent, based on the amount of calving and
                                                                                                                                                 insect-relief habitats to be adversely affected.                This is an
                                                                                                                                                 intolerable figure based on the International Porcupine Caribou
                                                                                                                                                 Management Agreement initialled in December 1986 by both the
                       2.1   Agreement with YTG Submission                                                                                       Government of the Northwest Territories and federal government
                                                                                                                                                 of Canada, as well as your Department.
                             We have noted the issues raised by the Yukon Territorial Government
                             in their presentation at the Public Hearings held in Kaktovik,                                                      While the Report acknowledges the potential impacts on the Porcupine
                             Anchorage, and Washington, D.C.          We share their main concerns.                                              Caribou herd, thereis no mention of the importance of this herd
                             namely:                                                                                                             for domestic use by the people of the western Northwest Territories.
                                                                                                                                                 This is a particularly glaring omission in light of the above
                             a)   The insufficient attention paid to section 1005 of the Alaska                                                  mentioned agreement to protect the herd and its habitat and its
                                  National    interest Lands Conservation Act (1980) that calls                                                  recognition    of   native    use   by   Government     of   the    Northwest
                                  for   official   consultation    about    the  1002(h)    Report.     The                                      Territories.    As signatories to that Agreement, we are concerned
                                  G.N.W.T.    was never consulted, nor were its agencies, native                                                 to note the apparent lack of contact between the Secretaries of
                                  citizens or interest groups (such as the Beaufort/Mackenzie                                                    Department of Interior and State Department on this matter, not
                                  Delta Development Impact Zone Group);                                                                          to menfion contact with the signatories to the Porcupine Caribou
          71                 b)   The inadequate reference given by the Report to the potential                                                  Herd Management Agreement itself.
          00                      cumulative impacts of the possible development in the whole                                                    The Government of the Northwest Territories has offshore responsibi-
                                  Beaufort area.                                                                                                 lities in the Canadian Beaufort for wildlife manacement, particular-
                             c)   The lack of acknowledgment by the report of the ecological                                                     ly polar bear.      The Beaufort population extends from Tukoyaktuk.
                                  responsibilities shared by both the U.S. and Canada to ensure                                                  Northwest Territories to it least as far west as Point Barrow,
                                  that the coastal plain on both sides of the border is managed                                                  Alaska.    While the oil companies are justifiably proud of their
                                  to meet conservation oriented objectives.                                                                      safety record (at least no major Arctic spills), the potential
                                                                                                                                                 mortality from even a localized spill in a denning area could
                             Moreover,     the Government of the Northwest Territories has the                                                   be serious.   As well, port and harbor development to support coastal
                             following additional points to raf.se:                                                                              plain and related offshore development could lead to abandonment
                                                                                                                                                 of denning areas.
                        2.2  PLANNING AND COORDINATION MECHANISMS
                                                                                                                                                 Approximately 1/5 of the total snow goose population of Banks
                             The 1002(h)      Report does not adequately address the mechanisms                                                  Island, Northwest Territories use the coastal plain as a staging
                             that would ensure the proper coordination needed between the develo-                                                site in the fall.       This is not mentioned in the Report, nor is
                             pment of nearshore and onshore environments.             As the Department                                          the   obligation    both   nations   share   under   the   Migratory     Birds
                             of Commerce      has  still   not   formally approved     the North      Slope                                      Convention and North American Waterfowl Management Plan for the
                             Borouoh's Coastal Management plan under the Coastal Zone Management                                                 protection of the species and its habitat.
                             Act, the strategic framework to affect this coordination is absent.

                                                                                                          /3                                                                                                             ... /4

                                                           4 -

                     3.   CONCLUSION

                          The 1002(h) Report admits the importance of the coastal plain
                          area to the entire national wildlife refuge.         While it is only
                          a small portion (5 percent), this area is critical as a calving
                          ground and insect-relief habitat for the Porcupine Caribou Herd.
                          as migratory wildfowl and as denning grounds for polar bear.
                          The full leasing alternative is unacceptable to our government.

                          The  report includes optimistic projections about the potential
                          for oil discovery (a 95 percent chance of the 1002 area containing
                          4.8 billion barrels in-place) and much is made of the need to
                          safeguard the national interest for future oil supply.         We agree
                          that these are important considerations, but the transboundary
                          risks inherent in proceeding with the full leasing alternative
                          constitute unwarranted trade-offs.

                          The need for improved consultation between Canadian and U.S.
                          interests in this area is apparent, particularly in ensuring that
                          mutual  obligations for wildlife and related habitat protection
                          are met.    The Government of the Northwest Territories must be
                          involved in any cooperative natural resource management agreements
                          that are struck, and policies and guidelines for development affect-
                          ing shared resources should be agreed to jointly.
        (D                This 1002(h) area is arguably the most important part of the refuge
                          from an ecological viewpoint.     The extent of development proposed
                         Jor this area and its potential impacts must be more carefully
                          weighed before an irrevocable decision is made. We urge the accept-
                          ance of Alternative 5, wilderness designation.

                    DO YOU WANT TO MAKE PUBLIC COMMENTS?

                    If you would like to speak at the hearing today, please fill in the blanks
                    below and turn it in to one of the Fish and Wildlife Staff members present.
                    You need not complete this sheet to submit written comments. Thank you.
    																		STATEMENT BY THE

    																	  GOVERNMENT OF THE YUKON
                    Please print

                    Name  Stephen Fuller
                    Mailing Address

                                                                                                                 IN RESPONSE TO
                    Check appropriate box below:                                                            DEPARTMENT OF INTERIOR
                                                                                                 DRAFT ARCTIC NATIONAL WILDLIFE REFUGE, ALASKA
                    		I am here to offer my own views.							   COASTAL PLAIN RESOURCE ASSESSMENT
                                       -or-
                            I am speaking for  Gov of the Yukon
                                              (please enter name of organization you represent)

    																		ANCHORAGE, ALASKA
    									 									 JANUARY 5, 1987

                                                                                            Presented by:
                                                                                            S.P. fuller, Policy Advisor
                                                                                            Department of Renewable Resources

                                                                                                                                                            with Canada either as a result of migration (in the case of
                                                    GOVERNMENT OF THE YUKON PRESENTATION TO                                                                 caribou and waterfowl) or as an Important constituent of a larger
                                              THE DEPARTMENT OF INTERIOR DRAFT ANWR EIS HEARINGS                                                            regional population (in the case of musk oxen and polar bear).
                                                      (Anchorage, Alaska, January 5, 1987)                                                                  In both countries, these four species are valued for their
                                                                                                                                                            subsistence use and for their intrinsic value as part of the
                                          Mr. Chairman, Panel Members, Ladies and Gentlemen.                                                                diminishing wilderness resourcelof our continent.       Yet the EIS
                                                                                                                                                            establishes the significance of the Impact solely on    the basis of
                                                                                                                                                            the effects of a population decrease in Alaska.
                                          Allow me to begin these remarks by sincerely thanking you for the
                                          opportunity to appear before you today.   The Governm-@nt of the                                                  The best example of this deficiency is provided by the EIS
                                          Yukon appreciate- the privilege you have provided in allowing us                                                  discussion of the Porcupine Caribou Hard. The potential decrease
                                          to make this presentation and we value greatly t.he growing spirit                                                In herd size of 20 - 400 due to Impacts in the heart of the
                                          of cooperation that has developed between our two great regions.                                                  calvin.9 area, is very correctly described as a m@jor Impact,
                                          We trust that you will carefully consider both the general and                                                    however,   the   effects    in   Old   Crow    and   other    largely
                                          specific concern@,,that we have.identified during our review of                                                   subsistence-based communities in northern Canada are only given
                                          the draft EIS.                                                                                                    passing attention in an entirely separate portion of the report.
                                                  time available today. I      will briefly outline the                                                     Fully four-fifths of the subsistence use of the herd is estimated
                                          in  the                                                                                                           to occur in Canada and there IS no treatment of the consequence
                                          highlights of our general concerns with the EIS, and I will be                                                    of a major decline In herd size on such use.
                                          tabl Ing a written text of my remarks as well as a more detailed
                                          written  *interrogatory",     containing     specific     technical                                               Mr. Chairman, there are similar omissions in the treatment of
                                          observations and questions    concerning  a number of specific                                                    snow geese, polar bear, and musk oxen, which we have elaborated
                                          aspects of the FIS.   We understand that the detailed materials                                                   In our background submission and I will not discuss further at
                                          will also form a part of the record of these proceedings, and                                                     "is time.    Rather, 1 want to emphasize with you V@at the EIS
                                          that we car, antieipata a written response to our questions in due                                                appears t.o nearly completely Ignore transboundary effects and it
                                          course.                                                                                                           cannot be considered complete until this omission is corrected.
                                                                          lement the authors of the report.                                                 In particular the effects on northern native peoples and their
                                          To begin, we would like to COMP                                                                                   hopes for the sustainable development of the renewable resource
                                          for providing a succinct, well written exposition Of the baseline                                                 economies must be acknowledged.
                                          environmental and socioeconomic data,@rdliV Impact significance
                                          criteria and the summary comparisons of environmental effects and                                                 In some ways, Mr. Chairman, we would be happy if this message as
                                          consequences. ' Although we are Critical of some aspects of the                                                   the only one we delivered to you today.            In light of the
                                          EIS, we believe that the public review Process and the nature of                                                  principles and optimism that lead to the development of our
                                          the discussion and Inevitable debate is substantively aided, when                                                 domestic Porcupine Caribou Herd Management Agreement, and have
                                          options and opportunities are clearly evaluated In this matter.                                                   formed the basis for our negotiations towards an International
                                          It certainly makes the job of external analysts such as ourselves                                                 agreement with your country,        a believe that transboundary
                                          far far easier and we sincerely appreciate that fact.                                                             cooperation on    resource management     problems    and issues     is
                                          our first Imajor criticism of the EIS as it is now structured                                                     fundamentally Important.    The present omissions from the EIS do
                                                                                                                                                            not well serve our mutual interests and concerns.
                                          however, deals not with the present contents, but rather with
                                          several significant omissions.                                                                                    The second fundamental deficiency in the EIS is         the lack of
                                                                                                                                                            acknowledgement of the cumulative effects of 1002       oil and gas
                                          in particular.   although the EIS fairly identifies major or                                                      development proposals with those of the various         offshore OCS
                                          moderate impacts on the populations of caribou, snow geese eA                                                     lease sales.    Surely the consideration of the effects of the
                                          other watQz1owl. polar bears and musk oxen. there I! no adequate                                                  developments on several significant species cannot be considered
                                          treatment of the transboundary consequences       of   those direct                                               to be adequately assessed unless these various proposals are
                                          impacts.   in each case the populations in question are sh-ed

                                         considered   together.     Incremental   direct   effects    and    the                                               productive and meaningful session, which will meet the      "letter of
                                         cumulative effects of habitat loss or modification should be                                                          the law" In question, we would like to emphasize our interest.in
                                         evaluated. at least additively, before any judgements are made                                                        establishing   early   and continuing      formal    liaison  on    such
                                         about the significance of impacts and the ultimate acceptability                                                      questions In the future.    The traditional knowledge of our native
                                         of those impacts.                                                                                                     population and the scientific knowledge of our professional
                                                                                                                                                               biologists should be shared on questions of this magnitude.
                                         In addition it is important that with respect to migratory
                                         waterfowl, snow geese in particular, it should be acknowledged                                                        Mr. Chairman, in addition to our three basic concerns about
                                         that the 1002 lands are a critically Important staging area, but                                                      transboundary effects,     cumulative effects and the need for
                                         ere only one part of the habitat of the species.         Consideration                                                consultation, a would also like to report to you,            a set of
                                         of the significance of cumulative effects Should therefore                                                            historical occurences that are both mildly ironic and disturbing
                                         acknowledge the potential for habitat loss in other portions of                                                       In light of the recommendations in the draft EIS.
                                         the habitat away from the north slope region.          Most migratory
                                         waterfowl species are under considerable stress in the southern                                                       About the time of the passage of the ANILCA legislation, various
                                         portions of their habitat and that habitat is increasingly                                                            international    bodies,    the   United   Nations    included,     were
                                         reduced or circumscribed by human users.          The potential for                                                   finalizing The World Conservation Strategy.            The WCS Is a
                                         negative synergistic effects If such stress and habitat reduction                                                     development strategy with the complementary aims of encouraging
                                         Is replicated in the north is considerable and must be considered                                                     sustainable development of resources, ensuring the protection of
                                         in your analysis and decision making.       We were quite encouraged                                                  ecosystem integrity and maintaining species-specific genetic
                                         to note that last year in the March 1986 Issue of Ducks                                                               diversity.    The WCS has been adopted by some 40 countries,
                                         Unlimited's journal Assistant Secretary Horn acknowledged that it                                                     including Canada, and at the time of the initiation of the WCS,
                                         would be necessary to stop the continued loss of some 458,000                                                         the ANILCA legislation was considered a landmark, a significant
                                         acres of habitat each year In the United States.       In response to                                                 tool that would substantively aid implementation of the WCS goals
                                         a question about the feasibility of the North American Waterfowl                                                      by Protecting arctic ecosystems.         .In June of 1986 a major
                                         Man:gem:nt,P Ian's tambitious goal of an additionalt5 million acres                                                   International   conference    on   updating    the  wCS    in   Otta@a,
                                         of  rot ct d habi at by the year 2000 he states hat he was well                                                       recommended that the WCS would be Improved it a circumpolar folio
                                         aware that there was a need to "arrest the alarming loss of                                                           was added to the WCS, outlining the relative iinportance and
                                         wetlands' and "to get the finger In the dike and stop the                                                             necessity of viewing northern regions in an integrated and
                                         leaking".   We suggest that full protection for the ANWR north                                                        holistic manner, leading eventually to international agreements
                                         slope would be a very fine way to achieve this.                                                                       on the management of the very species in question here today.
                                                                                                                                                               Unfortunately, oil and gas developments in the ANWR at the scale
                                         The third major theme which we would like to stress with you                                                          proposed In the draft EIS would be a significant step backwards
                                         today Mr. Chairman is primarily a procedural matter.           Although                                               In any effort to achieve such an objective.
                                         there are several references to what apparently were informal
                                         consultations with various Canadian interests, there in fact, was                                                     At the present time In the Yukon we are working quite diligently,
                                         no direct Consultation with any community, Interest group, or                                                         with other government agencies, both territorial and federal,
                                         government agency.     Such consultation was mandated in Section                                                      towards    the   implementation    of   the    WCS.     This   includes
                                         1005 of the Alaska National Interest Lands Conservation Act, but                                                      coordinating initial work on a northern circumpolar conservation
                                         even if it had not been prescribed in this manner the benefits of                                                     strategy; working towards a Yukon Conservation Strategy; and
                                         mutual cooperation on tranaboundary resource management questions                                                     initiating a local conservation strategy for Old Crow which
                                         are such that consultation should have occurred without recourse                                                      covers much of the Canadian portion of the Porcupine River Basin.
                                         to legislation.
                                                                                                                                                               Development of a conservation strategy In the Yukon and around
                                         This point has  been raised with your government on several recent                                                    Old Crow will do much to complement the substantive aspects of
                                         occasions   Mr.   Chairman   and   a  formal   meeting   between     the                                              formal land use designations that have been achieved in recent
                                         Goverment of Canada and the Government of the United States will                                                      years. to truly oe@ure the futur@    for internationally significant
                                         occur in the near future.         While this will no doubt be a                                                       resources like the Porcupine Caribou herd.       The new North Yukon

                                             National Park, and environmental screening and review processes
                                             established as a result of our Inuvialuit Settlement Agreement                                                     1002 lands,   We believe that, at this time, you should decide.in
                                             have resulted In significant protection for the Canadian north                                                     favour of increased and enhanced protection of 1002 lands.
                                             slope.  Such protection was sorely lacking until 1984; we lagged                                                   Cooperatively the governments of the United States of America,
                                             behind the progressive steps taken by your governm nt when you                                                     Canada, Alaska and the Yukon can protect one of the world's
                                             established AKWH.   It will Indeed be Ironic if the historical                                                     remaining truly wild places In perpetuity.
                                             circumstances are reversed as a result of this draft EIS, leaving                                                  Thank you very much for this opportunity.
                                             Canada with a more complete system* of protection for the
                                             international north slope resources.

                                             Finally, Mr. Chairman, we would like to restate that the draft
                                             ,EIS does not adequately report the international significance of
                                             the ANWR lands and resources.       ANWR is nearly unique in the
                                             world, intended to protect a complete spectrum of undisturbed
                                             arctic ecosystems in North America; and the 1002 area is the
                                             heart of the most biologically productive part Of JZNWR.         Given
                                             the biological richness of the area and the proposed scale of
                                             development under the proposed leasing scenario the potential
                                             adverse environmental effects are unprecedented and, with all due
                                             respect, unacceptable.

                                             Although the draft EIS suggests that experience from the Prudhoe
                                             developments  can- be   used   to mitigate    the   effects   of   new
           ,n                                developments. this suggestion is not correct.        Such experience
           I                                                                    about what will happen if the
           .1                                does not answer any questions
           1W
           co                                Porcupine Caribou herd is substantially displaced from the
                                             calving grounds and no alternative habitat of similar quality
                                             exists.

                                             Mr. Chairman, it Is the opinion of the Government of the Yukon
                                             that   it  is   unacceptable   for   you   to  allow   the    proposed
                                             developments in the heart of the Porcupine Caribou herd's calving
                                             grounds, and that the draft EIS is deficient in asserting that
                                             such a displacement. which would lead to a decrease in herd size
                                             of 20 - 40% is in any respect acceptable.

                                             Mr. Chairman, the writers of the Executive Summary of the Els
                                             assert , (quotes) "development on the 1002 lands would proceed
                                             with the goal of no net loss of habitat quality and that
                                             unnecessary adverse effects would not be allowed to occur- (close
                                             quotes). We do not believe, given the exposition of facts in the
                                             main body of the EIS. and our own observations, that such a goal
                                             is even remotely achievable and the statement stands as a         poor
                                             representation of the reality of the situation.

                                             ,Mr. Chairman, there is a continuing need for more research, more
                                             examination of data, and hard decisions about the future of the

                                                                                                                                                                 GOVERNMENT OF THE YUKON PRESENTATION To
                                                        STATEMENT BY THE                                                                                   THE DEPARTMENT OF INTERIOR DRAFT ANWR EIS HEARINGS
                                                                                                                                                                       (WASHINGTON, JANUARY 9, 1987)
                                               GOVERNMENT OF THE YUKON TERRITORY
                                                                                                                                                   MR. CHAIRMAN, PANEL MEMBERS, DISTINGUISHED OBSERVERS, LADIES AND
                                                                                                                                                   6ENTLEMENI

                                                                                                                                                   MY NAME IS WILLIAM J. KLASSEN.      I AN THE DEPUTY MINISTER OF THE
                                                                                                                                                   DEPARTMENT or RENEWABLE RESOURCES FOR THE GOVERNMENT OF THE
                                                       IN RESPONSE TO THE                                                                          YUKON.    OUR DEPARTMENT     HAS  THE   PRIMARY RESPONSIBILITY      FOR
                                                  DEPARTMENT OF THE INTERIOR                                                                       MANAGEMENT OF THE PORCUPINE CARIBOU HERD WHEN IT IS PRESENT ON
                                        DRAFT ARCTIC NATIONAL WILDLIFE REFUGE, ALASKA,                                                             THE CANADIAN SIDE OF THE ALASKA/YUKON BORDER.
                                               COASTAL PLAIN RESOURCE ASSESSMENT
                                                                                                                                                   WITH HE TODAY IS MR. WILLIAM OPPEN, THE DIRECTOR OF THE
                                                                                                                                                   INTERGOVERNMENTAL RELATIONS BRANCH OF THE YUKON GOVERNMENT'S
                                                                                                                                                   EXECUTIVE    COUNCIL   OFFICE.     MR.   OPPEN    HAS   THE    PRIMARY
                                                                                                                                                   RESPONSIBILITY FOR LIAISON BETWEEN OUR GOVERNMENT AND OTHERS.

                                                       WASHINGTON, D.C.                                                                            WE WOULD LIKE TO BEGIN OUR REMARKS TODAY BY THANKING YOU FOR THE
                                                        JANUARY 9, 1987                                                                            OPPORTUNITY TO MAKE THIS PRESENTATION.        THE RESOURCES OUR TWO
                                                                                                                                                   COUNTRIES SHARE ALONG THE ALASKA/YUKON BORDER ARE CRITICALLY
                                                                                                                                                   IMPORTANT TO THE PEOPLES OF THE YUKON SO WE ARE TRULY THANKFUL
                                                                                                                                                   FOR THE PRIVILEGE OF REPRESENTING OUR INTERESTS IN THESE MATTERS,

                                                                                                                                                   IN THE TWO PREVIOUS HEARINGS THIS WEEK IN KAKTOVIK AND ANCHORAGE,
                                                                                                                                                   THE DEPARTMENT OF THE       INTERIOR HAS HEARD PRESENTATIONS By
                                                                                                                                                   PROFESSIONAL STAFF OF OUR DEPARTMENT, FROM THE PEOPLE AND ELDERS
                                                                                                                                                   OF THE COMMUNITY OF OLD CROW, FROM OUR PORCUPINE CARIBOU
                                                                                                                                                   MANAGEMENT BOARD, AND FROM THE COUNCIL FOR YUKON INDIANS.           As
                                                                                                                                                   WELL, TODAY, WE ARE TABLING A TECHNICAL ANALYSIS OF THE DRAFT
                                                                                                                                                   EIS.

                                                                                                                                                   WE ARE HERE TODAY TO REPEAT AND REINFORCE THE COMPLEMENTARY
                                                                                                                                                   MESSAGES IN THESE DIFFERENT PRESENTATIONS - AND TO URGE YOU TO
                                                                                                                                                   RECONSIDER THE RECOMMENDATIONS FOR FULL DEVELOPMENT CONTAINED IN
                                                                                                                                                   THE DRAFT EIS.      WE SINCERELY BELIEVE THAT CRITICAL WILDLIFE
                                                                                                                                                   HABITATS AND RESOURCES ON THE     ALASKAN AND CANADIAN NORTH SLOPE
                                   PRESENTED BY:                                                                                                   SHOULD BE STRONGLY PROTECTED,     AND THAT THE NORTH SLOPE ITSELF
                                                                                                                                                   SHOULD BE MANAGED ACCORDING TO    CONSERVATION-ORIENTED OBJECTIVES,
                                   W,J, KLASSEN,  DEPUTY MINISTER,                                                                                 ANY DEVELOPMENT IN THIS REGION SHOULD BE PERMITTED ONLY IF IT
                                         DEPARTMENT OF RENEWABLE RESOURCES                                                                         WOULD NOT CONFLICT WITH THE CONSERVATION OF            THE WILDLIFE
                                   W. OPPEN, DIRECTOR, INTERGOVERNMENTAL RELATIONS BRANCH                                                          RESOURCES.
                                         EXECUTIVE COUNCIL OFFICE
                                                                                                                                                   WE FURTHER BELIEVE THAT REASONS FOR PROTECTING THE 1002 LANDS ARE
                                                                                                                                                   FAR MORE COMPELLING THAN THE OFTEN LIMITED TECHNICAL REASONS

                                                                                                                                                                                     2

                                   FORWARDED IN THE REkRT.   ALTHOUGH THE DRAFT EIS DOES IDENTIFY
                                   THE TRADEOFFS WHICH WOULD BE REQUIRED TO ALLOW FULL DEVELOPMENT                                                 INTERNATIONAL SIGNIFICANCE OF WATERFOWL HABITATS SUCH AS THE
                                   IN THE 1002 LANDS, IT DOES NOT ADEQUATELY ADDRESS THE TANGIBLE                                                  ARCTIC NATIONAL WILDLIFE REFUGE NORTH SLOPE.      WITH REFERENCE TO
                                   REALITY THAT THE MOST HEAVILY IMPACTED SPECIES ARE TRANSBOUNDARY                                                THE NORTH AMERICAN WATERFOWL MANAGEMENT PLAN, WHICH HAS THE 60AL
                                   RESOURCES OF CONSIDERABLE INTERNATIONAL SIGNIFICANCE.                                                           OF PROTECTING AN ADDITIONAL FIVE MILLION ACRES OF HABITAT BY THE
                                                                                                                                                   YEAR 2000, ASSISTANT SECRETARY HORN STATED 714AT "THE PLAN GOES
                                                                                                                                                   AFTER HABITAT ACQUISITION SO THAT WE CAN START TO BUILD HABITAT
                                   WITH RESPECT TO THE PORCUPINE CARIBOU HERD, FOR EXAMPLE, A MAJOR                                                BACK UP,   ONE OF THE CRITICAL ELEMENTS IN HELPING PUT OUR
                                   IMPACT IS IDENTIFIED DUE TO THE ENCROACHMENT OF DEVELOPMENT INTO                                                WATERFOWL POPULATIONS RACK TOWARD THE 100 MILLION LEVEL.           THE
                                   THE HEART OF THE CALVING GROUNDS.  THE EIS SUGGESTS THAT SUCH AN                                                OBJECTIVE NOW IS TO GET THE FINGER IN THE DIKE AND STOP THE
                                   ENCROACHMENT COULD LEAD TO A 20-40% REDUCTION IN THE SIZE OF THE                                                LEAKING'.    IN OUR OPINION,     PROTECTING   THE   ARCTIC   NATIONAL
                                   CARIBOU HERD. FOR THAT REASON ALONE, WE BELIEVE THAT ANY SUCH                                                   WILDLIFE REFUGE COASTAL PLAIN WOULD DO MUCH TO ACHIEVE THIS.
                                   IMPACT SHOULD BE CONSIDERED ENTIRELY UNACCEPTABLE.    HOWEVER, WE
                                   FURTHER BELIEVE THAT THE DRAFT EIS CONSIDERABLY UNDERESTIMATES                                                  SIMILARLY, POLAR BEARS PRESENT IN THE AREA ARE PART OF A       LARGER
                                   THE SIGNIFICANCE OF A REDUCTION OF THAT MAGNITUDE TO THE                                                        REGIONAL   POPULATION   THAT   SHOULD   BE   ASSESSED   IN   A    MORE
                                   SUBSISTENCE USERS OF THE HERD, WHO ARE PRIMARILY LOCATED IN                                                     COMPREHENSIVE MANNER THAN THAT PROVIDED IN THE DRAFT EIS.
                                   COMMUNITIES IN CANADA INCLUDING OLD CROW IN THE YUKON AND FORT
                                   MCPHERsoN, ARCTip RED RIVER, AKLAVIK, INUVIK AND TUKTOYAKTUK IN                                                 CARIBOU, POLAR BEAR, WATERFOWL AND OTHER MIGRATORY SPECIES PLAY A
                                   THE NORTHWEST TERRITORIES.     By  IGNORING    SUCH  TRANSBOUNDARY                                              CRUCIAL ROLE IN THE SUBSISTENCE ECONOMIES OF THE LARGELY NATIVE
                                   EFFECTS THE DRAFT EIS IS FUNDAMENTALLY FLAWED,                                                                  COMMUNITIES IN THE YUKON AND IN THE NORTHWESTERN CORNER OF THE
                                                                                                                                                   NORTHWEST TERRITORIES.    IN RECENT YEARS WE HAVE BEGUN TO BETTER
                                   WE ALSO MUST VOICE OUR CONSIDERABLE DISAGREEMENT WITH THE  WRITERS                                              MANAGE THESE SPECIES, BOTH FOR THEIR OWN SAKE AND TO ENSURE THAT
                                   OF THE EXECUTIVE SUMMARY WHO SUGGEST THAT DEVELOPMENTS     ON THE                                               THE SUBSISTENCE ECONOMY IS SUPPORTED IN A MANNER WHICH CAN BE
                                   C
                                   R              G        CAN BE                                   OF                                             SUSTAINABLE INTO THE FUTURE.     THESE MEASURES HAVE INCLUDED THE
                                   A lBGU CALVING  ROUNDS          UNDERTAKEN WITH NO MET    LOSS
                                   HABITAT QUALITY. SUCH A STATEMENT CONTRADICTS THE MAIN    BODY OF                                               ESTABLISHMENT OF THE NORTH YUKON NATIONAL PARK AND HERSCHEL
                                   THE DRAFT EIS AND WE BELIEVE SUCH AN ACHIEVEMENT IS LIKELY                                                      ISLAND TERRITORIAL PARK AND THE SETTLEMENT OF THE INUVIALUIT LAND
                                   IMPOSSIBLE.                                                                                                     CLAIM,   WHICH ESTABLISHES A CONSERVATION-ORIENTED REGIME FOR
                                                                                                                                                   MANAGEMENT OF    THE YUKON'S NORTH SLOPE.         IN ADDITION,     THE
                                   WE HAVE   SIMILAR   CONCERNS    ABOUT   THE   OTHER    SIGNIFICANT                                              GOVERNMENTS OF CANADA, THE NORTHWEST TERRITORIES AND THE YUKON
                                   TRANSBOUNDARY SPECIES.                                                                                          60T TOGETHER WITH NATIVE INTERESTS TO CREATE AN IN-CANADA
                                                                                                                                                   AGREEMENT ON MANAGEMENT OF THE PORCUPINE CARIBOU HERD,            THIS
                               .THE MUSKOXEN PRESENT IN ALASKA ARE SLOWLY REPOPULATING THE ARCTIC                                                  AGREEMENT HAS BEEN IMPLEMENTED THROUGH THE PORCUPINE CARIBOU
                                   NATIONAL WILDLIFE REFUGE AREA AS WELL AS THE NORTHERN YUKON,                                                    MANAGEMENT BOARD,   IT IS WORTH POINTING OUT THAT THE STIMULUS FOR
                                   WHERE THEY WERE EXTIRPATED DURING THE LAST CENTURY.     THIS IS A                                               MANY OF THESE MEASURES WAS THE CREATION OF THE ARCTIC NATIONAL
                                   VALUABLE AND IMPORTANT OCCURENCE WHICH SHOULD BE PERMITTED TO                                                   WILDLIFE REFUGE IN 1980, AND OTHER CONSERVATION MEASURES ENACTED
                                   CONTINUE.                                                                                                       IN ALASKA.

                                   THE MIGRATORY SNOW GEESE POPULATIONS, WHICH USE THE 1002 LANDS AS                                               THESE LAND ALLOCATIONS AND MANAGEMENT STRUCTURES HAVE BEEN PUT IN
                                   AN IMPORTANT STAGING AREA, ARE ALSO UNDER CONSIDERABLE THREAT                                                   PLACE TO PROTECT HABITAT FOR PORCUPINE CARIBOU AND OTHER SPECIES,
                                   FROM THE PROPOSED DEVELOPMENTS,     AND THERE     IS VERY LITTLE                                                AND TO ENSURE AN APPROPRIATE, SUSTAINABLE ALLOCATION OF THE
                                   ACKNOWLEDGEMENT OF THE INTERNATIONAL IMPORTANCE OF THE SPECIES,                                                 HARVEST IN THE REGION.       THEY ARE AN ACKNOWLEDGEMENT OF THE
                                                                                                                                                   DEPENDENCE OF THE PEOPLE OF OLD CROW ON THE HARVEST OF THE
                                   HOWEVER, WE  DO NOTE   THAT THE    DEPARTMENT OF     THE   INTERIOR                                             PORCUPINE CARIBOU HERD AND  AN ACKNOWLEDGEMENT OF THE CONSIDERABLE
                                   RECOGNIZES THE IMPORTANCE OF WATERFOWL HABITATS.     WE WERE VERY                                               IMPORTANCE OF THE HERD, GENERALLY, TO THE PEOPLE OF THE YUKON,
                                   ENCOURAGED TO READ IN A RECENT ISSUE OF THE DUCKS UNLIMITED                                                     THE NORTHWEST TERRITORIES AND CANADA.      IN ADDITION, THEY ARE AN
                                   JOURNAL THAT ASSISTANT SECRETARY HORN IS WELL APPRISED OF THE

                                                                  3                                                                                                                  4

                                  INDICATION    OF   OUR   GOVERNMENT'S     STRONG   COMMITMENT    TO     THE                                                   THE CUMULATIVE EFFECTS OF SEVERAL DEVELOPMENTS COULD ONLY BE
                                  IMPLEMENTATION   OF THE WORLD CONSERVATION STRATEGY.                                                                          DEALT WITH THROUGH JOINT PLANNING WITH ALL RESOURCE USERS ON BOTH
                                                                                                                                                                SIDES OF THE BORDER.     THIS RAISES THE ISSUE OF CONSULTATION WITH
                                  MR.   CHAIRMAN,    NONE OF    THESE VERY     SIGNIFICANT FACTORS ARE                                                          OUR    GOVERNMENT   AND OTHER     CANADIAN    JURISDICTIONS.       ALTHOUGH
                                  IDENTIFIED    IN   A MEANINGFUL WAY       IN   THE   DRAFT   EIS,    WHICH                                                    REQUIRED UNDER SECTION 1005 OF THE ALASKA NATIONAL INTEREST LANDS
                                  NONETHELESS PROPOSES TO IMPOSE A DRASTIC REDUCTION IN THE SIZE OF                                                             CONSERVATION ACT, NO CONSULTATIONS WITH OUR GOVERNMENT OR OTHER
                                  THE 14ERD THAT WILL POTENTIALLY HAVE A HUGE EFFECT ON OUR PEOPLE                                                              CANADIAN AGENCIES.       INTEREST   GROUPS OR      NATIVE    ORGANIZATIONS
                                  AS WELL AS YOURS-                                                                                                             OCCURRED.    IN THE HEARINGS IN ANCHORAGE ON THE OFFSHORE LEASE
                                                                                                                                                                SALES, WE MADE AN INTERVENTION IN WHICH WE EXPRESSED OUR CONCERNS
                                  MR. CHAIRMAN. ALL OF THE SPECIES AT RISK FROM THE PROPOSED                                                                    ABOUT THE LACK OF CONSULTATION WITH AGENCIES IN CANADA. WE WOULD
                                  DEVELOPMENT HAVE BOTH UTILITARIAN AND INTRINSIC VALUE AS PART OF                                                              LIKE TO EMPHASIZE THAT SAME CONTINUING CONCERN HERE TODAY.              ONLY
                                  THE ARCTIC ECOSYSTEM.      THEY ARE INTERNATIONALLY SIGNIFICANT AND                                                           BY ACTIVE AND ONGOING CONSULTATIONS BETWEEN OUR JURISDICTIONS CAN
                                  FIGURE HIGHLY      IN THE NORTH AMERICAN UNDERSTANDING OF               THE                                                   WE   ENSURE    COORDINATED     AND     CONSISTENT   MANAGEMENT     OF    THE
                                  IMPORTANCE    OF   ARCTIC   REGIONS.      PROTECTING    COMPLETE     ARCTIC                                                   TRANSBOUNDARY RESOURCES THAT WE SHARE. THE GOVERNMENT OF CANADA,
                                  ECOSYSTEMS WAS     THE PRIMARY VISION OF THOSE WHO DEVELOPED THE                                                              THROUGH THE FEDERAL DEPARTMENT OF EXTERNAL AFFAIRS, HAS FORMALLY
                                  ARCTIC NATIONAL    WILDLIFE REFUGE AND    WHO LATER HELPED TO CONVINCE                                                        REQUESTED A MEETING OF UNITED STATES, ALASKAN, YUKON AND FEDERAL
                                  THE GOVERNMENT OF CANADA TO PROCEED       WITH COMPLEMENTARY PROTECTION                                                       CANADIAN OFFICIALS TO FULFILL THE REQUIREMENTS OF SECTION 1005.
                                  MEASURES.     IT WOULD INDEED BE EXCEPTIONALLY UNFORTUNATE IF THIS                                                            ALTHOUGH IT HAS NOT BEEN CONFIRMED, IT IS OUR UNDERSTANDING AT
                                  VISION WERE FORSAKEN, BASED ON AN INCOMPLETE ASSESSMENT OF THE                                                                THIS TIME THAT THE MEETING 'MAY BE HELD LATER THIS MONTH IN
                                  VALUES OF THE REGION.                                                                                                         OTTAWA.
                                  MR   CHAIRMAN, IN OUR VARIOUS PRESENTATIONS THIS WEEK WE HAVE                                                                 TO SUN UP, MR. CHAIRMAN, WE HAVE        THREE MAIN CONCERNS WITH THIS
                                  POINTE D OUT A RANGE OF PROBLEMS WITH THE DRAFT EIS, WE HAVE                                                                  EIS.   FIRST, WE WOULD NOTE THAT,         DESPITE THE REQUIREMENTS OF
                                                                                                                                                                SECTION 1005 OF ANILCA, NO CANADIAN GOVERNMENTS, AGENCIES, NATIVE
                                  TE CHNICAL    CONCERNS ABOUT ASPECTS OF         THE   INTERPRETATION OF                                                       GROUPS,   ENVIRONMENTAL GROUPS OR OTHER           INTEREST GROUPS WERE
                                  BIOLOGICAL OATAJ WE HAVE DISAGREEMENTS WITH           THE RATING OF THE
                                  SIGNIFICANCE OF SOME IMPACTS; AND WE ARE DISTURBED BY THE                                                                     OFFICIALLY CONSULTED ABOUT THE 1002 REPORT,         SECOND, THE EIS DOES
                                  TRADEOFF THikT HAS BEEN CHOSEN BY THE AUTHORS OF THE DRAFT EIS,                                                               NOT ADEQUATELY CONSIDER THE POTENTIAL CUMULATIVE EFFECTS OF THE
                                  PARTICULARLY IN THE LATTER CASE THERE IS A FAILURE To ACKNOWLEDGE                                                             VARIOUS DEVELOPMENT POSSIBILITIES IN THE ALASKAN NORTH SLOPE AND
                                  THE TRANSBOUNDARY EFFECTS OF DEVELOPMENT,            WHEN ONE CONSIDERS                                                       THE    ADJOINING    CANADIAN      LANDS   AND    WATERS.      THIRD,     THE
                                  FURTHER THAT THERE IS NO ASSESSMENT OF THE CUMULATIVE EFFECTS OF                                                              RECOMMENDATIONS IN THE EIS 00 NOT REFLECT THE BROADER ECOLOGICAL
                                  DEVELOPMENTS ON 1002 LANDS WITH THE PROPOSED DEVELOPMENTS ON THE                                                              RESPONSIBILITIES THAT OUR GOVERNMENTS SHARE TO ENSURE THAT THIS
                                  OUTER    CONTINENTAL     SHELF   LEASE    SALES    OR   OTHER     POTENTIAL                                                   GLOBALLY-SIGNIFICANT      WILDLIFE     RESOURCE    IS  14ANAGED   TO    MEET
                                  DEVELOPMENTS OR ACTIVITIES IN ALASKA AND THE IMMEDIATELY ADJACENT                                                             CONSERVATION-ORIENTED OBJECTIVES.
                                  AREAS OF CANADA, ONE CAN ONLY CONCLUDE THAT THE DRAFT EIS DOES
                                  NOT PROVIDE AN ADEQUATE ASSESSMENT OF THE NEGATIVE CONSEQUENCES                                                               IN VIEW OF THESE AND OTHER CONCERNS WE "AVE RAISED, MR. CHAIRMAN,
                                  OF DEVELOPMENT-                                                                                                               WE WOULD STRONGLY URGE IMF. DEPARTMENT OF THE INTERIOR TO
                                                                                                                                                                RECONSIDER THE SUBSTANCE AND THE CONCLUSIONS OF THIS DRAFT EIS.
                                  WE WOULD ALSO ADD THAT IF WE CONSIDER THIS UNDERESTIMATE OF                                                                   THE RESOURCES AT RISK ON THE 1002 LANDS ARE NOT SIGNIFICANT
                                  ENVIRONMENTAL EFFECTS IN LIGHT OF THE EXTREMELY PROBLEMATIC                                                                   SOLELY    FROM   AN   ALASKAN    PERSPECTIVE.       THEY   ARE   ALSO     OF
                                  NATURE OF THE ENERGY RESOURCE ESTIMATES, WE ARE NOT CONVINCED                                                                 CONSIDERABLE SIGNIFICANCE TO CANADA AND HAVE WELL -ACKNOWLE DGED
                                  THAT THE TRADEOFF PROPOSED IN THE DRAFT EIS IS EITHER A REALISTIC                                                             INTRINSIC INTERNATIONAL       SIGNIFICANCE,    AND SHOULD BE MANAGED
                                  OR A COMPLETELY FAIR EXPOSITION OF ALL THE FACTORS AT RISK IN THE                                                             ACCORDINGLY.     IN THE LAST 15 YEARS, BOTH IN ALASKA AND IN CANADA
                                                                                                                                                                SIGNIFICANT STEPS HAVE BEEN TAKEN TO PROTECT THESE RESOURCES. IN
                                  SITUATION.                                                                                                                    OUR OPINION, HOWEVER. THE FULL-LEASING ALTERNATIVE RECOMMENDED IN
                                                                                                                                                                THE DRAFT EIS WOULD BE A STEP IN THE WRONG DIRECTION.

                                                                        5                                                                                                                              6

                              THANK YOU VERY MUCH FOR THIS OPPORTUNITY.

                                                               7

                                                                                                                                                                                                                                                                                                                                                                                         M. M.     Ap,,,;
                                                                              Not Man Apart
                                                                                                                                                                                                                                                     From                                                                                                                                           I=- T=r=
                                                                                                                                                                                                                                                                                                                                                     Not
                          Superfund comes through
                                                                                                                                                                                                                                                     Political Purity                                                                                AW
                                                                It.   D.

                                                                          am. a d
                                                                                                                                                                                                                                                     wl.=                                   Fl-      wh'adpa.-I'd-h.
                                                                                                                                                                                                                                                                       C=                            d-d- -d -w p-
                                                                                    ERiE
                          LM             6MMItm       @,4,p                        -                                                                                                                                                                                                                 d- III& d. 6- C.W-                  d-
                                                                                          &W-fi.A By
                                      .f;:==bjiL fty-P                C- It. P-W- h. 10 dp
                          VM pb
                          d-d                W d...d d..p                                                                                                                                                                                                                                            -.w 0. -dk, Z.P=,.=
                                                  -h                                                                                                                                                                                                                                                   AW@ --pqp .-.k
                          tf..=@== =M@                                                                                                                                                                                                                                                               I           -d*                     IIA MA
                                      WW 116 b&- E...-d               R,.bl-            p-A, -A d-                                                                                                                                                                                                   d-      :,= tZ
                                                                                                                                                                                                                                                                                                     d.M- d d.
                                      0-           E.--d              ft P-d-                   p-d .                                                                                                                                                                                                                                                                                                . . .......
                                                                                                                                                                                                                                                                                                                             Y                          ..............
                                                                      R.Pd-                                                                                                                                                                                                                                                                     . ..... ....
                                                                                                                                                                                                                                                                                                       .0 d-          TtII,              bOl=
                                                                      d- d- &.                                                                                                                                                                                                                                               ":Zd_          . . . .. .......
                                                                              b.- bd %m kbb* III                                                                                                                                                                                                     d..,b Ia." P.&-d mI d-
                                                                      4d,
                                                                                                                                                                                                                                                     @I-&-ftsh.Wdw@                                  kM k du 4,Wt
                                                                                                                                                                                                                                                         b.A IfII, di--- .4 -N@b                     U kd- h.                I.-         R-h.
                                                                                                                                                                                                                                                              b. " -@ @                              d*d- . - dj'a I
                                                                                                                                                                                                                                                     d. - ft.                               &M P@    :L- I-                              b,
                          n. p.@ &r- b-                                   _A6.4 Nt-..d                      MdAw                                                                                                                                     I- m      .....   Il,                  LL-d-              PL.@
                                                                                                                                                                                                                                                     4c" 11. L-ft
                                                                L                                                                                                                                                                                      V,,W "ISM                            -&-,- a
                                      ===bVpl                                                                                                                                                                                                                                                                                                 - - --- -----
                          IN- 5
                          @ d d.                    P-.b-.d                                                                                                                                                                                          d.,.,b                                 A-       E......     k- a A
                          kA..M IIII,
                                                                      Landawk Hydroelectric Bill Protects Fish and Wildlife-
                                                                                                                                                                                                                                                                                                                      11 d*
                                                                                                                                                                                                                                                                                                                             h-.Pprd     . . . . ........
                          fi.d
                          IL75 bN- E-             ;=rST144                                                                                                                                                                                                                                                                               b,*
                          bd- h-=-d-.d O.Ad@                                                                                          -,,d ft 4-             d.. filM d.
                          t3 b4-          . W.Ilh-d A-,W                                                                                                                         P= k..W                                                             fi- W M.AW J- b- d.                             h- U_
                          M SIZ                 p,"                                                                                                          6. pm-                b- -.d....r
                             SW V- b- - w ft-                                                                     M&                                                               MWA P.4-                                                                                                 ......A  C...b Md- 0. -.V% V .
                                                                                                                                                                                                                                                     10 r- ..I- P.-                         .
                          b-k                d.                       ftP..&-                                     bhq III FERC. h-ft =Ab.                    *- - - - - -iV.                                                                         &.*                                             . p. -p- paw- bIbW b-
                                                                                                                                                                                                                                                     I.-                                             A- 1.6 -A d. p.-                    FiIW
                          dftd-t=                                     6.14                                                                                                                                                                                                                  fidd     -FL
                                                                      dd-w
                                                         PA-              b, - -===                               =Zt--=                                                   . =d             Wb..
                                                                      C-- (Mo.
             in                                                 -     "I
                          h. =1
                                      d.                Th-           :L"=-.TCC==                                 P.-M                                          .1 d. H.- E.W d C-
                                                                                                                                                             C-- M . S- 1). C- il-
                                                                                                                                                                                                                                                     FOE Hires New Executive Director
                                                                                                                                        -.1 ft , R-- C-- 6. ft A. d"
                                            ---p-                                         =zW
                                                                             -bm= &,b-                      -h-   (PMA). P.,-                                                                                                                          Wo pk,,d w                           hki%,A
                                                                                                                  19M PAlk U'UY 1=1=1                        =.:d
                                                                                                                                                                                                                                                     Crd" L Vibm w If, @ EII-,I
                                                                                                                    =md-=Wb, 'Mh                                                                                                                     0- d ft-b 14 ft &lA Srw
                          bA A. V-fi. 111.            6--             N-          T.                                                                                                -a" C .. If                                                      @ftfi-h.,IKIEd
                                                                                                                                                                                                                                                     IM bI, d. * - ..b.,db.                               ;,          , i
                                                                                                                                                                                                                                                              -C-q .1 T..- --.a
                                                                                                                                                                                                                                                     kw-
                                                                                                                                                                                                                                                             W                              =7
                                      CONTENTS                                                              Special Election Issue                                                                                                                                                          1%5 a
                                                                                                                                                                                                                                                     M- 7.

                             N-                                 1.5   WOE       ......................      7                   D-W .... tO-U                Md E.-M C@           ..........    17
                                                                                                                  L- T.W
                                                                                                                  Th. 0-         Rb- tn-                     :=EnC=                                                                                                                         ..b FOE*. CTd- WE-
                                      Mm E.,C-W       Pbui. M                                                                  h-d                                                                                                                                                          W                                            A-T
                             S. - 1.9 p- -                            d- A.                     U d. FOE
                                                                                                                  ..4 - = = p-                                   bft                                                                                                                                     k@:::MIIAI
                                      Rd- . P-ftft&-                  1-6-d -1                              icI   kb   I      I                                                  z 1-                                                                                                                            -at         ==kl
                                                                      P-.% MA@ @=                                                                                                                                                                                                           . @ FOV. 1961. *. b. .ed
                                                                                                                                .1 ft fk-h. a-               A- d-                                                                                          r-.w b.0,
                                                                                                                  P.Vmw w b, - of ft Lm                      D.WR-i                                                                                                                                                   di- . -b. d.
                                                                                                                                                             UI, N-- Alf- --.d by P-
                                                                                                                                                  L3.16                                                                                                 Zb.;,,fftWhI.V-DCdt-                         W& A. M-
                                                                                                                                                                                                                                                     a ft N-w A."- S-q
                             :=OW M- Ri-                                                                                                                     C.Wk                                                                                                                                                     d.     f.. I:=
                                      d. U.-WO                                                                         PW..d D- D.,W BA.                                                                                                                                                             V- C..U Wdb. ft
                                      d                                                                     r-    FOE                                        L- . 6. Edi     . ..........       19
                                      -h             i. M a                                                                  bw W-6 --w It.
                                                                                                                      C..-
                                         .-hbs-                       Vq-
                                                                                                                                                             P.P.6-
                                                                                                                                                  14-15                                                                                              ddwbwiwCWDAndmft,,197?w
                             &-V IGE bid-                                                                                                                                                                                                                                                                   =mdmW'Wdb@M
                             0. pi- P-                                                          EDE .1 d.         FOIPACW-d- J. d,. J"S                      C- Pb-"A W- SbW F-r                                                                     ml.whk.h-wa- @ ,                                =                                   - md
                                                                                                                                                             5,                                                                                      1!,1, Dp-. k . d. -.,bA                         @ p- d .p.W 4d-
                                                                                                                                                                                                                                                     Akd. L.I& -f.,p 0- IM dW.

    ~0

                                                                                                                                                      G~al                                                                                                             Plastic Clogs The Oceans
                                                                                                                             Co~ age In Bio-topi~                                                                                                                                                                                                                                                               ~p-~1p- -~ -~           4~                                                                                                                                                                            ~-
                         N.d~p,~                                    I~                                                           ~                                                                                                                                  In ~i~                                                                                                                                                      ~~p-                                                                                                     ~                                                                                                                                                                                                                                                                                                                ~pm~                                                                                                                                                                                  d~                                                                                                                                                                                                                                                                                          ~                                                                                                                   ~~w
                                                                                                                                                            ~                                                                                                                            ~_ G~~                                                                  ~"~                                                                             ~                                                                                                              ~-~~                           -~~h.~                                                                                                                                                                                                                                                                                             ~A~ C_
                                                                                                                                                      ~ ~                                                                                                                                                                                                                                                                                                                                                                     ~.~        ~                                                                                        b~              ~1pl                                                                                                                  ~~Ih~                                                                                                                                                                    ND~                                                  ~                                                                  ~V ~0 ~                                                                                                                                                                                              ~             ~.~.
                                                                            H~                                                                                                                                                                                      1~d~1p@~p-~@~-~                                                                                                                                                                                                                                                                                                ~                            ~                                                                                                                                        .~-~                                                                                                R~t~                                                    ~-~~                 ~&
                                                                                                ~                                                                                                                                                                   ~F~2p) m~II~pW~4~                       ~   ~~p I,,          ~                                                              ~d~                                                          k~- ~                                                    WIS~p-~ ~i~-                                                                                                                                    ~ ~       -~-~                        ~                                                                                                                                              ~pI~~                                                                                                                   ~-~~~                   I~                            -I,-                ~                                                                                                                                                                                                                                                                                                ~1d bn~                                                                                                                                                                                                                                                                                                                                                                    ~                                                                                                                                           ~pC~=~                                                                                          ~. -~                  49 p~               ~2p- ~_~             A- ~                                                                                                                                             p~~ -~p.~     bit ~                                                                                                                                                      ~~      ~(~                                                                               A~~              ~                                                                                                                               ~.~                                                  ~                     ~I~pW ~                                                                                            ~ ~q~ ~                                                                                                             ~                                      ~   ~.~       ~ph~
                                                                            ~2pd~"~                           ~                                                                                                                                                              ~-~                                ~o~                      ~Y~       ~                                                                      ~p-~p-~.~                                                    Th.~                                                                                                                         VOL                     ~.                   ~p.~~                    L~o~                                                                              it= ~             ~.~                                                                                              ~                                                                        ~                            ~                                                                                                                                      ~1pP~w~id~           -~         ~                                                                                                                                                                   ~S~                                                                                                                                                         ~~..
                                                                                  AVE^.                                      T~                a ~              ~                        ~     ~p-~                         ~d ~                                                                                                                                                                                                                                                                             ~                                                                                                                                                                                                                                                                                                                                                       P- ~                                                                                                                                        A     ~                     ~ ~~=~                ~                                                               III   _ ~1pk _ _~,
                              ~(~ ~pb~                                                                                             p~- ~-~w~                 ~-~~2p&~                                                                                                                                                                                                                                                                                                                                        ~pm          I~p.                 ~C~, ~                                                                                                                                                                                                                                                                      False Fronts                                                                                                       ~~                                                                                                                   ~                 ~                                                                                                                                                                                                                                                              d.
                                                                                                                                                            I            ~. -~                                                                                                       ~  d~1p=
                                                                            ~~                              =-~=~                                                                                                                              ~pk. A. A,, ~p- III~                                                                                                              A&
                                                 ~I~                                                                 ~                 ~                                                                                                                ~@ ~p.~                                                                                                                   d.                                                                                                                                                  ~p.~p.
                                                                            ~                                                                                                                                                                                                                                                                                                                                                    ~                                                                                                                                                                                                                                                                                                                                                                                            ~ ~                                                                                                                                                                                                                                                                                                                                                                                  ~.~ ~                                                                                                                                                                                                                                                                       ~H~
                                                                                                                                                                                                                                                                                                            ~                                                    ~1pW~                        ~~p11~    ~1pD~                              ~~1pf~                                                                                                                   ~                                      ~             P..
                          USSR                                                                                                                                ~    ~                                                                                            ~~2p(~                                                                                                                                              ~       1                                                                                                     ~P~pw~          ~2p"~              ~-~         R~w the R~                                                                                                   ~                                                                                                                                              ~p.~                                                                                                                                           e~pR~                                                                                                                                                                                                                                                               ~2p.~p:-~   ~  ~f~~                                                                                                                                                                                                                                                                    we ~~p.   b~                                                                               ~                                                                                                                                                                                                                    ~ ~                Thais Protest Radioactive Dump
                                                                            ~~      ~.                                                                                                                                                                               ~~A~wp~                                                              ~         ~                                                                                   ~                                                                                                               T~                -~p-~                                                              ~                                                                                                                                                                                           ~&~                                                 In d~pW ~d a-- ~  ~
                                                                                                                                                                                                                                                                                                      ~ m~~                                                                                     E
                                                                                                                             ~~~K-~~                                                                                                             ~~6~I~               d~                                                              --~                                                                  ~                                                                                                                                                                                                                                              ~       ~1p.~                    ~~         ~                                                                                    ~~~                                                                                                                   ~~                                                                                                                ~ --A
                                                                            d.            ~                                                                                                                                                                               P- ~A- E~     ~
                                                    -,A Rd~                                                  ~_~ ~        ~                                                                                                                                                                 ~d            ~                                     ~@~~, - ~                                                                                                                        ~p4 ~p.~     ~                                                                                                       ~~pdi~
                                                                                                                                                                          ~i~                                                                                ~pr~~~~                ~-~2p-~d~4      ~                 ~                                                                                                                           d~.~      ~                                                                                                                          ~                                              - ~                   ~~2pw-
                                                                                                                                                                                                                                                                                 ~~                                                                 ~                                                                                                                                                                                                                                                                                                                                            ~                               ~pI~*
                                                                                                                                                                                                                                                                                 ~ b~                                                                                                                                                                                                                                                               by                         ~1pb~      ~                FWS Proposes Reserve Sea Otter                                                                                                ~                                                                                                       p-~  ~                                                                                                                                                                                                                                                                   ~- .~~                                  d~                           ~                                                                                                                           ~_ ~    ~                                                                                                                                     ~~                        ~=~                                                                                                                                                                                                                                                                                                                                                                                          ~
                                                 Breeding ~                                                           ~           ~                                                                                                             "If ~         ~                                                                                                                       ~              - A-                                                                                                                       by ~I~1p1~4~p- P_ A ~1pw~            I~                                                                                                           ~           P.M.                       A& ~                                                                                     ~~p-~                                                  ~                 ~p.-~                                                                                                          ~I                                                                                                                                                                                                            ~                                                                                                                                                 ~pd~                                                                                                                                                                            ~d
                                      ~phm~,                                                                                                                                                                                                                    ~0~       ~d~                             ~                              ~           ~                                                                                                               ~                                    ~                                                                                                                                                                            ~1pd ~~h.               HMO~--~                                     ~F~                                                                                                                                                                                                                                       ~          d~p. d~                        ~pI~p,~Is                                                                                                                                                                                                   ~p.~      =~      ~              ~2pp~pd ~            ~f~~                                                                                                                        ~                                                                                                                                         ~~pl~                          _ III             p~b ~I-~pI ~     ~~
                            ~         ~                                                                                                                                                                                                                                                           4~                                                                                                               ~1pf~d~                                                                                                                                                                         1~   ~                                                                                                                                                       ~        ~c~"                                                                                   ~, ~                                                                                                                        ~f~p"~                                                                                                                               ~             ~.~S ~pb~                                                                                                                                        ~                                                                                                                                                                                         ~p.~                                                                                                                                                                                                                                                                                                                                                                                            ~. 1- ~- ~                                                                         -CAN                                          -by                                                                                                                                                                                                                                                                    ~1p" ~ ~                                                                                                                   ~       ~2p-                                                                                                                   ~            ~2p'~                                                                                                                                                                                                                                                                                                           ~                                                                                                                                                                                                                                                               ~~1pw ~~      ~                            ~                 ~.
                                                                                                                                                                                                                                                                                 ~b~    ~pI~A-                             ~b~                           ~                                                                                                                                                                                                                                                                                                                                              -~~                                   F~   ~        U~p4 ~-~                                                                                                                                                                                                                   ~(A~            ~pd~K~
                                                                                         ~~                                             ~                                                                                                                   d~~N  ~ph ~            ~                                 ~p, _ ~                                                                                           ~                                                ~     OR ~                                                                     P.O. ~1pf~pw~3~                                                                                                                                        ~

    ~0

                         N~                                 ~                                                                                                                              ~                    Po~
                         ~1pI~2pd~                    - ~- ~                                                                                                                                                                                       The Mississippi:
                                               ~pl~          ~                                                                                                                                                                                          That Old Dammed River
                                   A~f~w ~                                            ~                                                             ~~.~p-~. ~. ~                ~p@ ~                             i~  ~a.- ~pW~1
                                                      H~                     ~P. ~                                                                                                                                                                                                                                        ~.~         ~            $,AM a- ~                ~- ~.~.~                                     ~          ~p.~                                                                                                                                                                                                           R~~2p.~pq~                              ~                     ~ ~1pb~fa~                                                                                                                                                                                                                    W~p'-~. ~~@ ... ~0~                                     ~2pA~   N~~p~1~                                                                                                          ~                                                                                                                                                                                                                                                                    ~~id ~.~                                                                                                                                        ~                                                                              ~~                                                                                                                                                                            ~1p&N-~           ~                                                                                                                                                                                                                                                                        ~    ~#~                                                                                                                                                                                                                                                                                 ~q~               ~L            ~p1~~ ~            A~                I- EPA. ~            by         -~                                                                                                                                                                                                                                                                    ~                                                                                                                                                                                                                                                                                                                      ~m~2pP~  ~           C~ I E~-~                 ~1~         ~                                                                                                                                                             d ~pw0h~                                          fi~               m-h~1pSi~   ~                                                                                                                                                                                                                                b~ ~                                                                                                                                                                                                                                                                                                                                 ~~     ......      ~                                                                                                                                                                                                                                                                                                                              ~p.
                                                                                                                                                                                                                                                                                                                                                                ~-di~                                                                                                                                                                                                                                                                                   ~                                      ~ ~              EPA ~d N- ~                                                                                                                                                                                                                                ~                     ~1                                                                                                                                                                                                                                                       ~                     a ~~ d ~         b~p.~~                          I                                                                                        ~"                                                             EPA Bans                                                                                   -.pd ~i~                ~       A p~~                            I-     ~.~                       d-dd-~p&
                                                                           ~~                       ~d ~pw ~                                                                                                                                                                                                                                                                                                 ~ ~F ~~-
                                                                           ~                 ~1 ~  ~                                                     Pesticide                                                                                                                                                                                                                                                          ~                                                                                                                                                                                                                                                                                                                                                                                                                                             ~pb~                                                                                                                                                                                                                                                                                                                                                                                                                                        ~
                                                                             b-                                                                  ~                                                                                                                                                                               ~pi~                                         ~.                                 ~                                                                 ~i~pl~1pd                     ~               ~~                         Dinose~                                                                                                             ft       ~      ~.~~      by ~- ~.~                                ~-~.
                                                                                                                                                                                                                                                                                                                      d~i~                     ~-
                                               U~  D.~                                                                                                                                                                                                ~                                          ~ ~                                                                                                                                                                                                                                                                                                                                A-~pd- a ~%                                         ~~      ~                             in 19~              ~ h. ~                      ~pk~1p. ~. ft                      1~                                                 D~~1pb~@~                                                                                            ~                                           =~k~~                        h~.~p1 b~
                                               ~ ~        ~  ~pN~        ~                                                                                                                                                                                                                                                                                          ~                                                                                                                                                                             ~                                                                             d~A~                    ~                                           ~w~~                               A~~                                                                                                                                ~                                    ~ m~p@~                                                                        ~         ~                                                                                                                                                                                                                                                                    ~                                                           b~                                                     b~ ~pR- ~2p-
                                                                                                                                                                                                                                                                                                                                                                                        d    ~                                               ~p!~p. a
                                                                                                                                                                                                                                                                                                                                            ~_ ~                       ~~                                                                                                                                                                                                                                                                                                                                                                                        ~.hkh
                                                                                        ~W~                    ~                                                                                                                                     Am.&% a d~~&                                                                                                                   ~                                                                                                                     ~           ~pi~                  ~                                                                                                                                                                                                                             b-~   ~~1p@~                                                                                                                                                                                     A~ ~                                                                                                                                                                                                                                                                                                                          b~2p- ~-                    ~pk~t a                               h~       ~2p8 1- ~                  '~                                   A~~                              ~                                                         ~EPA~                                                                     ~                                            ~             ~~p~pW.                         ~N~pk~                          ~P~                                                                                                                                                                                                                                           ~                                                                                                                                                     Al.~          Ck~- ~                                                                                                                                                                                                              ~       ~1pw -
                                                                                                                                                                                                                                                                                                                                                                                        ~A~                 ~     =.ft ~                 ~                                                                                                                                                                                                                                                                                                                                                                                      ~   ~                                   ~2p.~     ~                                                                                                                                                                                                                                                                                                                                           ~                             K
                                                                                                                                                                                           The m~@ b~                                                                                             d.-~                                                                                                         ~                    New York Passes Environmental Bond Issue                                                                                                                          ~1pk~                                                                                                                                                                             ~                                                                                                                                                                              a.                                                                                                                         ~                                                                                                                  ~~p.~                                                                                                                                                                                                                                                                                                            ~d~                                                                                                                    ~                           ~ Y~         h~                                                                                                      --~                                                                                                                                                                                                                                              a ~p@ ~                                                                                                                                                                                ~~                                                                           ~pb~                                                                                      ~                 ~     E~m~1p. d~                                                                                                                                                                         ~    ~~                                                                                         n~p.
                                                                                                                                                                                                                                                                                                                               ~                                                     ~pr~                                                                                                                                                                                                                                                                                                                                                                              ~                                     ~".....
                                                                                                                                                                                                                                                                                                                      ~f~                                                        ~ ~               i~~   i~1p.                                                                                                                            ~          ~                                                                                                                ~                                                       ~        ~     ~p7~                                                 ~                                                                                                             b~2pd. ~~                                                                   ,-a A ~w~                              ~                               ~~                  Inn-@              ~                ~           ~l~1p.                            ~                                                                                                       ~1pK~p.~                                                                    ~~-.~                                                                                                                                            ~.~. Upp~       ~1pW                     ~W                                                                                                                               ~                                                                                                  ~b           ~h~                                                                                                                                                                                 ~d~pA~                                                             ~    ~2p19~1pv~                                                                                                               ~w~p@~            ~                                  ~ ~~                                                                                                                                                                                                                                                                                                                   ~                                                                 U~h
                                   ~pq~                                                                                                                                         ~4~19~0~p).~                                                                                                                                                                                                                  ~~~~~       ~.~, a ~                                                                                                                                        EPA~~t~                                                                           h~pW E-                                                                                                                                   ~~1p..~
                                                                                                                                                                                           d~~                                                                    ~p@ ~                               ~-~p6
                                                                                                                                                                                           ~       ~                   ~                               ~                                                     b~                                                                                                      ~2p;~~                                                       ~ Aa~d.                                ~   ~                       T- R-                                   ~     ~H~p-~p. A]-
                                                                                                                                                                                           ~' ~                                                                                                                                                                                                                                ~~"
                                                                   ~                                                                                                                                                                                                                       ~h~~@            ~p@~1pb ~                  -~1~2p-                                            ~                   ft N-~ ~ by                                                                                                                                         ~E~                                                                          R-~p. ~f~~                     ~W-                             ~p-~1p. ~-~                                Th. ~3~@
                         ~      ......         ~- ft            T- - A-               PAM ~b-                       ~                                       um. ~                                                                      ~H~@ ~~               ~~h~     ~w~~                            W~pf~m ~           b~- ~                         p~2p.~-                                   ~2p-~                                  ft ~        ~                                                       4~p~1p*~                                                                     ~by                                                 w-~~d~ d~          ~t~   Y.~pd      A~A~            ~                     S~t ~                                        ~                                                                                      ~~p.~                                                ~d ~f                                                  -~
                         ~                                                                              1. ~p.-~pW~                                                     ~                                                                                      ~b~            ~                                  Th. E~                                        ~W~p.
                         ~~~                    d-p~@~                   ~.~                p~                ~                                                                                   T~                                      A-~~                                    ~-~                                 ~.~2p.~                    -~~                        ~~h ~p-~0                                                                                    ~    ~pW                                                                     ~p-~~               ~~2pG~                        ~~                  ~        fi~~ ~~                                                                  ~.~~                                 ~" ~p.                                  ~ ~~                                                                  Aft ~p~.~-~           ~2p.~p.~       ~p-~2pd~~                                  ~@ -~Wfi~       ~1pi~                               ~p@ A~m~                                                                                         d~ph~d - ~                                                                  ~                     ~    ~pf~pb~     ~pd~w~k~~                     ~-~
                                                                           d~~                         ~*~- Y~                              = ~I.- ~.~                                                         _~=~~            ~pi~                        ~ ~ 26
                                                                           ~=~pa~                     ~         N~                                      ~. ~                                                             ~1 ~p5                  -a ~~          ~W a ~                 ~pkW                       ~     -WHAT YOU CAN ~               ~A~p. ~                         ~pw~         ~                ~6 p-~                                 ~                                                                                ~ph~        ~f~    ~ph                                                                                                           ~~       ~1pt~2pbh L~                 ft ~W~                              ~ p~                                   N.-- ~~                                                                   ~                        ~i-           ~.~                                                                                                 ~                                                                                                                                                                                                                                                                                                                                                                                                              b~    ~                                                                     N                                                                                                                                                                                                                                      ~A~1p.~                 U~                                                        ~p@ E~2pF
                                                      ~~ ~~                                                                                           N~.. Api~1p- ~                                                  ~f~                                                                           -I,- -                                                              ~                Y                            L~p.             ~-~                            5 14~ ~@ ~                                       ~                                                                       ~,~ph~1p-                                              ~     ~pb                                                   ~              ~           ~                                                                                                                                                       h~~                                                                                      ~   ~~i~    ~d ~2ph~                                    P-                 ~d~pb ~pd
                                       ~                 ~                                                                                                       ~ t~"h.~                                                        ~~.                                                                                    ~1p@
                                                                   ~                                                                       ~                                                                                                                                                                                                                                                                             d. ~& ~p. .~                                                b~U~                   ~            ~p.~1pt~                                         ~                                                                                   ~d~1pdW~                     ~   ~~      ~-~                                                                     ~~~                              ~pd.         ~&~                              ~c~~p"~                                                        S- ~            ~p-                                                           W.~~~                                       D~~.~                                                                                                ~  ~6~                                                                                                                                                                                                                       ~                                                     ~                                                                                                                                                ~                                          ~

    ~0

                          InF~    ~                  In~            In~           In~                                               FOE International Meets in Malaysia
                                                                                                                                    ~pS~,~"
                                                                                                           ~                                                                                                                          p~2pV.~1pi~                                                                                                                        d~W ~.
                                                                                                                                    ~                   ~
                                                                                                                                                              ~                                                                                                                                                                                                                                                                 us.       ~~                                                                                                                                              ~
                                                                                                                                    ~_ ~ ~

                                                                                                                                    ~- ~                                                                                                                                                                                                                                            n             Horns Over Caribou
                                                                                                                                                                                                                    Locki                               ~                                                                                                                                                                                                                                                      ~g~p,d Md. H~
                          Bro~ieu                 ~.~       A. fig
                                                            ~-~                           ~p.      ~                ~1pb~ph~                          ~h~                                          ~p1. ~  e~2pj~                     ~            ~pf~~. fi-d~W~. ~F~@~2pk~Wd~p1-                    ~
                                                                                                                         ~pOE~2pC~                                                                                                                                     b~~~     Hd ~~                 ~a~p6~  ~1pg ~pW~                    ~                                                                                           A              a .a- ~.~1pa ~/                                            ~        ~2p.~p. ~                                                   ~            ~~                  ~*~2pd~                         ~. ~pp~~U~~                                                 ~                   ~~b ~p-~0 ~                                         A~2ph~.b~                                          ~                                                                                                                                             ~q ~An, -~p6~2p- ~                                                                                                                                                                                                                                                                                                                         ~pF~.~pl~                         ~E C~pd             T~S~p*~1pW ~d~2p.           ~~ ~                                                              ~                  .~pd ~.~/~pW ~    b~       U~V. U~ ~             ~pW-~                  -~2p- ~pd.~-~~              d. -~.~                                                                                                                                                                    ~'~~S-
                          ph_                                                                                                                                                                                                                                                                 ~~-~                             ~~           ~                    ~w~~p-            - ~~            ~~Cb~                                                                      -~.~.&A                                                                ~           ~ ~                     .~I ~p0          ~ &A ~(~            ~pV ~W ft                                                                                                                                                                  Z
                                                                                                                                                                                                                                                                                              ~p@ ~              ~~pF~           ~                                    ~                       ~~                                                                                                                                                                 ~4 ~             i~                                                                                       ~        d~p.~                                              ~~ ~ ~  ~u~@~         ~8~    ~        USF~@~~                                                                                                                                                                                                                                                                                    ~p.~                                                                                                                                                                                                  ~'~pi~                                                                 d. ~t:=.
                                                                                                                                                                                                                    ~-~                   ~~                      ~~ ~                                                                                                                                                                                                                    ~2pd       a                     ~2pm-~       v~@ ~                         h~                                                                                                                                                                                                                                                                                                                                      d~y
                                                                                                                                                                                                                                ~~2p-~
                                                                                                                                                                                                                    ~  _~d~        ~                                                                              SM..            ~                                                                                                                                                                                                                                                                       p~p,~            In the Shadow of the Shenandoahs                                                 ~. ~~                                                                            -~1pq                           ~~~p,            ~ C~          ~                                                                                                                                                                                                                            ~ A-, ~d                   ~~. ~W~d~     ~-~                                                                                                                                                                                                              ~                      I~ppop~  ~                                                       ~
                                                                                                                                                                                                                    ~m         ~             =~                 ~p@~~~            d~1pm~pI~                                                                                                                                                                                                  ~                                                                                                                                                                                                                         ~                                                                                        P~P~                                                                                                                                                                                                                                                                                 -~f a ~pf~b~~        Th~
                          =FOE ~~                                                                                                                                                                                                                                                                                            ~h~                                                                                                                                                                                                                ~1pm~ ~                                                                                                                                                                                                              ~A~1pk~                                     ~pV~~              b~        ~@~h           ~                                                                                                                                                           UT=~                                           ~         d~d ~         ~           -~                                                                                                                                                                                                                    ~               ~&-~                 --                   ~   ~&~f~                                                                                                                                                                                                  ~~~      -.ft ~                      At- ~ ~          ~                  ~~ ~ ~                                                                                                                                                                                                                                                              ~            -~-~1p@
                          -~L ~                                                                                                                                                                       ~pP~            A~W~                       ~1 ~                        ~               W~~                                                                                                                                                                C~~-~             ~W ~                                                      d,
                                                                                                                                                                                                                    A.. N-~1ph ~                ~~p.                 ~                    a
                                                                                                                                                                                                                                                                ~0~    ~. ~-~         ~EAh
                          ~                                                                                                                                                                                                       big h. h.      b~p.             ~~~1pp~            ~1pM~                                                                                                                                                                                                            ~                                                                                                          A. p~"~        ;=I. ~E                                                                                                                                                                               ~1pt Fp~p-~                                                                                  ~ph.U~2pdW~                 ~-k~                                                                                                                                                                                                           A~p, ~1p*~           A~pa~d o~~pt
                          .~~                                                                                                                                                                       p- ~                                                                                              h~1p- ft-
                          p~pd~ph~                                                                                                                                                       p~ph~m~pW~sh for ~1po~ ~i.                                       B~pA~
                          ~1p&~FOE -ff hd                                                       I~ ft-     ~2pE ~-~~G~                                         Th- ~1p.~-                                                       ~            ~2p-~pd~                                     --~                                                       ~~~                                                                             ~                         ~. ~                    ~                             ~A~            ~                                                                                                                                                                                  ~                                                                       ~ ~        ~~1pmp~      ~pw~C~~   ~              ~2pW ~                                                                         ~      1      ~ -a                       ~l~pd~ ~ ~            US.                                                                                                                                                                                                 ~ft ASA~           ~                                                                                                                                                                                                                                           D.,
                                                                                                           ~pq a                ~- ~                                                                 N.~.~                          v~d                           7~1p@ ~     ~p-~@~        ~p@~pp~                                                     ~p6~ ~1p- p~                                                     ~1. p-J ~1pm~@       d~~1p@~d~p@ -~1pm p~~                  ~                          ~pi   ~                    ~~~ *".I                                                                ~~m~              ~p, p~d, --~  ~pP~         d ~pLk..~~d-
                          ~                          ~                 W~       d ~I- W~DC    ~                                                                     ~                                                                 ~             D~pW~p@~                                                          A'                                                                                                       ~                                               ~-~ ~                                             ~ph
                                                                                     -~pa~4~pw ~  ~~                                                                                ~~f~               ~p.~~-                h~~        .ff.. HOF. fi~2p_                                                                                                                                                                                                      I.." ~ A -k. ~-                     I~pw~p-             -b~ ~i~ph~                        -A.                                                ~                                                                                                                                             ~~ ~                           ~ ~                  ~S              ~.
                                         ~        ~W                                                                                                                                                                                      A, ~~                                             ~_~2p.~                      A~pR- WE~~@~                                                  i~b~.                       ~~A                        ~2pb~         ~         ~           -~   ~pJ~p. ~2pd ~pb-~ch~                                                                                                                                                                                                                  ~:~                                 ~                          ~                  ~p, b~1ph~                                                                                                     a ~pd ~i~        ~~~~  C~f~p,~1p@~                                                                           ~                  ~                                                                      - ~pI~     ME. ~    ~                                                                                              - -----
                          ~                                                                   ~m~

    ~0

                             ~                        ~                                                                                                                          ~

                                                                                                                                                                                                                                                                   ~

                                                                                                                                                                                                                                                                                                                                                 -~                                                                                                                                                                                                                                                                                                                                                                                                    AN

                                                                                                                    My Gwichen g~                                                                                                                  A~C~p-~                ~       A~1p-
                                                                                                                    ~~pk~.~2pO~                                                                                                  C- Fit~, ~f~                                                                                                                             w~pr~n Water,'
                                                                                                                    ~.~1pI~.~                                                                                                       ~                                                                                                              ~~1pi~              ~2p.~p1~
                                                                                                                                                                                                                                                                   is the: end              in       sight, for large lam                           pr~          ~                                                                                                                                                           ~          ~     ~p,~                                                                                                                  ~              t~                      d~      &A ~                                              ~   ~                                                  -A~                                                 by    ~                                   ~~p- P~                     ~pV                                                                                                                                                                                                                                 mad W~             a~pb~w~a~             &tub d~         P~                               ~A~                                                                                                                                                                                                                                                                                          ~p1~ Th. A-
                                                              ""US                                                  The Cycle of the Caribou                                                                                                                                                   ~/ ~d ~-~~                                WJk~S~pt~                                                                                                                                                                                              ~ ~pb~~p& ~ ~pti~                                         ~. ~ P~                                                                                                                                                                                                                                                                                                                 ~~                      ~.~                            ~           ~~                    ~                             ~                                                                                                                                                                                                                                                                                           ~                                                               It .,.a
                                                                                                                                                                                                                                                                   ~       ~1pk- ~                        ~ ~~2p- T~
                             ~~US p~    ~p-~pd th~pd ~~                                                                                                                                              ~1pb ~                     fi~p-~ ~  ~V- ~p& - d~                     p-~h ~     ~~1pt- L-~                                                                                                                                                                                                                                               Th. U.S. ~5~-                            T~                                                                   ~m c~~t~,~~                                                                                                                                                                                                                         ~f~- ~2p1~              ~y~       ~                                                                       fi- "I-- ~T~                                                                                                                                                      ~p. US ~p. ~     ~~pC~                                                                         ~pw ~ph~                                                                                                                                                       I.- ~.~                 ~p1~P~                        ~~.~pb ~                                                                                ~                                                                                                                                                                  a~p.~               ~1p.                                                                                       ~t~.~t~                          ~pa,~        ~                                                                                                                                                                                     ~         -~                                                                                                  ~                                                                                                                                                                                                                                                                                                                                                                                               ~
                                                                         ~h~pjm-~                                                                                                                                                                --~p'.~1p- ~           ~dA ~2p=                                                                                                 ~O.~                   ~1p-.~.~                  Tb~ ~                                                                                                                                                                                          ~~                                                                                     ~                                   Ad~        b~1p. ~                                                                                                                                                                                                                                                                                                          ~~`~~                   ~pd~~            ~A ~                                                                                                                                                                        ~. ~t~H-                                                                                                           ~1pI~1pi~                    ~.~2ph ~                                                                                                                                                                                                      ~w ~ Sh-~                                                                                                                                              h~           ~ C--               ~ ~      W.~       e. A~.~                                                                                                                                           ~   ~G~                                                                                          ~pr~            ~,
                             E-~(~. ~P~             ~.~.~                                                                                                                                                               ~p@~2p.~                                                                                                                                                                                                                                                 r~      I~                                                                                                                                                                                                                                                                                                    ~                                           The Animas I~1~                                                                                                                                                                                                                                                     ~ . ~ b~
                                                                                                                                                                                                                                                                            ~2ph~                        1~pA-~              wh~ projects sink
                                                                                                                                                                                                                                                                   ~~-. d~'            R~      ~..~                                                                                                    ~ ~~~                                                                                                                ~                       A   ~1pt~pt, ~b~                             _~~~ p~     p~-~                                                                                                                                                                                                                                                      ~pV~~pW ~pt~1pi~               p-~K ~c~W                         -~mw~                                                                                                                                                                                                                                                                ~pp~h~         p~~                          ~                 ~             ~1pW.            ~1ph~                                                                                                                                                                                                                                                 ~U~ptd ~1p,            ~2p72 ~- ~                                                                                                  ~                                                                                                                                                                        P-        ~Win.                                                                             ~2p.~                                                                                                                                                                                                                                                                                                                                                  d,"
                                                                                                         ~                                                                                                                                            ~p;-~p- ~     ~1pm~       ~                                                                d~~                        ~               ~                                                                                                                                                                                       ~~-~                ~W ~ll
                                                                         I"                                                                                                                                                                                        ~ R~                 ~2p"~ ~                        ~t~ph~pt~-~               k~ph~~~                                                                                               ~                                                                                                                                                     It~pw ~q~p. ~                                  ~       ~ L ~V~Y                             - ~1p. ~.~..
                                                                                                                                                                                                                                                                                        ~w                                           ~      .~           ~pW ~    . ~ ~p.
                                                                                                                                                                                                                                                                                                                                                                     ~i- ~1pp~2p- ~pd~2p.~                                                                                                        ~                            A~                                                                                       .~                            ~1pA~1pa ~    p~2pd -~ ~~1p.-- ~1pW h~                                                                                                                                                                                                                                                                                       ~pb~pb~                 ~1p, ~ d ~                                                                                                            1,~pt~                               5                                                           ~                                   a phi.                                                                                                         ~-~                                                                ~~         ~    ~1pq~2pb~p.
                                                                                                         ~                                               ~p-~-~                                           E                                                                                                                 ~2p.~pd~                                                        ~                       ~ ~                   k~                      ~      d. .I- ~                    ~pd~- ~                                                                                Up. ~~                                      ~         I- - fit          ~, h~                                                                                            ~~~pt~=                                                                                                                                         ~@
                                                                                                                                                                Brad, ~2pv~~                                                                                                 C.~                                                      ~l                             ~                     ~s~i ~d-                                                        ~   ~pI~                               ~~. ~                                                                          ~. b~pb~p. ~                        ~            ~pb~1pW .I -
                             ~          s- ~~                              ~   p~ ~- ~                                                                                                                                                        ~ ~ph~                    ~. ~                 d.            ~-r~ Am ~                                                                                                                                                       ~                       ~                                                         ~~- ~            ~           ~A~                                                           ~p,~~ at ~h~2p,~  Dn~2p- ~                                                                                                                                                                                                 ~ ~.~                                                                                                    ~.
                                                          b~           ~pd~                                                                                    :==.a                     ~2pq~-                 ~                                                         ~               d              ~                                                 ~@ ti-                         ~pv~2pW ~pt~                                                                                                                                                                                                                                                                                                                                                       c,
                                                                                                                        =~           ~.~                                                     ~-                                            ~,~~  ~                                                                                                                                                                  A~          ~,~p~
                               At            ~pd p~,                                             ~.     f~     p~1pH~.~                          ~~                                              6~2pz~~          ~pM~                                                                                                                                                                                                                                                              ~- ~- ~d                                                                ~p=~pt~                                                                                                                                                                                                                                                 ~p-~          ~k~1pi~p-~               ~.        ~     ~1pp-~p~w~1~                                                                                                                                                                                                                                                                                                                                         ~. It~                                     ~                                                                                                                                                                                                                                                                                                                                                                                                                                   In.
                                                                                                                                                                                                                                                                   ~~, Am~~                                                                 ~.~~          ~                 ~                                                                                                                                                                                                                                                                                                                                             ~-~p6~,                           ~.~

    ~0

                                                                                                                                                                                                                                                                                                                                                                                         ~                                                                                                               ~i~ ~~         I
                                                                                                                                                                                                                                                                                                                                                                                         i~--a         A sky high ~ v~                                     Th. ~~n~  a       ~pi~p0 ~iA~a~                                                                                                                                                                                                                                                                                                                                                                                                                                                                    ~1p-~- ~ph~h. --A. did
                                                                                                                                                                                                                                                                                                                                                                                         ~ ~1p,~~~2pM~     ~                                                                                                                                                                                                                                                                                                                                                                            ~ - ~1pi~                                                            _ in -~.~l .~    -~~ab On ~6~                                                                                                                                                                                                                                                                                                                                                                               -~            ~1pi, ~g~                                          D~i, 1~~1p;~1pn~i. Th. ~-ion ~pn,
                                                                                                                                                                                                                                                                                                                                                                                         TAR _,no ~pn~p.~6 - di~p. ~i~                                  ~l~pd ~1p9~ri.~k~~                               ~                                                                                                                                                                                                                                                                                                                                                                                            ~% ~p*~n, .~                             U~C- ~            ~~                                                                                                                                                                                                                                                                                                                                                                                               line~.~- ~n~                                                       ~i~i~                                                                                                                                                                                                                                        ~                                                                                                                            ~-               ~i~ ~~pA                                                ~~                                                                                                                                                                                                                                                                                                                                                                           ~                                                                               ~,~1pn~          , 16~                  Bow W~                                                 h~1p;~~                                                                                                                                                                                                                                                                                                             7~~n ~                        din~n~&                                                     ~~- ~. ~                                        ~p~_~pv~                                                                                                                                                                                                                                                                                                                                                        ~                   ~d~- hid - ~~~q~p~pt~                                                                                    AM                                                                                                                                                                                                                                                                                 kink ~pil ~~                                                                                                                                 r~                                                           ~.~p"~                                                                                                                                          &TAIL ~n~pI~~                                                             ~ ~f~   ~pM~ ~pd~w~~                                    ~2p1,~n~                                                                                                                                                 ~                                                                                                                                                                  ~n~~                    ~                                            ~ ~nd~                                                                                                                                                                                                                                                                                                                                                                                                  T~I~nl~~                                                                                                                                                                                                                                                                                                                                                                                     in~  ~n~p, Win~n~1pn~                           _ ~_                          T~~ ~                                                                                                                                                                                                                                                                                                                                                                                ~p=~      ~                                                                                                                                                                                                  o. ~pn~                                                                                                                                             ~                                        ~                         On,, ling~1pn~h. fi~7 ~ ~1pn, ~                                                ~                                                                                                                                                                                                                                                                                                                  ~P
                                                                                                                                                                                                                                                                                                                                                                                         ~ ~                                                                                                                  ~                j~~~k
                                                                                                                                                                                                                                                  T                                                                                                                                                           ~pf~                                                                                                                                                                                                              TAR    -id~pp~                                                                                                                                                                                                                                dip bail                                                            ~                                     h~pt w~                                                                                                                                                                                                                                                                                                                                                                                                                                                                   ~                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        ~                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 ~_                  ~                                                                                                                                                                                                           in ~- ~                                                                                                                                             ~pP~                                             ~i~                               <                                                                                                                                                                                                                                                                                                                                                                               ~2p"~                                                                                                                                                                                                                                                                                                                                                                                   I~.~      ~n~pn~pV ~                                           ~                  I~l~ ~i~1p1~                                            ~ph ~                                                                                                                                                                      ED.                                                                                                                                    ~    ~                                                          A                  ~i~. ~2pA~
                                                      ~                                                                                                                                                                                    ~                                                                                                                         ban a.
                                                      ~                                                                                                                                                                                                                                                                                                                                                ~                      ~pi~ ~                                        .~                                                                                                                                               ~i~~1pd~2p.                                                                                                                                                                                                                                    ~    ~                                                                                                                                                                                                         A_~- ~. ~                                                                                                                                             d~                                                                                                ~                                            ~y ~                                                                                                                                                                                                                                                                                                             ~                                                ~pn~                                                                                                                                                                                                                                                                                                                    of ~~                                                                    p~                                         D~~                                                                                                                                          in ~1p6~p. - d~                                                                                                                                                                                                                            ~                 ~pbr~p- in
                                                                                                                                                                                                                                                                                                                                                                                                                                                  d~                  ~                                                                                                                                                                                                    -~1p@ ~                                                                                                                                                                                                                                                "~                                     ~                                                                                                                                             ~                                                                                                                                                                                                                                                          -d~1pS~-                            ~i~pk~~P
                                                      ~  ~                                                                                                                                                                                                                                                                                                                                                              ~                            ~                                                ~                                                                                                                                                                                    -A lit h~                                                                                                                                            ~                      'it                                 ~pd ~1p. in ~                                                                                                                   i      e                                                                                                                                                                                                                                                                                                               ~                            -~~ni~i~                                                                                                              ell            ~                                                                        -in,                          ~.                                                                                                                                 bi- ~   ~1pk~                                                                                           in
                                                                                                                                                                             ~;~                                                                                                                                                                                        ~                                                                                                                                                                                                         ~
                                                      ~~                                                                                                                                                 ~d ~i d-~                                                                                                                                       ~             ~~r                      a ~                 ~1pn-
                                                                                                                                                                                                                    -h_ ~~                                                                                                                                                                                                       ~_                                                              ~1pV ~.                     Th. ~ R~                                            El-~                                                                                                                                          ~J~- ~                                                                                                                                          ~          ~                                                                                                   ~pi~                                                                                                                                                                                                                            ~R ~                                                                                                                            ~@               ~ ~             "a ~-                                        --~   ~n~
                                                      N- -~                                                                                                                                         L~1pn~                                                                                                                                                                                                           =.,A            -a ~                                                                                                                                       dw Rim -1~~ ~                    ~                                                            in ~p-~                                                                     ~                                                                                                                                               ~                                                                                                                                                                                                                                                                              ~A~                                                                                                                                                                                                                                                                                                                                                                           ~~1p-pk~~                                                                                                      ~                                                                                                                                                                                                                                                                                                                                                      ~n~i~j ~pd~,~pb~                                                  hin ~pi~                                                                                                                                                                       in                                                                                                                                 ~f~d a ~~                                                                                                                      C~                                                                                                                                                                        We                                                                                                                                                                                             B.                   ~                      --~-                         = ~                                                                                                                                                                                                                                                                                                                                                                                                                                        h~                                        ~2pp~2pd ~                                                             ~                                        -~.~                                                                                                                                      ~                                                                                                                                                                                  T~                                                                                            ~1pi~           ~ 12
                                                                                                                                                                                                                                                                                                                                                                                                                                                  ~                                        ~"'~                                                                                                                                      ~                                                                                                                                                          ~~                                                                                                          ~pb~2p- ~ph
                                                      ~m~                                                                                                                                    ~d~~- I                                                                                                                                                  ~2p-~pi~2p'~*~                                                                         ~.~pi~pm~                                                                                                                                                                                                       ~, ~~n a ~                                                                                                                      ~                                                                                                                           ~v~ ~                                                 ~                                                                                                                                                   ~_~                                                                                                                                                    ~n~~                                                                                  ~                                                                                                                                                                                                                                                                                                                                                                           ~1pM~~                                                            R~ ~~~~                                         ~1pp~p6~     A k~2pd~~,                                          ~~      ~    ~         P.A.-                                                                                                                                                                in, ~~ Ph- ~                           ~                            ~-~                                                                                                                  ~       -I ~n~                                        A. ~~                                                                                                                                         ~i ~,~~                               C.~pi~                                            ~p1~~~              ~~ ~                                                                                                             ~                                                                                                                                                                                           ~                                        ~~~pSD in       ~                                                                                                TAIL                                                    ~                                                                                                                         ~pt~-~.                                   ~                         ~ld~l~= I w~                                                                                                                                                                   ~                                                                                                                                                                                                              ~ - .~                                                                                                                                                                                                                                                                                                                                                                                                                                         i~                                                                                                                                                                         in                                                                                                                                                                                                          A~                                                   ~                            gr~. Now I'm- ~a ~
                                                                                                                                  ~                                      ~                         by hih                                                                                                                                                                                    ~p=~                                                                                                                                                                                                                                                                                                                                                                                     ~pil1i~S~n~                                                                                                                                                                                                           hp                                                                                                                                                                   ON~1pl ~~d~               ~b~                                                                                                                                                                                                  ~~~   ~                                                                                                                                                    ~i~                   ~2p- ~             ~-df-~d
                                                                                                                                                                                                                                                                                                                                                                                         p~1pw~. ~                                                                                                                                      -ling ~                                                 ~~                     -~~                                                                                                  In d~p" ~                                                                                                                                                                                                                                                                ..A-
                                                      ~~p~                                                    ~~                                                                                                                                                                                                                                                                                                                                                                                                      d-- ~pn,
                                                      "I- ~pl~   ~         "~a ~~                                                    ~                 I~2p,~                                                                                                                                                                      ~                                                       - ~                                                  T~            ~               ~                        in,     ~                                      ~                                                                                                                                                          -~                                                                                 ~                                             ~2pR~                                                                                                                                     ~ph~~.~                                                                                                                                  ~~p" ~, ~n~                 d~-~                                                     ~- ~i~pi~n~~                                        L~&.                    ~                        p~p.                     ~                                                                                                                                                                                                                      in~.
                                                                                                                                                                                     --A                            ~                                                                                                                                                                ~~p~                                    ~                                                                                                                                                   ~=                                                                                                                                                               ~i~i~1pd ~                                                                ~~                                            R ~                                                         i~                ~      ~                                                                                                                                                                                                                                                                                ~pn~i                                           d~                                              ~    ~              L~                                                                                                                                                                                                                                                               ~                                                 -~                -.-A~                                                                                                                                                                                                                                                                                  ~p.~pW~                                        ~~                                                                                                                                                                                                                                                                                                                                  ~                                    ~                 ~- ~~                 ~          ~pE~. ~                                                                                                                                                                                                           ~       ~                                                       ~                                                   ~h
                                                                                                                                                                                                                                                                                                                                                                                         ~pw Wi~ ~-hic~                                                            ~                                                      ~                                                                   ~                                                                                                                                                                                                                                                                                                                                                                                                                                  ~1pi~p- ~.
                                                      ~                                                                                                                                                                                                                                                                                                                                                                                    ~pR~                                                                          ~~                                                                                         ~pn W~g~pk~           Wt- TA~~                                                                                                                                                                                                        ~i~t~pk~                                                                                                                                 ~                                                p~                                                                                                  in                  Ain-                                                                                                                                                                                                r~- ~ US. in ~                                                          On. ~                                        ~                                                                                                                                                                                                                                                                                                                                                = ~                       ~ b-- kind                                                                  d.~l~ ~                                                                                                                                               ~i~pH~                                        ~              ~~n,~                                   ~~                                         -A --A'-                      ~f~                                                                                                                                                                                                                                                Bu ~                                                                                                                                                                                                              ~p- ~a, in ~                                                                                                                                    ~n~,         ~2pT.                           like ~a~~Fin~1pi~ ~ ~n~                                                 ~h~ic                                ~~l~1pi~                                                           A-~p-~pD                                                                                                                                                     ~~1p. ~M ~                                                             ~. -.a ~M
                                                      ~ TAR b~                                                                                                                                     _~n~lld~                                                                                                                                           ~p_~n~r 'by ~pW~                                              ~n~                          ~    ~              ~                                                                                                                                           --Sa~                                             I~pl~1p- ~                                                                                                                             A.& ~pd. ~2p-I... ~                                                         ~                                                                                                                                                                         Th, ~~                                                                                                                                                                                    ~p-~~!                                                                      ~pF~                                                                                                                                                                                                                                                                                                                                                                       :~pd~     ~.~2pd. ~1 d.
                                                                                                                               ~                                                                          TA~                                                                                                                                                  F-
                                                                                                                        ~~                                                                         ~ ~, b~                                                                                                                                ~             ~                      h~                                                                                                                                                                                                                                                                                                                                                                                     ~pn~~p~                      ~1p@ 'ad ~                                                                                                                                                                                                                                                                                                                                                                                                    --~by d~                                                                                                  ~1pn~~p-                        ~                                            ~                                       ~                    C~                                                                                                                                                                                                                                                                                                          ~                      ~. ~                                        ~                                  ~pI~                                                                                                                                                                                                                                                                    ~1 h~~                                                                                                                          ~                                     ~~                                                                                                                                                                                                                                                                                                             ~                                              ~~p7~f ~n~~~1pm~                                                                                              ~                                                                                                                                         ~p.                                                                                                                            ~ ~                                         ~pn~4~                  ~ 'if ~                                                                          ~2p-~                                                                                                                                         ~A~2ph
                                                      h~pn~p-                ~1pi~c                                                                                                                 ~u~1pn! =~                                                                                                                                a. ~. ~                                            ~d~                            ~                                             ~                                                                                                                                                                                                                ~       Desert Revolution
                                                                                                      ~p- ~                                                                                                                                                                                                                                                             ~ AL. ~                                            ~ in ~w                                           ~        ~                                                                                                                                                                                                                                        -~                                                                                                                                         ~                                                ~p- ~p- ~                 d~~                               ~-~p~                                                                                 I                                                                                                                     ~~p1~                            k~i~                                                                                    ~1pb~                      be         pp~        k~                ~~                                                                                                                                                  ~pp~F~                        ~                                        ~= .~                          b~                                             ~                                                                                                                                                                                                          -WHAT TO DO, F.
                                                      ~~p, find by        Sin! A~                                                                                                                                                                                                                                                                                      ~~pp~pi~                                                                                                                                                                                                                                                                                                                                                                       _~                                          r-~                                                                                     ~~~2pd-                                                                                     ~                                                                                                                                                       .11'~pil ~- ~                       ~bi-
                                                      ~pi~0~pn~                                      -~                                                                             f. ~k~                                                                                                                                     ~i~h~~                                           ~,                                                                                                                                                        ~ ~                                                                                                                                                 ~~Ad~~t ~~-~d~                                                                                                                                                                                                                                                                                                                                                                       ~       ~p& A ~~i~                                                                           ~T
                                                      ~din                                          D,~                                                                                                                                                                                                                                                                    ~                                     ~.~p1~. I-&                      ~~n~d~                                                                      ~ A~                                                                                                                                                      ~, A. d-~                                  ~                                            ~p, f. - ~             pp~~p@ ~                                                                                                           ~p.~p_~                                                                                                                                                                                                      ~                                                                                                                                                          ~1pk-~p. p~                                        ~p"~-~       ~      A~,d ~k1~                                                                                          ~               Me
                                                      VAIL ~                                   in d~2p'h~pd                                                                                                                                                                                                                                                               ~p, D~    ~pf~                  ~                                                                  1~                                                                                                                      ~

    ~0

                                                                           ELECTION SPEC~                    The Unfinished Agenda
                            ~n~                       ~~
                            P~     ~~~pb~              ~1p1,~~ ~V-~                                               ~pF~w ~                                                                                           ~- ~~V~    ~        ~                 A.- ~~                   d~                  ~W ~p&~    ~~~                                                                                                      ~                                                  ~          ~ ~ ~                    ~2pd~2p-~                   ~.~                                                                    ~                       ~    ~            ~1pf~- ~2pj~                   Th~                0~          AM ~                                                             ~           ~          d~                  ~                                                     ~D~b~                      ~~              ~                  -~                                                     b~                                                 ~p,pd   ~-~                                                                              ~ a* ~pk~   d~pS~f~          ~2pij . ~- ~~pl~86            ~               ~W            ~                  ~~,~~d-- ~       ~p.~                         ~   ~   ~ i~.~p-~~
                            ~1p19~b-~                                                        ~d~                                            IEPA        ~p~          a          or    ~                 ~                                               . ..... ~~              ~ ~@                                            ~~-~                  -~pP~                              ~p~, ~W-~~              ~~-~              ~@ ~~                                          ~2pd~       ~ -~ ~              k. IN -.ph- -a                                I d~        ~p@        It~       ~pm 19~p0 ~                                  h~~                                         ~A. b~d                                       ~              ~pV~L~1p6~~-~~  R~~~~     ~                 h~                                                                                                              ~1p,~                  by ~C.~       ~                  ~~i~p6~~pt    ~h~                                                    N~@~                      . -.~1p@~ph, ~G~~t
                                                 ~pd~~         -~@~~               ~i~pk ~~                  ~                 ~1~ P-~-~   -~ ~pd               ~p-~pu ~                                            d~p7~W. h~      p~~ ~   ~Z~~                                              ~       ~           ~p- ~.~                      ~~               ~~pd~pk ~w P~-~U ~2p. ~ ~~^ ~m ~" ~~ ~pi-~pk p~          A- ~pd~       ~pp~1pbl~                ~p1~pj~          - A ~2p'~              d~                   ~@ ~p4~                                                                   ~                  ~ ~        ~~-~                     ~70~                    ~                             ~p~                    ~          ~2p.                                           ~              ~                        ~                                          ~                      ~1p@ b~1pW    ~-~~      ~1pL
                            ~                ~p ~p&~       V-             ~f~W~pq d. ~ ~          ~p-~M                              W. d. E~ d~A ~     ~d~- . - ~                                                                                                                                                                      ~                        ~ ~6~1pb ~                                                           -~- ~1pp~                   ~.~p-                                                                              ~.-~2pW - ~                                                                                                                            ~wh. G.~
                            ~ph~T~                                                                                            ~                 ~@~p" ~                                                                                        ~p@~                        ~m~                                                                                  ~2p-
                            ~~                         so-                                                           1. ~                    ~p-~-                                                                                       ~ ~. ~                     ~pd~p,~@~                                             oo                ~p-               -~              ~~                      ~                                                    p-~~                                                                                                                             ~I p-~w~                            a Md~                                                                 ~pd~1pl~pv
                                                                 40                                                                 - ~FOE ~                                                                                        ~            ~pi~. ~                                                                                                                  ~pd~M-
                            Sp~d d~pb~                                                         ~fi~pf~
                            ~ ~pL~-                           ~                                        ~p.. ~p-~              W,-.~pf~                                                                        ~ ~ ~~          ~- ~~           ~p'76~p'80~                   ~pi~ ~                ~@~pS, ~.~                              year                            ~2p.~                  ~pb~b~                   ~                                          ~~                       A, p- - d. ~@~                                                                           ~pw ~'~&~1~

                               pw 14

                                                                                                                                         IM
                                                                                                                                                                  IM                                                                                 pw Ij

                               HOUSE                                                                                                                                                                    i
                                          ci.i.ME                                                                                                                        S6
                                                                        141
                                                                                                                                                          IN
                               M"U.
                                                                                                                                                                                                                                                          n@

                                                                                                                                                                                                                                   c
                                          14                                          A4
                                                       'r i5l!,j  -Y
                               Afd I.W. MMA)
                                     (CA)
                               P@ (rU
                               G-W M;:
                                                                 Zi.                                liY;V                                                       Tiusjohusoo
                               r-!y W@ ICA)                                                                                                                     South Dalcoew
                                                                                                                                                                                  f
                                                                                                                                                                                                                          rw,    AN
                               L-16 CUP
                               Rkh.d SwsM Cot
                                                     M"                                                                                                                                                                  V

                               s
                               ..dw Y_ (I"                                                                                                                                              i"y                  HN                                               t
                                                                        Paw waxio                                                                                                     -Y.
                               M.,                                      0-8-
                               C." St= INN)
                               V
                                  (MM i"
                               C                                                                                                                                                                                                    sim lrl
                               Cky CROP                                                                                                                         am
                                                                                                              Gov.                                                                                            Edgii                 M,  r
                               wb- ("o),                                                                      Idaho                                                                                                                             (AM
                               FW Wink
                                           VQ
                                                I                                                                                                                                                                                  @Lll- Al.    (CA)@ -

                               l.dw.i.ipm
                               S,                                                   R    Hany Raid                                                                                                                                                MIN-        I
                                                                                                                                                                                                                  M,
                                                                                    N
                                                                                                              Am,
                                                                                                                                                            v fft;@..e
           Ul
                               I.*. Br_ (Tx) -
                                                                                                                                                                                 ig w
                               '=rtv(vV4
                                                                                                                                ilu Wirth
                               Mi6Law,IWA)
                                     (WD
                                                                                                              Rwr-w

                                                                                                                                                                                                                                  T;
                               MUS
                               E CHALEMGMS                                                                                                                                                                sw
                                                                          C4
                                                                                                                                                               M   Espy
                                                                                                                                                               bf,
                               Didsbw(c%
                               Ji.)-(LN)                                                 UP
                               p

                                                                                                                                                                                                                                 .4

                                                          .4

                                                                               Qar
                                                         :`7

                                                                                                                                                                                                   7-
                                                                                                                                                                                                                4

    ~0

                              ~                                                                                                                               N~i~1pq~0~                                                                                A~.~~                                                                                                                                                                                                                                                                                             ~w ~~                                                                                              Election ~                                                0
                              Fear f Losing on the Campaign Trail                                                                                                                                                                                                                                A Green City Ser~                                    ~P~                                                                ~                                     ~.~pC-~                                                                                          w
                                                                                                         ~                P-            ~pp-~                                                                                                                            ~ ~, ~i~%~~ I- ~1pm ~~g~~                                                                                                                                                                                                                                                                                              I a,
                                                              ~~                                                                                                                                                                                                                   wad ~                                                                                                                                                                                                                                                                                        ~pv~~b ~-~-~                                                                          ~1p.~p*~m -        -~  ~pW~            d~                                               ~k~1p&                 ~.~2pb--                          S~pb~                                                                                                      ~,~pt~0~M
                                                                                                                                                                           M~pW ~pP~                                                                                              ~p-~. ~po~p6~            ~w~                                                ...... ~pd~py D~~p-                                            ~2pq~                                                                                                ~                                                                             ~1pW ~5~                                                                                                                                                                                                                                                                               ~                            ~ ~p1~pC.~                                                                                                                                                                                                                                     e~~         ~1p- ~                          ~                                                                                                                                                                                                                                                                                       do. ~p@ ~                    -~pb~-                                                PETROCHEMICAL                     NUCLEAR ~                       S~~a~ps                                                                                                                                              ~2p-                                         ~                                                                                                                                                                                                                                                                                   d F I ~p@~                    ~~~                                PAC~              PA~                                                                                                                                                   ~a~pp~W.                       ~ ..~                                                                                                                                                                                                                                                                                            ~1pt~                                                                                                  ~1p)                7. C-~           ~                                                                                                                             ~ ~                          ~    ~                                                     ~                                                                                                  ~- b~t
                                          ~                                                                                                                                                                                                                                            -~                ~@ ~-~                                            L ~~pM                    ~pF~   ~             ~pi~. ~                                                                                    ~                                                                                 ~pN~-
                              i~~         ~~                                                                                       d~~pa~                                                                                                                                                                                                                   d~                                                                                                                                                                                                                                                                                                                                                                                   Th
                                                                                                      ~~  9~a~         $Ain                                                                                                                                                                                     b~            ~pm                                                    she oil                                                                                                                                                                                              ~=~                                                                                                                 ~~~                --A."                                                                                                                 ~p-~            ~                                                   ~2pd  ~                I& ~                                         ~pV ~                                                                                               ~=~                          ~~~                      AM ~9 ~                            ~      ~                      ~.~p0~ It. Florida P~         ~             ~p1~ph~w~                                                                                       ~p=~p. ~.,,,~-~ .. ~1p. ~m ~~                                                                                                                                                             ~p. ~~p%~                                                                                       ~~u~pc~                            ~a~                            Th. ~     ~p-~                                           ~l ~            ~                 ~pw~                                                                                                   ~    i~             ~
                                                                                                                                                                                                                                                                                                                                            ~~d~d-
                                                                                            ~                                                                 pad. ~~~                                                                                               W~ ~                      ~                                                                                                                                                                                                                                                                                                                             ~h~~                                                                                                                                                                                                                                                                                                                                       ~z
                                                              ~~        ~a~~k                 ~~ ~                 ~p.~a~p.                                                                                               A.~            p~              ~~                                                                                                                                                                                                                ~1p,~                        ~p.~a~                        ~                                    ~d~                    ban ~~&~             "I                                                                                                                                                                                 ~                 -~1pa~~                                                                                                                                                                                                                                                                                       ~pm~r
                                          ~~a~                      ~2p.~               ~~~~b~       ~.~                                                                                               ~pl~~                                   or, __a                     I~ 4~                            ~1, ~2p*                                  --~ .. I.&.                   Th. ~  b~M~                       ~                                                                                        ~pa~pV~                                                                              d~                                 ~                          ~G~                                                                                                     ~                            ~            ..... ~                                               ~d ~1pm~                                                                                                                                         ~~~            ~                                                   ~                 --~2p- ~                       ~~~~~                                                                                 ~1pad-
                              ~p&~=                                                 ~   ~                     ~         A.- b~r~      ~@~                                                                                                        ~~                ~pk~r~                                   ~pk~,~               ~                 ~p-~i~p.~                                                                                 ~=
                              ~~                                              ~-~pl~             ~t~~                             ~2p,~po-                                                                                                   ~p- ~pC~                        ~1pU ~                              ~p~ sad                ~                                  d. ~b N~pS~                                                                                                                          Th.
                                          ~      ~-                        ~-                                                                         ~~t~.                                                                                                     ~~            ~                        ~.~    House ~r~                                                           ~~ph~                    ~                                                                                                                                     ~p- G  ~                                                                                          ~                            0-                  d~                                                    ~~am kind in ~                                                                                                                             ~                ~d ~p- ~                                    ~w~              ~dgar ~1pb~6                  ~W~                                                                                   ~Al~          ~~                 ~~~a~                                                                                           ~                                                                                            #I-. WE                                                                MAW ~h~                           p~.~.~p*                           ~1pq~                                                               ~p-~                                                                                                 Ara ~b~pb
                              ~F~- ~k~                          ~p=~             ~- ~b~               A&- ~                                                                                  '-A= d
                              ~               -~                                                                                                                                                                                                                       ~~~~                                                                                                                                                                                                                                                                                   d~p=
                                          ~. h~1pf~                                                                                                                                                                                                                      ~                                                                                                                                                                                                                                                                                   ~P~b ~-~d ~                    ~ bd~1p@ ~                                                                 DIRTY D02EN TAKERS                                                                                                                                                                                                       ~ ~1pw
                              ~2p- ~                                                                                                    ~ C~    ~p5~                                                                                          ~~                                                                      ~                                                                                                                                                                                                                                                                                                                           ~1pf~2p=~~             m -to N~pW~                                                                                                                        ~p:~                                                                                                                                                    ~_ ~                   ~p-~r.
                                             ~         ~                   ~                                                                                                                                                                                                       ~                                                              -a-  ~p@
                                                                                                                              t. ~~1p-~                                                                                                                                                         ~~                                               ~  ~~                        k~     ~                      ~ oar. A-~                                                                                                                                                                           ~pb~1pY~                                                                                                                ~   (~                                         ~                                                                                                                                   ~                                      ~~~                                                                                                                                                                                                                                                                                                                             ~                                                                                                                                                                                                                                                                                           d ~h~&- -A- ~                                                          - d~p.~                                                                                                                                                                                                                                                                                                                   D~                ~-                       ~~~                    p~~M ~.                                                                       3~(R~                                 ~                                                                                        ph.- d~                                                                                                                                                                                                                                                                                                       ~                        ~ad
                                                                                                                              ~2pl~OK)                                          ~                                                                                                 ~~1pb~p-                    -~~                                                                                                                         S. ~,ki (~                                  ~                                                                                                 ~ld~                      ~,                                           h~t
                                          ~~    "~            ~                                                                                                                                                                                    ~1p= ~1p6~                  ~p"                                 ~=
                                                              ~                                                        6. ~p- ~                                    ~~                                                                                                                             of ~               ~                                                                                                                                                                                                                                                                                                                                                          ~
                                                                                                                                                                                                                                                                                                                                                  ~prb~            ~p, ~pa~                                                                         7. Ad. Sp~~                           ~                                                                                           ~1pW~                        ~W~pW~                                                                                                                     ~, 1~pW~                                   SWIM                                                                                                  ~p.~~a~d~                                                                                ~                                                                                                                                                                                             ~~                  ~~~                                  ~.
                                          ~~pd~                                      ~~       9                                                                                                                                                                  k~.~                                                                       ~                                             -~            ~WA ~            ~pQ~~p"~                                                                                                                                                                          a.- d - d~-
                                                                                                                              it. ~~                                         ~                                                                                              ~'~                    - ~d ~i~p-~                                            F~~       ~d~p~                                                                  ~                                                                                                 T- ~                                   ~l-~~v~                                                    ~                                                                                                                                                                                                                                                                                                                       ~h~~ ~                                                                              -~V ~pd                   tZ~2pC- ~                                         ~~                                                                                ~                          ~                                                                                      ~ph~p.                                                                                                                                                                                        d~                                                                            E~                                         ~p@~                                ~pI ~o ~ ~pf~                                                                                                                                                                                                                                                    ~             ~a~                                                                                                                                                                                                                                                                                                                          ~~ph~                                                                                                                                                                                                                                                                                     A~.~pt      ~                                                                                                                                                                                                                                                                                              ~                            p~     ~                   .~ ~                                                                                                                                                                          d-               ~,
                                          ~pi~p-                                    R                                                                                                                                                                                                    ~~                              ~ ~     p~                                                                                     ~. ~          ~p% ~                                                                                                                                                   ~-~                                                                                                                L
                                                                                                                                                                                                                                                                                                 ~                                                                                                                                                                                                                                                                                             ~pe~

    ~0

                                                                                                                                                                                                                                                                                                                                                                                                           ~q
                                                                                                                                                                                                                                                                                                         LE~                                                                                                                                                                                                                                  ~-.                                  ad ~p. ~pi~                                        ~~pi- ~d ~~                                                                                                                                                                                                                                                                             W~pL~                                               ~ ~f ~                                                                                                                                                                                                                                                                                ~ ~2p.                                                 ~~- ~                                                                                                                                                                                                                                    ~               ~~~                                                              ~p- ~- d~                                                B~                                                                         -                                                                                    ~                       ~    ~1p.~p. a                                                                      ~p.~~                                                                                                                                                                                                                                ~M~                     d~.~d -I.- fi~                                              ~w~ ~h~                                                                                                                                                                                                                                                                        ~m~p.~p-                                              .~~p6~
                                                                                                                                                                                                                                              ~p-~ ad.                                     OD~ ~                       ~p,~d. ~p,- ~~                                                                                                                                                                                                                                                                                                                                                  Pa- ~                                                                                                                                                                                                                                              ~1p-~pb~                                                                ~                      ~.~                      The Nemesis                                          ~                                                                                    a-         ~                                                                                 A.
                                                                                                                                                                                           ~                                                                  ~2p=~            ~1 A-                d. ~      d~                                                                                                                                                                                                                                    ~r ~p.. ~                                Affair                           ~                                                                                      E- ft d.~                                                                -0~                A~~                                        ~                                                                  ~                                                                                                                                                                                                                                                                        ~p.~p, ~2p1~ P.A*, ~                    By ~~                           ~             ~2p-~@ ~1p%~    d, ad= I ~pA                                                                                                                                                                                  ~pl ~
                                                                                                                                                                                                                                                                                                                                                            ~6 ~                                                                                                                                                                                                                                                                                                                                                                                                   ~                                                                                                                                                                                                                                                                                                                                                                ~                                                                                                                                                       ~pd~           ~                                                                                                                                                         ~    ~                                                                                                                                                ~pi a, ~h~pf~                                                                                          ~-                                                            ~                                                                                                                                                                                                                                                                                                                                                       ~~2p1. If- If. O~,~                                                                                                                                                                                                                                                                        T~                                                          ~      ~V ~p-~                                                              d~R~1pa~pW~p%~pa~pd~                                                                                      ~-~                                                                                       - - -- ~j~~ "If ~@ ~pM ~                                                                        ~.% ~          ~-~ib a ~~S~    by ~ ~. ~                                  ~                                        ~                                                          -h~b~                ~                                                                                ~       ~          - q~-i~.~1p@                                                                 = - ~~ ~            ~p-~i~                              ~          ~p= pp~2p- ~                                                                                    ~                     -~W~   ~                   ~                                                                                                                 ~                          ~&-~               ~                                                                     ~p.                                                          ~                             ~                                     ~i~                  d~= im                                                     ~ ~ P-      ~~                                                                                                        ~                  d. ~                                                                  ~bk                                                                       ~Z ~pw                                                                      ~p-~&                                                                                                    ~                                                                          ~           ~pn~1pf~                   ~d ~           A-                                                                                                                                                               ~          p~p,~                                                                                               ..~ a ~k~            ~               ~                                                                                                                                                ~6 ~                                                                                                             App~~~        R~-~               ~                                                                                 ~~@ ~~E~                          ~- ~p6~
                                                                                                                 ~pF~1pP~~                                     ~                                                                                       ~    ~p'~p7~                    ~p, ~- &a.& ~  ~                                                                      ~ I-                             hub ~t~ ~                 ~p.                                                                                                                                        -ft _ ~                               ~b- ~                     ~                                                               ~         e.        o.        ~~                   d~             ~                                                                                                                                                                                                                                                                                                                                                                                           ~                                                                        ~@~p.                             ~w ~                                                                                                                                                  ~ ~    ~1pF~2p1. ~                         ~                                                                                                                                                                                                                                                             ~            ~      ~                     ~, P- Wi~             0~p-~"                    ~-~ ~~                                                                                                                                 a.- ~p6~p. ~                                 ~            ~p-~                                                                       ~ ~          ~ i~                                                                                                                                              h~p- . d~~d ~                                                                                                                                                                                                                                                                                                                                                                                 ~
                                                                                                                                                                                                                                                                                                                                                                                                ~~                      ~1pW..~@                             ~-~1p-                       ~.~~          New                   N~y                                                                                                   ~;~                                        ~ ~r~-~                                                                                                                                                                                                                                                                        ~ a                      ~                          ~6~p& ~     ~                          ~                                                                                                                                                                                                                                             d-~                                               ~                                                                      ~2pd~               ~2pd~pA                       ~~                                                                    ~~                                      ~pb a                                                                                                                                                                                                                       ~                                                                       ~4~                                               ~                                                                                                                                      ~~~~A                                             ~ ~f ~              ~~                 d~ ~p-~~1p. ~pd~   ~pk                    ~                                                                                                                                                                 ~p" ~ I ~                 ~~U~                    ~p@~pA ~~~                              ~        b~2pd.                                                                                                      ~2p1~1pW-                                     ~1ppA~
                                                                                                                       ~         ~  ~    ~ ~ ~                                                                                                                                                                       Classifieds
                                                                                                       ~                     ~         ~2p6~   ~ph~                   ~1  ~                                            N~                                                       ~I~1p-                                                                                            ~
                                                                                                                                                                 ~- ~                                                                                                    ~~                  h                                                                                                                                                                                                                                                                                       ~                    ~-
                               ~~                                                            ~                                                    ~&~                                                                                            ~.~   ~                       I~pI~h~                                                                                                                      ~ ~                                                                                                                                                                                                           A.                   = ~~                  N~    ~~                                         ~~~~                                                                                                                                         d. ~. ~1pW~                      ~~                         ft ~2ph~p. fi~          Agricide: The                        ~                                     ~                                                                                                           ~H~~                                               ~~~.
                               5~p@~                                                                                 ~k~                                                                                                                                ~r~@ ~ ~~                                ~~                                                                                                                                                                                                                                                                                                  ~ ~q~                      p- ~w ~pl~              ~       ~. ~   Hidden Crisis                        ~                                        ~P~                                                                                                              ~~ hh ~                    ~U At~             ~', h~                                                              ~-~1pM~    ~S~                                                                                                               ~~m           ~- I~                   I.- ~p=~                     ~1p-                     ~hat Affects Us                                                               w~ ~                                                                                                           - ~~
                                     ~                                                                       ~6 ~           ~1pw~- 1"                                                                                                                  ~                                                          ~p@
                                                                                                                       ~                                                                                                                                        0~                                                                  A~                                                       ~           ~.~                                                                                      ~1pM ~                                             -~                                                                                                                                               a ~   ~. ~                                                                                                                                                       ~-I-
                                           ~ ~                 ~d ~                                                     p~             ~~                                                                                                                   ~-~                                                                                                                                           ~        ~~.~                                                                                       d~m ~                                                                                                                                                                                                                                                                                                                                                       d, ~                                                                                                        a ~M~                d.. ~ b~                                                                                                                                                          H- ~                                                                                                        ~        ~ ~  ~&~pi~                                                                                                                                   ~~                 ~A.                                                                                                ~p@ ~O~                                      ~ ~2pd Th~                                                                                                                                        ~                                                                                                                           ft- e. b~                                      ~v~                                                                                                                                                                                                                                                                                                ~~                                     ~p.~- ~~                                                                                                                                                                                                                                                                                                       H.~                              ~                                                                                                           Where There's a                     Will                                                                                                                                 7~~I,                                                  p~~                                                                                                                                                                                                                                                                                          ~pk.~                                ~4 -~                                                                                                   ~2p- ~                  ~                   ~                                                                                                       ~                A~~~~@~                                                                                              ~         -A-- ~
                                                                                                                                                                                                                                                                                          ~py ~p',             2~                   ~-p-~m

                                                                            ~D-~~           d-~     ~         ~d~     a -A~                 ~~~                           0                                    ~p.                                         ~&         ~p~                                                              ~~                                                              ~&~                                                                                             )~b
                                     ~~                                                                                                                                            ~~                         ~~~          ~z~                                                    ~                                                                                                                                                                                                                                                                     ~

    ~0

                                                                                                 ~8~6~~~qA

                                   Friends. ~.                                                              N~. o~t                                       E~t ~~M S2
                                                                                                         Man                 T~b~e~-N~ew~u~nag~a~z~i~r~wof
                                                                                                          Apart             Friends of t~qhe Earth

                                                                                                                                          ~qt

                                                                                                                                                           ~4~~q1
                                  .~8qA~0qM~8qk

                                                     F~r~k~r~qA of the Ear&
                                  ~T~l~wu~m~n~d~s ~c~vf~con~c~qm~w~d p~qwp~k, wound the ~s~u~q& Care ~tD
                                      m p a a m~,~*~v ~f~w ~S2~5. My ~Sp~M~W D~O~U~St~j~W
                                 -A      ~m    ~M~' ~A~@ A~p~@. ~b~,
                                          ~d POE               ~q-
                                  Sp~W ~d~q@ m ~w~b~m~d ~F~bmd~, o~F ~d,     ~0~3~2~3 ~o~qm ~o~s~m ~o~d~-~S
                               N E~-~ft~h but                                                                             FA~0qONG I~qM ~qFUT~4qM:
                                                                                                           ~qCAN ~FARM~qM ~qMFORD ~F~0qME~q&~q@~.~L WAT~qM
                                ~S~q-          ~z~i~p~c~k~q- ~6qZ~-                   ~L~- Zip ~C~.~q@                           GREEN ~c~r~qm                    ~I~D~I~qM C~3~U~b~UNA~LS
                                S~-~d CA~p~-  S- A~pp.~L ~F~d.~6 ~.~0 ~6. ~E~@~& ~5~30 7~,~b ~k ~&~E~- ~V~.~*~A~W~- ~DC. ~qM~6.
                                                 Aim
                                                 ~8qq~0qw

                                  ~~4qW~-

    				Yukon
                            Government        News Release......                                                                                    - 2 -

                             FOR RELEASE                                                                                                            Further to these initiatives, the federal government hopes to
                             January 6, 1987  #005                                                                                             present its position on the issue to the U.S. Department of the
                                                                                                                                               Interior at a meeting in Ottawa on January 23.  The Yukon governmennt
                             CONCERNS RAISED ABOUT PROPOSED ALASXAN OIL AND GAS EXPLORATION                                                    will also be represented at that meeting," the minister said.
                                                                                                                                                    Porter told the legislature that it was ironic and disturbing
                                  WHITEHORSE - Renewable Resources Minister Dave Porter ann-                                                   that the U. S. government was proposing to reduce protection for the
                             ounced today that the Yukon government is increasing its efforts to                                               wildlife in the Arctic coastal plain after years or urging Canada
                             persuade the United States Department of the Interior to not allow                                                to do a better job of protecting resources on its side of the
                             oil and gas exploration and development in the Artic National                                                     border.
                             Wildlife Refuge in Alaska.                                                                                             "It is even more disturbing that they would write an impact
                                  Porter told the Yukon Legislative Assembly today that present-                                               statement which only makes passing references to the effects in
                             ations are being made to implement a unanimous motion of the                                                      Canada. when, in fact, several important subsistence species are
                             legislature that was passed in December in opposition to the U.S.                                                 involved and most of the negative socio-economics effects would be
                             proposals.                                                                                                        experienced in Canada generally and by Old Crow in particular.
                                  Concern has been expressed an both sides of the Yukon/Alaska                                                      "The Yukon government is deeply concernced about moves toward
                             border that the proposal will have serious consequences on the                                                    oil and gas drilling in Alaska that could have unfortunate and
                             future of the Porcupine caribou hard which uses the proposed region                                               unnecessary long term effects on the ability of the Old Crow people
                             as its calving grounds.                                                                                           to harvest the Porcupine caribou herd as they have traditionally
                                  The renewable resources minister told the legislature that an                                                harvested the herd for generations," the minister said.
                             official from his department had made a presentation yesterday to a
                             hearing in Anchorage, Alaska and bad pointed out a number of                                                                                      - 30 -
                             serious emissions in the draft environmental impact statement.
                                  A presentation was also made by the Council for Yukon                                                        Dennis Senger				Government of Yukon
                             Indians and additional interventions are being made tonight in the                                                Public Affairs Bureau              Box 2703
                             village of Kaktovik, Alaska by the Porcupina Caribou Management                                                   (403) 667-5431                     Whitehorse, Yukon, Y1A 2CS
                             Board and the band council of Old Crow," Porter said.
                                  "On Friday of this week my deputy minister and a represent-
                             ative from the Executive Council Office will make a further inter-
                             vention in Washington, D.C.

                                                                                      ...../2

                                                                                                                                                                                                                  { 2 }

                                                                                                                                                                                          A PRESENTATION WAS ALSO MADE BY THE COUNCIL FOR YUKON INDIANS AND
                                                                                                                                                                                          ADDITIONAL INTERVENTIONS ARE BEING MADE TONIGHT IN THE VILLAGE OF
                                                                    MINISTERIAL STATEMENT                                                                                                 KATOVIK, ALASKA BY THE PORCUPINE CARIBOU MANAGEMENT BOARD AND THE
                                                                                                                                                                                          BAND COUNCIL OF OLD CROW.  ON FRIDAY OF THIS WEEK MY DEPUTY
                                                                                                                                                                                          MINISTER AND A REPRESENTATIVE FROM THE EXECUTIVE COUNCIL OFFICE
                                          DATE:         06 JANUARY 1987                                                                                                                   WILL MAKE A FURTHER INTERVENTION IN WASHINGTON, D.C.  FURTHER TO
                                                                                                                                                                                          THESE INTIATIVES, THE FEDERAL GOVERNMENT HOPES TO PRESENT ITS
                                          BY:           HONOURABLE DAVID P. PORTER                                                                                                        POSITION ON THE ISSUE TO THE U.S. DEPARTMENT OF INTERIOR AT A
                                                                                                                                                                                          MEETING IN OTTAWA ON JANUARY 23.  THE YUKON GOVERNMENT WILL ALSO
                                          RE:           YUKON GOVERNMENT PRESENTATIONS TO  U.S.                                                                                           BE REPRESENTED AT THAT MEETING.
                                                        DEPARTMENT OF INTERIOR HEARINGS ON THE
                                                        FUTURE OF THE ARCTIC NATIONAL WILDLIFE                                                                                            MR. SPEAKER, IT IS A LITTLE IRONIC AND VERY DISTURBING THAT THE
                                                        REFUGE, COASTAL PLAIN                                                                                                             U.S. GOVERNMENT IS PROPOSING TO REDUCE PROTECTION FOR THE WILDLIFE
                                                                                                                                                                                          OF THE ARCTIC COASTAL PLAIN, AFTER YEARS OF URGING CANADA TO DO A
                                                                                                                                                                                          BETTER JOB OF PROTECTING RESOURCES 0N OUR SITE OF THE BORDER.  NOW
                                          MR. SPEAKER, I AM PLEASED TO ANNOUNCE TODAY THAT I HAVE TAKEN                                                                                   WE HAVE A NATIONAL PARK AND SPECIAL MANAGEMENT MECHANISMS IN PLACE
                                          STEPS TO ENSURE THAT THE YUKON GOVERNMENT, AS WELL AS SEVERAL                                                                                   AND HAVE IN EFFECT CAUGHT UP WITH THE U.S.; THEY SEEM TO BE HEADED
                                          MAJOR INTEREST GROUPS, ARE MAKING COMPREHENSIVE PRESENTATIONS TO                                                                                IN THE OPPOSITE DIRECTION.
                                          THE UNITED STATES GOVERNMENT, OPPOSING THEIR PROPOSAL TO OPEN UP
                                          THE HEART OF THE PORCUPINE CARIBOU HERD CALVING GROUNDS TO OIL AND                                                                              IT IS EVEN MOPE DISTURBING THAT THEY WOULD WRITE AN IMPACT
                                          GAS DEVELOPMENT IN ALASKA.  THESE PRESENTATIONS REPRESENT THE                                                                                   STATEMENT WHICH ONLY MAKES PASSING REFERENCE TO THE EFFECTS IN
                                          ACTIONS WE ARE TAKING TO IMPLEMENT THE UNANIMOUS MOTION OF THIS                                                                                 CANADA, WHEN, IN FACT, SEVERAL IMPORTANT SUBSISTENCE SPECIES ARE
                                          HOUSE SEVERAL WEEKS AGO.                                                                                                                        INVOLVED AND MOST OF THE NEGATIVE SOCIO-ECONOMIC EFFECTS WOULD BE
                                                                                                                                                                                          EXPERIENCED IN CANADA GENERALLY, AND BY OLD CROW IN PARTICULAR.
                                          YESTERDAY IN ANCHORAGE, OFFICIALS OF THE DEPARTMENT OF RENEWABLE                                                                                THE YUKON GOVERNMENT IS DEEPLY CONCERNED ABOUT MOVES TOWARD OIL
                                          RESOURCES SPOKE TO A NUMBER OF VERY SERIOUS OMISSIONS IN THE DRAFT                                                                              AND GAS DRILLING IN ALASKA THAT COULD HAVE UNFORTUNATE AND
                                          ENVIRONMENTAL IMPACT STATEMENT.  THE DEPARTMENT OF INTERIOR IS                                                                                  UNNECESSARY LONG TERM EFFECTS ON THE ABILITY OF THE OLD CROW
                                          PROPOSING TO OPEN UP A VAST AREA ON THE NORTHERN SIDE OF THE                                                                                    PEOPLE TO HARVEST THE PORCUPINE CARIBOU HERD AS THEY HAVE
                                          ARCTIC NATIONAL WILDLIFE REFUGE TO OIL AND GAS LEASES: WITHOUT                                                                                  TRADITIONALLY HARVESTED THE HERD FOR GENERATIONS.
                                          FIRST CONSULTING CANADA; WITHOUT CONSIDERING THE TRANSECONDARY
                                          EFFECTS ON CANADA; AND WITHOUT LOOKING AT THE TOTAL CUMULATIVE                                                                                  IN LIGHT OF THESE CIRCUMSTANCES WE HAVE INSTRUCTED OUR OFFICIALS
                                          EFFECTS OF ALL THE DEVELOPMENTS ON THE CARIBOU, POLAR BEARS, SNOW                                                                               TO MAKE VERY STRONG STATEMENTS ON BEHALF OF OUR GOVERNMENT AND IN
                                          GEESE AND MUSK OXEN.                                                                                                                            THE INTERESTS OF THE PEOPLE OF OLD CROW AND THE PEOPLE OF THE
                                                                                                                                                                                          YUKON AND THE NORTH.  COPIES OF THE STATEMENT MADE IN ANCHORAGE
                                                                                                                                                                                          ARE AVAILABLE FOR YOUR REVIEW.

                                                                                                                                                              GOVERNMENT OF THE YUKON PRESENTATION To
                                                       STATEMENT BY THE                                                                                 THE DEPARTMENT OF INTERIOR DRAFT ANWR EIS HEARINGS
                                                                                                                                                                    (WASHINGTON, JANUARY 9, 1987)
                                              GOVERNMENT OF THE YUKON TERRITORY
                                                                                                                                                MR. CHAIRMAN, PANEL MEMBERS, DISTINGUISHED OBSERVERS, LADIES AND
                                                                                                                                                GENTLEMEN:

                                                                                                                                                MY NAME IS WILLIAM J. KLASSEN.      I AM THE DEPUTY MINISTER OF THE
                                                                                                                                                DEPARTMENT OF RENEWABLE RESOURCES FOR THE GOVERNMENT OF THE
                                                      IN RESPONSE TO  THE                                                                       YUKON.    OUR  DEPARTMENT    HAS  THE   PRIMARY   RESPONSIBILITY    FOR
                                                 DEPARTMENT OF THE INTERIOR                                                                     MANAGEMENT OF THE PORCUPINE CARIBOU HERD WHEN IT IS PRESENT          ON
                                       DRAFT ARCTIC NATIONAL WILDLIFE REFUGE, ALASKA,                                                           THE CANADIAN SIDE OF THE ALASKA/YUKON BORDER.
                                              COASTAL PLAIN RESOURCE ASSESSMENT
                                                                                                                                                WITH ME TODAY IS MR, WILLIAM OPPEN, THE DIRECTOR OF                 THE
                                                                                                                                                INTERGOVERNMENTAL RELATIONS BRANCH OF THE YUKON GOVERNMENT'S
                                                                                                                                                EXECUTIVE    COUNCIL    OFFICE.    MR.    OPPEN   HAS    THE    PRIMARY
                                                                                                                                                RESPONSIBILITY FQR LIAISON BETWEEN OUR GOVERNMENT AND OTHERS.

                                                       WASHINGTON, D.C.                                                                         WE WOULD LIKE TO BEGIN OUR REMARKS TODAY BY THANKING YOU FOR THE
                                                       JANUARY 9, 1987                                                                          OPPORTUNITY TO MAKE THIS PRESENTATION.        THE RESOURCES OUR TWO
                                                                                                                                                COUNTRIES SHARE ALONG THE ALASKA/YUKON BORDER ARE CRITICALLY
                                                                                                                                                IMPORTANT TO THE PEOPLES (IF 114E YUKON $0 WE ARE TRULY T4A%YFUL
                                                                                                                                                FOR THE PRIVILEGE OF RFPRFSFNTING OUR INTERESTS IN THESE MATTERS;

                                                                                                                                                IN THE TWO PREVIOUS HEARIf!GS TH:S WCEK IN KAKTOVIIX AND AnHORAGE,
                                                                                                                                                THE DEPARTMENT OF THE INTERIOR HAS HEARD PRESENTATIONS BY
                                                                                                                                                PROFESSIONAL STAFF OF OUR DEPARTMENT, FROM THE PEOPLE AND ELDZ'3S
                                                                                                                                                OF THE COMMUNITY OF OLD CROW, FROM OUR PORCUPINE CARIBOU
                                                                                                                                                MANAGEMENT BOARD, AND F.@J.-. THE COUNCIL FOR YUKON INDIANS.         As.
                                                                                                                                                WELL, TODAY, WE ARE TABLING A TECHNICAL ANALYSIS OF THE DRAFT
                                                                                                                                                EIS.

                                                                                                                                                WE ARE HERE 70DAY To REPEAT AND REINFORCE THE CO,11PLFMEq7Al','
                                                                                                                                                MESSAGES IN THESE DIFFERENT PRESENTATIONS - AND TO URGE YOU TO
                                                                                                                                                RECONSIDER THE RECOMMENDATIONS FOR FULL DEVELOPMEAT CONTAIAED IN
                                                                                                                                                THE DRAFT EIS.      IdE SINCERELY BELIEVE THAT CrITICAL WILDLIFS
                                                                                                                                                HABITATS AND RESOURCES ON THE     ALASKAN AND CANADIAN NORTH SLOP_
                                  PRESENTED BY:                                                                                                 SHOULD BE STRONGLY PROTECTED,     AND THAT THE NORTH SLOPE ITSELF
                                                                                                                                                SHOULDVIE MA:AGID ACCORDING    TO CONSERVATION-ORIENTED OBJECTIVES,
                                  .I.J. KLASSEN, DEPUTY MINISTER,                                                                               ANY DE  EL.PH NT IN THIS REGION SHOULD BE PERMITTED ONLY IF IT
                                        DEPARTMENT OF RENEWABLE   RESOURCES                                                                     WOULD   NOT  CONFLICT   WITH    THE CONSERVATION    OF  THE   WILDLIFZ
                                  W. OPPEN, DIRECTOR, INTERGOVERNMENTAL RELATIONS BRANCH                                                        RESOURCES.
                                        EXECUTIVE COUNCIL OFFICE
                                                                                                                                                WE FURTHER BELIEVE THAT REASONS FOR PROTECTING THE 1002 LANDS ARE
                                                                                                                                                FAR MORE COMPELLING THAN THE OFTEN LIMITED TECHNICAL REASONS

                                                                                                                                                                                  2

                               FORWARDED IN THE REPORT.      ALTHOUGH THE DRAFT EIS DOES IDENTIFY                                                     INTERNATIONAL SIGNIFICANCE OF WATERFOWL HABITATS SUCH AS THE
                               THE TRADEOFFS WHICH WOULD BE REQUIRED TO ALLOW FULL DEVELOPMENT                                                        ARCTIC NATIONAL WILDLIFE REFUGE NORTH SLOPE,         WITH REFERENCE TO
                               IN THE 1002 LANDS, IT DOES NOT ADEQUATELY ADDRESS THE TANGIBLE                                                         THE NORTH AMERICAN WATERFOWL MANAGEMENT PLAN, WHICH HAS THE GOAL
                               REALITY THAT THE MOST HEAVILY IMPACTED SPECIES ARE TRANSBOUNDARY                                                       OF PROTECTING AN ADDITIONAL FIVE MILLION ACRES OF HABITAT BY THE
                               RESOURCES OF CONSIDERABLE INTERNATIONAL SIGNIFICANCE.                                                                  YEAR 2000, ASSISTANT SECRETARY HORN STATED THAT "THE PLAN GOES
                                                                                                                                                      AFTER HABITAT ACQUISITION SO THAT WE CAN START TO BUILD HABITAT
                               WITH RESPECT TO THE PORCUPINE CARIBOU HERD, FOR EXAMPLE, A MAJOR                                                       BACK  UP,   ONE OF    THE  CRITICAL   ELEMENTS    IN HELPING    PUT OUR
                               IMPACT IS IDENTIFIED DUE To THE ENCROACHMENT OF DEVELOPMENT INTO                                                       WATERFOWL POPULATIONS BACK TOWARD THE 100 MILLION LEVEL,              THE
                               THE HEART OF THE CALVING GROUNDS.      THE EIS SUGGESTS THAT SUCH AM                                                   OBJECTIVE   NOW IS TO GET THE FINGER IN THE DIKE AND STOP THE
                               ENCROACHMENT COULD LEAD TO A 20-40% REDUCTION IN THE SIZE OF THE                                                       LEAKING".     IN   OUR  OPINION,   PROTECTING    THE   ARCTIC    NATIONAL
                               CARIBOU HERD.    FOR THAT REASON ALONE, WE BELIEVE THAT ANY SUCH                                                       WILDLIFE REFUGE COASTAL PLAIN WOULD DO MUCH TO ACHIEVE THIS.
                               IMPACT SHOULD BE CONSIDERED ENTIRELY UNACCEPTABLE.         HOWEVER, WE
                               FURTHER BELIEVE THAT THE DRAFT EIS CONSIDERABLY UNDERESTIMATES                                                         SIMILARLY, POLAR BEARS PRESENT IN THE AREA ARE PART OF A LARGER
                               THE  SIGNIFICANCE     OF A   REDUCTION   OF  THAT   MAGNITUDE   TO   THE                                               REGIONAL    POPULATION    THAT   SHOULD    BE   ASSESSED   IN   A    MORE
                               SUBSISTENCE USERS OF     THE HERD, WHO ARE PRIMARILY LOCATED IN                                                        COMPREHENSIVE MANNER THAN THAT PROVIDED IN THE DRAFT       EIS,
                               COMMUNITIES IN CANADA    INCLUDING OLD CROW IN THE YUKON AND FORT
                               MCPHERsoN, ARCTic RED    RIVER, AKLAVIK, INUVIK AND TUKTOYAKTUX IN                                                     CARIBOU, POLAR BEAR, WATERFOWL AND OTHER MIGRATORY SPECIES PLAY A
                               THE  NORTHWEST    TERRITORIES.     BY  IGNORING    SUCH   TRANSBOUNDARY                                                CRUCIAL ROLE IN THE SUBSISTENCE ECONOMIES OF THE LARGELY rIATIVE
                               EFFECTS THE DRAFT EIS IS FUNDAMENTALLY FLAWED.                                                                         COMMUNITIES IN THE YUKON AND IN THE NORTHWESTERN CORNER OFF THE
                                                                                                                                                      NORTHWEST TERRITORIES.     IN RECENT YEARS WE HAVE BEGUN TO BETTER
                               WE ALSO MUST VOICE OUR CONSIDERABLE DISAGREEMENT WITH THE WRITERS                                                      MANAGE THESE SPECIES. BOTH FOR THEIR OWN SAKE AND TO ENSURE THAT
                               07 THE EXECUTIVE SUMMAAY WHO SUGGEST THAT DEVELOPMENTS ON THE                                                          THE SUBSISTENCE ECONOMY IS SUPPORTED IN A MANNER WHIC4 CAN BE
                               CARIBOU CALVING GROUNDS CAN BE UNDERTAKEN WITH NO NET LGSS OF                                                          SUSTAINABLE INTO THE FUTURE,       THESE MEASURES HAVE INCLUDED THE
                               HA al TAT QUALITY.  SUCH A STATEMENT CONTRADICTS THE 14AIN BCOY OF                                                     ESTABLISHMENT OF THE NORTH YUKON NATIONAL PARK AND HERSCHEL
                               THE DRAFf EIS AND WE BELIEVE SUCH AU ACHIEVEMENT             IS LIKELY                                                 ISLAM;) TERRITORIAL PARK AND THE SETTLEHENT OF THE INUVIALUIT LAND
                               IMPOSSIBLE,                                                                                                            CLAIM, WHICH ESTABLISHES A CONSERVATION-ORIENTED REGIME FOR
                                                                                                                                                      MANAGEMENT OF      THE  YUKON's   NORTH SLOPE.      IN   ADDITION,    THE
                               WE   HAVE    SIMILAR    CONCERNS   ABOUT    THE    OTHER    SIGNIFICANT                                                GOVERNMENTS OF CANADA, THE NORTHWEST TERRITORIES AND THE YUKON
                               TRANSBOUNDARY SPECIES,                                                                                                 GOT TOGETHLK WITH NATIVE INTERESTS TO CREATE AM IN-CANADA
                                                                                                                                                      AGREEMENT ON MANAGEMENT OF THE PORCUPINE CARIBOU HERD.               THIS
                               THE MUSKOXEN PRESENT'IN ALASKA ARE SLOWLY REPOPULATING THE ARCTIC                                                      AGREEMENT HAS BEEN IMPLEMENTED THROUGH THE PORCUPINE CARIBOU
                               NATIONAL WILDLIFE REFUGE AREA AS WELL AS THE NORTHERN YUKON,                                                           MANAGEMENT BOARD.     IT is WORTH POINTING OUT THAT THE STIMULUS FOR
                               WHERE THEY WERE EXTIRPATED DURING THE LAST CENTURY.          THIS IS A                                                 MANY OF THESE MEASURES WAS THE CREATION OF THE ARCTIC NATIONAL
                               VALUABLE AND IMPORTANT OCCURENCE WHICH SHOULD BE PERMITTED TO                                                          WILDLIFE REFUGE IN 1980, AND OTHER CONSERVATION MEASURES ENACTED
                               .CONTINUE,                                                                                                             IN ALASKA.

                               THE MIGRATORY SNOW GEESE POPULATIONS, WHICH USE THE IC02 LANDS AS                                                      THESE LAND ALLOCATIONS AND MANAGEMENT STRUCTURES HAVE BEEN PUT 1.4
                               AN IMPORTANT STAGING AREA, ARE ALSO UNDER CONSIDERABLE THREAT                                                          PLACE TO PROTECT HABITAT FOR PORCUPINE CARIBOU AND OTHER SPECIES,
                               FRO14 THE   PROPOSED    DEVELOPMENTS,   AM D THERE   IS   VERY   LITTLE                                                AND TO ENSURE AN APPROPRIATE,         SUSTAINABLE ALLOCATION OF THE
                               ACKNOWLEDGEMENT OF THE INTERNATIONAL IMPORTANCE OF THE SPECIES.                                                        HARVEST   IN THE REGION,      THEY ARE AM ACKNOWLEDGEMENT OF THE
                                                                                                                                                      DEPENDENCE OF THE PEOPLE OF OLD CROW ON THE HARVEST OF THE
                               HOWEVER,  WE   DO   NOTE  THAT   THE   DEPARTMENT   OF   THE   INTERIOR                                                PORCUPINE CARIBOU HERD AND    AN ACKNOWLEDGEMENT OF THE CONSIDERABLE
                               RECOGNIZES THE IMPORTANCE OF WATERFOWL HABITATS,         WE WERE VERY                                                  IMPORTANCE OF THE HERD, GENERALLY, TO THE PEOPLE OF THE YUKON,
                               ENCOURAGED TO READ IN A RECENT ISSUE OF THE DUCKS UNLIMITED                                                            THE NORTHWEST TERRITORIES AND CANADA.        IN ADDITION, T14EY ARE AM
                               JOURNAL THAT ASSISTANT SECRETARY HORN IS WELL APPRISED OF THE

                                                                 3                                                                                                                       4

                              INDICATION   OF    OUR  GOVERNMENT'S     STRONG  COMMITMENT    TO    THE                                              THE CUMULATIVE EFFECTS OF SEVERAL DEVELOPMENTS COULD ONLY BE
                              IMPLEMENTATION  OF THE WORLD CONSERVATION STRATEGY.                                                                   DEALT WITH THROUGH JOINT PLANNING WITH ALL RESOURCE USERS ON BOTH
                              MR.  CHAIRMAN,     NONE OF   THESE    VERY SIGNIFICANT    FACTORS    ARE                                              SIDES  OF THE BORDER.    THIS RAISES THE ISSUE OF CONSULTATION WITH
                              IDENTIFIED   IN    A   MEANINGFUL' WAY   IN  THE   DRAFT   EIS,   WHICH                                               OUR   GOVERNMENT   AND OTHER     CANADIAN    JURISDICTIONS.     ALTHOUGH
                                                                                                                                                    REQUIRED UNDER SECTION 1005 OF THE ALASKA NATIONAL INTEREST LANDS
                              NONETHELESS PROPOSES TO IMPOSE A DRASTIC REDUCTION IN THE SIZE OF                                                     CONSERVATION ACT, NO CONSULTATIONS WITH OUR GOVERNMENT OR OTHER
                              THE HERD THAT WILL POTENTIALLY HAVE A HUGE EFFECT ON OUR-PEOPLE
                              AS WELL AS YOURS.                                                                                                     CANADIAN   AGENCIES,     INTEREST   GROUPS  OR   NATIVE    ORGANIZATIONS
                                                                                                                                                    OCCURRED,    IN THE HEARINGS IN ANCHORAGE ON THE OFFSHORE LEASE
                              MR, CHAIRMAN, ALL OF THE SPECIES AT RISK FROM THE PROPOSED                                                            SALES, WE MADE AN INTERVENTION IN WHICH WE EXPRESSED OUR CONCERNS
                                                                                                                                                    ABOUT THE LACK OF CONSULTATION WITH AGENCIES IN CANADA. WE WOULD
                              DEVELOPMENT HAVE BOTH UTILITARIAN AND INTRINSIC VALUE AS PART OF                                                      LIKE TO EMPHASIZE THAT SAME CONTINUING CONCERN HERE TODAY.           ONLY
                              THE ARCTIC ECOSYSTEM.     THEY ARE INTERNATIONALLY SIGNIFICANT AND                                                    BY ACTIVE AND ONGOING CONSULTATIONS BETWEEN OUR JURISDICTIONS CAN
                              FIGURE  HIGHLY     IN  THE NORTH AMERICAN UNDERSTANDING OF          THE                                               WE   ENSURE    COORDINATED    AND   CONSISTENT     MANAGEMENT   OF    THE
                              IMPORTANCE   OF    ARCTIC  REGIONS.    PROTECTING    COMPLETE    ARCTIC                                               TRANSBOUNDARY RESOURCES THAT WE SHARE,      THE GOVERNMENT OF CANADA,
                              ECOSYSTEMS WAS THE PRIMARY VISION OF THOSE WHO DEVELOPED THE                                                          THROUGH THE FEDERAL DEPARTMENT OF EXTERNAL AFFAIRS, HAS FORMALLY
                              ARCTIC NATIONAL WILDLIFE REFUGE AND    WHO LATER HELPED TO CONVINCE                                                   REQUESTED A MEETING OF UNITED STATES, ALASKAN, YUKON AND FEDERAL
                              THE GOVERNMENT OF CANADA TO PROCEED    WITH COMPLEME14TARY PROTECTION                                                 CANADIAN OFFICIALS TO FULFILL THE REQUIREMENTS OF SECTION 1005.
                              MEASURES.   IT WOULD INDEED BE EXCEPTIONALLY UNFORTUNATE IF THIS                                                      ALTHOUGH IT HAS NOT BEEN CONFIRMED, IT IS OUR UNDERSTANDING AT
                              VISION WERE FORSAKEN, BASED ON AN INCOMPLETE ASSESSASNT OF THE                                                        THIS TIME THAT THE MEETING MAY BE HELD LATER THYS MONTH IN
                              VALUES OF THE REGION.                                                                                                 OTTAWA,
                              MR. CHA!RMAN, IN OUR VARIOUS PRESENTATIONS THIS WE2K WE HAVE                                                          To sum up. MR. CHAIRM    AN. WF HAVE THREE MAIN CONCERNq WITH THIS
                              POINTED OUT A RANGE CF PROBLEMS WITH, THE DRAFT EiS: WE HAVE                                                          EIS.   FIRST, WE WOULD NOTE THAT, DESPITE THE REQUIREMENTS OF
                              TECHNICAL CONCERNS ABOUT ASPECTS OF THE INTERPRETATION OF
                              BIOLOGiCAL DATAj                                                                                                      SECTION 1005 OF ANILCA, NO CANADIAN GOVERNMENTS, AGENCIES, NATIVE
                                                 WE HAVE DISAGREEMENTS WITH THE RATING OF THE                                                       GROU          :ONMENTALBOGROUPE JOR OTHER       INTEREST, G  'OUPS WERE
                              SIGNIFICANCE OF SCME     IMPACTS; AND WE ARE DISTURBED BY THE                                                             IPS'  ENVI                                               r
                                                                                                                                                    OFF CIALLY CO SULTED A UT TH        002 REPORT. SECOND THE EIS DOES
                              TRADEOFF THAT HAS BEEN CHOSEN 13Y THE AUTHORS OF THE DRAFT EIS.                                                       NOT ADEQUATELY CONSIDER THE POTENTIAL CUMULATIVE EFFECTS OF THE
                              PARTICULARLY IN THE LATTER CASE THERE IS A FAILURE TO ACKNOWLEDGE                                                     VARIOUS DEVELOPMENT POSSIBILITIES IN THE ALASKAN NORTH SLOPE AND
                              THE IRANSBOUNDARY EFFECTS OF DEVELOPMENT.        WHEN ONE CONSIDERS                                                    HE   ADJOINING     CANADIAN   LANDS    AND    WATERS.       THIRD,   THE
                              FURTHER THAT THERE IS NO ASSESSMENT OF THE CUMULATIVE EFFECTS OF                                                      RECOMMENDATIONS IN THE EIS DO NOT REFLECT THE BROADER ECOLOGICAL
                              DEVELOPMENTS ON 1002 LANDS WITH THE PROPOSED I)EVELOPMENTS ON THE                                                     RESPONSIBILITIES THAT OUR GOVERNMENTS SHARE TO ENSURE THAT THIS
                              OUTER   CONTINENTAL    SHELF  LEASE    SALES   OR   OTHER    POTENTIAL                                                GLOBALLY-SIGNIFICANT     WILDLIFE   RESOURCE    IS   MANAGED   TO   MEET
                              DEVELOPMENTS OR ACTIVITIES IN ALASKA AND THE IMMEDIATELY ADJACENT                                                     CONSERVATION-ORIENTED OBJECTIVES,
                              AREAS OF CANADA, ONE CAN ONLY CONCLUDE THAT THE DRAFT EIS DOES
                              NOT PROVIDE AN ADEQUATE ASSESSMENT OF THE NEGATIVE CONSEQUENCES                                                       IN VIEW OF THESE AND OTHER CONCERNS WE HAVE RAISED, MR. CHAIRMAN,
                              OF DEVELOPMENT.
                                                                                                                                                    WE IWOULD STRONGLY URGE THE DEPARTMENT OF THE INTERIOR TO
                              VIE WOULD ALSO  ADD THAT IF WE CONSIDER THIS UNDERESTIMATE OF                                                         RECONSIDER THE SUBSTANCE AND THE CONCLUSIONS OF THIS DRAFT EIS.
                              ENVIRONMENTAL EFFECTS    IN LIGHT OF     THE  EXTREMELY PROBLEMATIC                                                   THE RESOURCES AT RISK ON THE 1002 LANDS ARE NOT SIGNIFICANT
                              NATURE OF THE ENERGY RESOURCE ESTIMATES, WE ARE NOT CONVINCED                                                         SOLELY   FROM   AN   ALASKAN    PERSPECTIVE.     THEY    ARE  ALSO    0 --
                              THAT THE TRADEOFF PROPOSCO IN THE DRAFT EIS IS EITHER A REALISTIC                                                     CONSIDERABLE SIGNIFICANCE TO CANADA AND HAVE WELL -ACKNOWLEDGED
                                                                                                                                                    INTRINSIC   INTERNATIONAL    SIGNIFICANCE,   AND   SHOULD    BE  MANAGED
                              OR A COMPLETELY FAIR EXPOSITION OF ALL THE FACTORS AT RISK IN THE                                                     ACCORDINGLY,    IN THE LAST 15 YEARS, BOTH IN ALASKA AND IN CANADA
                              SITUATION.
                                                                                                                                                    SIGNIFICANT STEPS HAVE BEEN TAKEN TO PROTECT THESE RESOURCES. IN
                                                                                                                                                    OUR OPINION, HOWEVER, THE FULL-LEASING ALTERNATIVE RECOMMENDED IN
                                                                                                                                                    THE DRAFT EIS WOULD BE A STEP IN THE WRONG DIRECTION.

                                                               5                                                                                                                        6

                  THANK YOU VERY MUCH FOR THIS OPPORTUNITY.

                                                                                                                                       GOVERNMENT 0F THE YUKON

                                                                                                                                             SUMMARY OF
                                                                                                                                   TECHNICAL ISSUES AND CONCERNS
                                                                                                                               WITH THE U.S. DEPARTMENT OF INTERIOR
                                                                                                                          DRAFT ARCTIC NATIONAL WILFLIFE REFUGE, ALASKA
                                                                                                                                 COASTAL PLAIN RESOURCE ASSESSMENT

                                                                                                                                      PRESENTED IN WASHINGTON, D.C.
                                                                                                                                           JANUARY 9, 1987

                                                                                                                                                             B. ENVIRONMENTAL ISSUES

                                 SUM14ARY OF TECHNICAL ISSUES   AM CONCEOS                                                                                   Caribou

                                 Following a technical review of the draft Eis by the profes         sional                                                  Seventy-eight percent of the core calving area for the Porcupine
                                 staff of the Department of Renewable Resources and the                                                                      Caribou Hord lies within 1002 lands; the proposed east-west
                                 Intergovernmental Relations Office, the Government of the Yukon                                                             running pipeline/haul road could affect access to 80* of coastal
                                 offers the following comments and concerns which should be                                                                  insect-relief. habitat.       Displacement from the calving area
                                 addressed in the final EIS.                                                                                                 represents a complete loss of habitat that cannot be mitigated;
                                                                                                                                                             the magnitude of adverse effects is speculative but suitable
                                 A. GENERAL                                                                                                                  alternative calving areas for the Porcupine Caribou Herd are not
                                                                                                                                                             apparent.

                                 The Arctic National Wildlife Refuge (ANWR) Is nearly unique as a
                                 conservation system that is intended to protect a complete                                                                  Loss of calving habitat and barriers to free movement would
                                 spectrum of various undisturbed arctic ecosystems in North                                                                  reduce access to insect relief and feeding areas and result In
                                 Americ.a; the 1002 area Is biologically the most productive part                                                            increased levels of stress and disturbance. Cumulatively, these
                                 of ANWR.    Given the biological richness of. the area and the                                                              effects would reduce both available habitat and habitat values on
                                 proposed scale of development under the full leasing scenario,                                                              remaining areas, resulting in population declines.
                                 the pot:ntial adverse environmental effects are unprecedented and
                                 not at   II analogous to the Prudhoe Bay (PH) Development.                                                                  Repeated references in the Executive Summary to the Prudhoe Say
                                                                                                                                                             Oil Field (PBOF) and         its 'minimal" Impact on the wildlife
                                 The pro-deveiopment    nature of  Ithe Executive Summary is In direct                                                       resource, are mislead   Iing and not applicable to the 1002 lands for,
                                                                                                                                                             the following reasons:
                                 contrast to the rather well       Ibalanced section on Envircrusental
                                 consequences prepared by the L@FWS. DOI proposes full leasing of
                                 1002 lands and to control deVelopment by 'imposing appropriate                                                                1.  The  Ccntral Arctic   Herd (CAN) has not increased because of
                                 mitigative measures*.       DOI     III. dc this by ensuring that                                                                 oil   development;     its    growth    is due      to high calf
                                 'unnecessary adverse effects n the environment are avoided and                                                                    production/survival    land relatively    light hunting; the PROF
                                 that compensation for unavoid Is loss of habitat occurs". Those                                                                   has displaced CAN calving without apparent adverse effedta
                                 are reassuring words but                              14 to implement.                                                            because only a small part of calving grounds are affected
                                                                                                                                                                   and suitable alternative high quality habitat is available.
                                 There is a lack of strategic land use planning on             the Alaska                                                          There are a lot fewer caribou in the CAN (13,000) than the
                                 North Slope that confounds ins ability           to predict,  effects of                                                          PCH  (180,000)   -and the CAN is not yet using the availabl           Ia
                                 oevelopment.     There appears to be no coordination between                                                                      habitat to capacity.
                                 landowners or proposed oil/las leasing           schemes (OCS sale'97,
                                 sales on,private or State lauls/waters,          etc.).   The. cumulative                                                      2. The partial habituation to oil development appazent in CAH
                                 impacts, and their effects an ukon North         Slope development, muzt                                                          (particularly among bulls) that they spend most of tr.3
                                 be considered before one can r@ialisticaliy evaluate anvironmantal                                                                summer, and some all year, near PROF or the pipeline is riot
                                 impacts. Site-specific mitig4tive measures ere rendered useless                                                                   necessarily evidence that is transferable to PCH.                  PCH
                                 when regional development as an 1002 lands, Is uncontrolled.                                                                      spend only I - 2 months on 1002 lands in much                   higher
                                                                                                                                                                   densities and in much larger groups (linear developments ar3
                                 As with the OCS sale 197, no Canadian agencies                governments,                                                        more likely to become barriers to large groups of caribou);
                                 native or environmental groups were offici3ily consulted on the                                                                   thus habituation to oil development is less likely for the
                                                                                                                                                                   PCH partic
                                 1002 report.                                                                                                                                  ularly since it consists mainly Of Pregnant cows
                                                                                                                                                                   or cows with calves.

                                                                                                                                                                3. The TAPS corridor runs north-south along the migration routs
                                                                                                                                                                   of, CAN.    This proposed road and pipeline an 1002 lands runs

                                                                                                                                                                                                   3

                                                                      2

                                                                                                                                                mortality from oil spills and we can foresee abandonment of
                                     :
                                        t-westoand :eparates calving area from coastal insect                                                   maternal denning areas. The Only significant onshore donning area
                                      ::ief, h bita    and is therefore more likely to become a                                                 is on, and adjacent to, 1002 lands and both proposed marine port
                                     barrier.                                                                                                   sites are confirmed denning areas, especially Pokok on the east
                                                                                                                                                side of 1002 lands.
                                  4. Experiences with PBOF and CAN do not answer questions of
                                     what happens when caribou are displaced from their calving                                                 Most donning occurs offshore and sites have been confirmed
                                     ground; concerns over similar developments on other herds                                                  throughout the OCS Sale '97 area. a good example where the
                                     are still valid.                                                                                           cumulative impact of two developments (1002 plus Sale 197) has
                                                                                                                                                the potential    for major adverse impacts on an important
                                The  stated intent, under the full leasing scenario, is to leave                                                subsistence   species   shared   internationally.    This   is    not
                                the  PCH calving area until last to allow experiences from the                                                  addressed in the EIS.
                                rest, of 1002 to be used In developing mitigation for the calving
                                area; this would protect calving area but still inhibit access to                                               Waterfowl
                                coastal insect relief habitat.
                                                                                                                                                Ninety-nine percent of 1002 area is considered wetland which is
                                The importance of the PCH for subsistence use in Yukon and                                                      often considered critical habitat for breeding, moulting, staging
                                western N.W.T. must be stressed; in some years up to 801 of the                                                 and migrating 6irdo.    A major impact Is expected on snow geese
                                harvest occurs In Canada; thus adverse effects on the PCH will be                                               that bread on Banks Island and use 1002 area as staging site in
                                magnified in Canada.                                                                                            the fall; between 100-300,000 snow geese or 15 - 201 of the Banks
                                                                                                                                                Island population use the area.        These birds are a shared
                                muskox                                                                                                          resource with considerable subsistence value.       The subsistence
                                                                                                                                                issue is not addressed in the EIS, nor is the internatioral
                                impacts on muskoxen are considered major as they will be exposed                                                significance adequately covered.
                                to year-round activity throughout most of their existing habitat.
                                There is no information availsble on the response of musk@xen to                                                Further it is not apparent that   the EIS adequately considers the
                                sustained   oil    development    activities    but   given     their                                           potential volumetric do4nd for drilling water nor the -spatial
                                non-migratory, localized looding behavior and conservative winter                                               extent of the impacts of stream   diversion and potential damming.
                                energy budgets, one could expect a major change in distribution                                                 Seasonal flow patterns of coastal streams are quite :-'kely to be
                                and population growth. The herd on the coastal plain is tne only                                                modified and the effects of this are.as yet unassessed.
                                population on the  Alaskan North Slope and groups or individuals
                                have moved across to the Yukon where a subpopulation may now be
                                established.    The continued expansion of this muskox population                                               C. CONCLUSION
                                is unlikely given  full scale development.
                                                                                                                                                The draft EIS confirms the considerable biological signficance of
                                Protection of the PCH calving area would only protect a smail                                                   the ANWR lands, and the fact that most of the ?orcupin3 Carib@u
                                portion of muskox  population.                                                                                  Herd (PCH) calving area and insect-relief habitat is located in
                                                                                                                                                the 1002 lands (78*).      However, based on the initial winter
                                Polar Bear                                                                                                      seismic exploration of the region, the DOI computer models
                                                                                                                                                predict that there is a 19% change of economically recoverable
                                The Beaufort Sea population of polar bear ranges from Barrow to                                                 oil reserve (at S33.00/bbi).      Assuming Oil . is discovered the
                                Tuktoyuktuk and numbers about 2000 bears.        The population is                                              computer model predicts there Is a 95 percent chance that 0.6
                                currently stable and cannot withstand further mortality without                                                 billion barrels of recoverable oil is available and there is a
                                resulting population decline.      We have concerns over diract                                                 five percent chance of 9.2 billion barrels available.. Given the
                                                                                                                                                shape of the probability distribution, the most likely d1scover7

                                                                 4

                                   will be 3.2 billion barrels of oil under the plain.  U.S. demand
                                   for oil is estimated at 16 milli on barrels per day by the year
                                   2000.  If the ANWR area were developed and the oil discoveries
                                   were indeed achieved, the total U.S. demand would be met for 200
                                   days.

                                   The Department of Interior takes the position that the likelihood
                                   of discovery of oil, outweighs the acknowledged negative
                                   environmental impacts, including a 20 - 40% decrease in the size
                                   of the PCH.

                                   We do not agree that the very uncertain potential for recovering
                                   3.2BB is balanced by the loss of

                                        1.   a significant portion of the PCH calving area
                                        2.   the continued expansion of the only North Slope muskox
                                             population
                                        3.   an unknown but potentially important segment of the                                                                The Yukon Legislative Assembly
                                             Beaufort Sea polar bear population
                                        4.   wetland habitat for internationally important migratory
                                             snow geese                                                                                     Number 43			3rd Session				26th Legislature
                                        5.   wilderness values in an ecologically unique area
                                        6.   subsistence lifestyle not only in Kaktovix but also in
                                             Old Crow that have few alternatives to the PCH.

                                   To suggest, as is done in the Executive Summary, that                                                                                HANSARD
                                   "development on 1002 lands would proceed with the goal of no net
                                   loss of habitat quality and that unnecessary adverse effects
                                   would not be allowed to occur" is an unfortunate
                                   misrepresentation and will not be achievable.
                                                                                                                                                               Wednesday, December 3, 19   - 1:20 p.m.
                                   We believe the draft EIS should be amended to account for the
                                   various technical points raised above.  If the Department of
                                   Interior disagrees with any of the technical points we have
                                   raised we would appreciate receiving a written explanation of the
                                   reasons for the disagreement.

                                   Thank you.                                                                                                                        Speaker: The Honourable Sam Johnston

    142	YUKON HANSARD	December 3, 1986

    and graduated as a lawyer.  Now, to sit there as a Member of the
    Yukon Legislature would give me great pride and great pleasure.
    	We hope that the costs involved will not be prohibitive, and I
    have no hesitation in directing the House Leaders to make every
    possible effort to reach an agreement by which a sitting could be
    arranged to take place in Dawson in 1987.  Thank you.

    Hon. Mr. Kimmerly:  I am glad the previous speaker men-
    tioned costs, because that is part of the subject of my addition to
    this debate.  When we get to it in the Capital Supplementaries.
    Members will discover that there is money allocated in Justice for
    this building.  What we are going to do is reconstruct the old desks,
    which existed there in the Chambers' heyday.  This will be, of
    course, a little more expense than buying modern furniture,
    however it will enable local economic stimulation in that the cabinet
    work can be done in Yukon and we can copy the old desks.  I am
    told that two of them exist, which are in poor shape, but it is
    possible to reconstruct that old furniture.

    Hon. Mr. Kimmerly:  This will, of course, add to the tourism
    potential of that room, especially in that building, as it can be a
    room that can be displayed to tourists.  It will also be used for the
    circuit court when it sits in Dawson if the court consents to sit in a
    room that displays a crest, which exists in the building as well.

    Hon. Mr. Pealkett:  I would like to join this debate briefly.
    Unlike the fortunate Member for Porter Creekl West, my education
    is not complete and in some way one might argue that daily
    attendance in this House contributes to that process, but I must say
    that it is a toss-up some days as to which was the more pleasant of
    the two experiences, school or this institution to which I now
    attend.
    	Let us say quite simply that having moved the motion referred to
    by the Members here and having been joined in debate on that
    occation by the then Minister responsible, the Member for
    Riverdale South, and seeing the readiness to respond to this
    initiative.  I am, as the Minister of Renewable Resources said,
    extraordinarily pleased to have been blessed with the opportunity in
    my present role to see it through to completion.
    	Let me say without hesitation, in my view, that this is the most
    beautiful building in the Yukon Territory.  Architecturally I think it
    is the most appealing.  I also think the use of fir and native woods
    throughout is a wonderful example of what can be done, or what
    was done, by our forefathers with local materials and the building
    materials of the day.
    	On the last occasion that I was in that building, which, as the
    Member for Porter Creek East said, the locals refer to as the
    Museum Building.  I wandered up into the Legislative Chamber.  It
    was, as I said in 1983, a very sad occasion for me.  As someone
    who is perverse snouth to actually like legislators and is
    monomaniacal on the subject not to have visited every single one in
    this country at one point or another, and is even soft-hearted enough
    to feel quite sentimental about such facilities and their importance
    to our culture and civilization, and not just our political life, I was
    disturbed by the condition of the Chamber as it was then.  There was
    furniture on its side with cobwebs and dust.  It was in a general state
    of disrepair.
    	Even though the Chamber is not yet finished, even naked like it
    is, it is a beautiful sight.  It is wonderful to see what has been done
    in the restoration of that building.  I, for one, will look forward with
    great anticipation to the opportunity of holding a sitting, even a
    brief one, even a ceremonial one, at some occasion next year in that
    place.
    	I think it is important that, as a Legislature, we do that, not just
    as a gesture, as the Member for Faro suggested, towards a rural
    visibility.  I think it is also important for us to do to maintain a
    sense, as few Members - save and except the Leader of the
    Official Opposition - will have, of the continuity and the longevity
    of this institution.  I think you can make a convincing argument, for
    example, that this Legislature, as an institution, is older than
    Saskatchewan's.  That is something that I think few Canadians
    would appreciate.
    	Because we are in a new building, in a new facility, in a new
    capital, I think we lose the sense of that.  We lose touch with the
    past.  I think it is as dangerous to neglect one's history as it is to be
    absentminded about one's future.  I think it is very important that we
    celebrate the past -- the roots, if you like -- of this institution by
    having at least a ceremonial sitting in that place.
    	I would like to join the observation of the Member for Porter
    Creek West, with respect to the building not being just a building
    that has been restored and sitting there.  It is not a deal artifact.  It is
    a living, breathing building.  Not only are museum people there, but
    office of several government departments are there.  I think it will
    be a building that is used and enjoyed and treasured by not only the
    people of Dawson and the people of the Yukon Territory, but by
    many visitors, as well, for years to come.
    	I think it ought to be a source of pride to the people of this
    territory that the territorial government did this restoration, rather
    than Parks Canada.  The work we did in this case is commendable.
    It is something that is laudable, something about which we should
    feel very proud.
    	I would want to pay tribute to the architects, the Irndale
    partnership of Vancouver, BC and the general contractors, Klon-
    dike Enterprises, and the workers who performed so marvelously in
    the job.  As we comment on the facility today, and the prospect of
    having this House sit there, I can only resume my place with much
    appreciation of the fact that the desire to go there is shared on all
    sides of this House, and I welcome the day when we arrive and
    relive, in some sense, the experience of our predecessors in this
    institution.

    Speaker:	The honourable Member will close debate if he now
    speaks.  Does any other Member wish to be heard?

    Mr. Webster:	Judging from the remarks during debate, it
    appears that this motion has been recieved favourably, and I
    welcome all of you to the special sitting in the old council chambers
    in the OTAB, hopefully some time next year.
    	One of the difficulties or hardships facing a representative of the
    Klondike riding is the fact that the workplace, the Yukon
    Legislative Assembly, is 330 miles from home.  For once, it will be
    interesting that Members of the House will themselves experience
    commuting to and from work.  For this reason, amony others, I am
    very much looking forward to this special occasion.

    Motion No. 65
    Mr. Clark:  Item No. 3, standing in the name of Ms. Kassi.
    Speaker:	Is the honourable Member prepared to proceed with
    Item No. 3?
    Ms. Kassi:  Yes.
    Speaker:  It has been moved by the honourable Member for Old
    Crow:
    	THAT this House requests that the Government of Yukon seek
    immediate comminication by the Government of Canada so the
    Government of the United States expressing the deep concern of
    this House and of Yukon people over activity in Alaska which may
    harm the Porcupine Caribou Herd, a resource that people of both
    countries depend upon; and
    	THAT the Government of Canada to specifically requested to
    emphasize the importance of concluding an international agreement
    on caribou prior to the United States making any decisions on
    activity in the Arctic National Wildlife Refuge which may harm the
    herd.

    Ms. Kassi:	This motion is before the House today because of
    events in the United States, which may take place in Alaska in the
    near future.  These events concern the Porcupine caribou herd,
    which many people rely on.  I think all honourable Members are
    aware of the importance of this herd to my people as well as in the
    people nearby in the Northwest Territories and Alaska.
    	We are talking about the proposal by the Department of the
    Interior of the United States government.  This proposal suggests
    that the United States government allow oil and gas exploration on

    the Alaska North Slope in the calving grounds of the Porcupine
    caribou herd.  Most honourable Members are aware that the calving
    grounds of this herd are limited a great deal by geography.
    *There is a fairly narrow strip of coastal plain between the British
    Mountains and the Beaufort Sea that are used for calving grounds.
    Simply put, if the caribou lose the use of these grounds for
    whatever reasons, then the population of the herd will be reduced,
    perhaps drastically.  That means that a lot of northern people will
    suffer as a result.  This exploration will take place between Prudhoe
    Bay, the Yukon border, and the Arctic National Wildlife Refuge, an
    area that the US federal government has control over.
    	The report resulted from the Alaska National Interest Lands Act
    of 1980, which required detailed assessment of the impact of oil
    and gas potential in the area involved.  This report has been
    released.  It states that full-scale petroleum exploration should
    proceed.  They say that in doing this the impact on the caribou herd
    would be to reduce its population, and they seem to think that this
    is fine.
    	Obviously, the US Department of Interior did not consider the
    costs to my people or to other Yukoners, perhaps not even to
    Alaskans.  As well, the people of Old Crow will not benefit from
    this petroleum exploration in Alaska.  I doubt if Alaskans will in the
    long run, as well.  The point is that the actions of this government
    could well hurt my people by hurting the caribou herd.  Right now
    we have achieved a management agreement for users of the herd in
    Canada.  This is a great accomplishment, and, once again, I
    commend all concerned, including our Yukon and federal govern-
    ments.
    	At the moment, negotiations are underway between Canada and
    the United States for an agreement between these two countries on
    the international management question.  This is because both
    countries recognize how important this herd, this great natural
    resource, really is, and because international management is what
    we must achieve to protect the herd for our children and our
    children's children.
    	However, now we find a US government department deciding
    that the herd is not worth saving or, at least, that jeopardizing its
    future is an acceptable rish for a few barrels of oil.  From my point
    of view, and from the point of view of my people, the natural
    environment, which has meant a continued survival for so many
    years, is too often threatened by industrial development.  Pollution,
    over-population, and all these sorts of problems around the world
    mean more and more natural wildlife habitats disappear each and
    every year.  We see that every day when we look to the south; it
    goes on here in the north, as well.
    	My people, the Gwich'in, have cherished and protected our lands
    as long as we have been here, and we will continue to do so.  We
    will work to ensure the preservation of a natural habitat for the
    wildlife forever.  The land and the natural habitat it provides is our
    spirit, our culture, and our way of life.  We hold a moral obligation
    to respect and preserve this natural environment, which we are a
    part of.  The circumpolar north is the only vast wilderness left, and
    we must fight together to preserve it as long as we can.
    	The caribou are our main livelihood. The caribou are our life.  It
    has never been otherwise in my village of Old Crow.  Caribou have
    migrated near our village for many thousands of years, and this is
    why the village is located where it is today.  Our people have hunted
    this herd and depended on it for many thousands of years.  We have
    conserved that herd.  We have our ways to do so, and it remains the
    main source of food and clothing for my people.
    	The coastal plain is critical to the life cycle of the caribou herd.
    Calving time in that part of the year when the young caribou are on
    the calving ground is very critical to the health of the herd.  The
    caribou are extremely sensitive to intrusions at this time.  Explora-
    tion in this area would cause disturbance and harm to the herd.
    Their food base would be diminished, diseases will set in and, as a
    result, the population will become more vulnerable to predators,
    and the population would decline.  The Porcupine caribou still range
    freely, but they are being attacked from all sides, from Prudhoe
    Bay, from the Beaufort, from the Dempster, and from the
    Northwest Territories.  The herd are under pressure now; they
    should not be squeezed anymore.  The caribou have roamed freely

    for centuries in northern Yukon and Alaska.  We should leave them
    free and healthy.
    	The intent of my motion is to express, through the proper
    channels of the Department of External Affairs, to the United States
    government the importance of this herd to all Yukoners and the
    importance of achieving an international agreement on the Porcu-
    pine caribou before decisions can be taken on the petroleum
    exploration on the Alaska north coast and in the Arctic National
    Wildlife Refuge.  With that, I will end my opening remarks and ask
    all hon. Members for their support to this motion.

    Mr. Phelps:	I would like to begin by thanking the Member for
    Old Crow for bringing this motion forward.  It concerns a very
    important subject matter not only to the people of Old Crow, whom
    she represents, but, of course,  in all Yukoners, all northerners.  It
    really deals with a significant and unique world resource.
    	We have, and I have, a special interest in the Porcupine Caribou
    Herd because of the time that I spent, along with many other
    people, working to try to bring together a management agreement
    on the Canada side.  That agreement was finally achieved and signed
    in Old Crow just a little over a year ago -- time flies by.
    	All the community user groups had representatives from the
    Canadian side, and some from the Alaskan side, present at that very
    important signing.  i want to express my appreciation for having
    been invited by the Minister of Renewable Resources.  I accept that
    as a very gracious gesture.
    	I was pleased, at that time, to meet with many of the Elders of
    Old Crow whom we have had negotiations with; they have been at
    the table on numerous occasions, many of the Elders from the other
    communities, such as Fort McPherson and Aklavik and Inuvik, who
    have partaken of the strenuous ongoing negotiations, and to meet
    with some of the other negotiators, such as Bob Celeury from the
    COPE people, Grafton Njootli had carried the ball for a consider-
    able period of time, as well as then Chief Johnnh Able, later
    Stanley Njootli.  There was a tremendous number of people from
    Renewable Resources, from this government, who were involved
    and very dedicated in attempting to find a solution, which was very
    difficult to achieve, given the conflicting problems that all parties
    had.
    	There were so many user groups, each trying to get a fair share of
    the resource.  There were territorial rights to sort out.  There were
    the differing interests sometimes between the governments because
    of their special concerns.
    	All involved ralized that these kinds of competing interests had
    to be put aside for the betterment of the herd.
    	What was achieved, as the Member for Old Crow has ably
    expressed this afternoon, was a partial solution, because it dealt
    only with the Canadian side.  As most people know, the herd ranges
    across the international border into Alaska.  A significant area for its
    calving grounds are in Alaska.  The next step is to try to achieve
    agreement internationally with the State of Alaska and the user
    groups and then the federal governments, as well, bringing
    everything together into an international treaty.
    	It is a huge undertaking.  We have come part of the way, but it is
    almost overwhelming when one really sits down and considers all
    the various parties that attend and have significant interests in
    arriving at a solution to try to ensure that this herd is and will be, in
    perpetuity, protected as well as it can be within the competency of
    mankind.
    	I am pleased to see that there are some people from Old Crow in
    the audience today.  It is a significant fact that Old Crow's
    dependency on the herd is unique, unique in that, of the community
    user groups, it is the community that relies on the herd.
    	The communities in the NWT have other herds that they do hunt
    that they can turn to.  It is that unique dependence that made us
    extra careful in negotiating the agreement to ensure that that was
    recognized and that, if there were hard times during any period of
    years, Old Crow's interests would be protected in a very, very
    careful fashion.
    	I am convinced that, because of the work done by all of the
    people who were in attendance at the meetings, we did accomplish

    144 		YUKON HANSARD			December 3, 1986

    that very important goal.  What has happened now has to be of
    tremendous concern to us all.  It has to be particularly alarming to
    the Old Crow people whose very lifestyles are dependent on the
    health of the herd.  Again, I thank the Member for Old
    Crow for pointing out some facts that I will repeat, in part at least,
    because they are significant ones and they have been very correctly
    stated.
    	The first point that people have to be aware of is that this large
    herd calves in a very restricted physical area, restricted because it is
    a narrow coastal plain, the Beaufort Sea on one side and the
    mountains on the other.  When activity does take place, it certainly
    does not leave much room for that herd to get out of the way of
    mankind's develoopment.  That has to be of tremendous concern, not
    only to us, but especially to the Old Crow people.
    	The Member for Old Crow has spoken about the possible
    reduction of the herd, and that is certainly one consequence.  Yet
    another consequence, and one about which we must really be
    alarmed about, is the potential for the herd to change its migratory
    patterns.
    	This has happened already, from time to time, often for reasons
    that the biologists do not know.  There is a large degree of
    unpredictability.  It is a difficult situation to manage for that reason.
    If the Migratory patterns change, they could bypass Old crow at
    such a distance that it would have the same effect as a disaster to
    the herd itself, so that has to be a sincere concern shared by all of
    us.
    	I take a great deal of pleasure in standing up to support the
    motion.  I am sure that it will be passed unanimously in the House.  I
    am sure that that very fact will have some significance on the
    political process whereby the Government of the United States will
    be making its determinations regarding the possibility of allowing
    oil production on the north coast.
    	Once again, we will be fully in support of this important motion.

    Hon. Mr. Porter:	Like the previous speaker, I, too, would like
    to acknowledge the presence in the gallery of the representatives
    from the community of Old Crow and would like to welcome those
    individuals to these Chambers.  I think their being here today makes
    a statement as to the degree of concern that they have on this issue
    and, more specifically, on the future of the Porcupine caribou herd.
    Maybe their presence here today might mean that there will be some
    dry meat on my desk when I get back.  I will have to wait until the
    break.
    	With respect to this particular question, I was contemplating an
    announcement earlier on with respect to the initiatives that this
    government is undertaking regarding the international talks.  It was
    during the discussions with the department concerning the drafting
    of that announcement that we learned of the most recent events.  In
    the last two weeks we have become aware that a new draft report
    from the US Department of the Interior recommends a major
    expansion of oil and gas leasing and exploration of some critical
    portions of the Porcupine caribou herd's range, particularly the
    calving grounds.
    	Needless to say, it is a disturbing development that, potentially,
    runs counter to many of the incremental habitat protection
    improvements that have been achieved on both sides of the border
    in recent years.
    	The US report acknowledges that there will be negative effects on
    the Porcupine herd and thereby there are potential negative
    consequences for the people who use that herd.  I think we have
    heard in earlier debates the importance of the Porcupine caribou
    herd to all of the people who live in the area of the caribou habitat,
    and I think that we are very well apprised of what that particular
    resource means to thos people.
    	For me, as the Minister of Renewable Resources, there are at
    least two necessary reactions to the announcement made by the US
    Department of the Interior.
    	First, I think we have to redouble our efforts to negotiate an
    effective international agreement, and, secondly, I believe that this
    House should make its immediate concerns about the proposed oil
    and gas leasing clearly known to our US friends.  We have an ideal

    opportunity to do so because public hearings are to be held in
    Kaktovik, Anchorage and Washington, DC before January 23,
    1987.
    	I have outlined before that in our International Management
    Agreement we need the strongest possible assurances of the
    strongest possible habitat protection measures.  We need asn equit-
    able management and allocation system, and we need to ensure that
    the use of the herd can be sustained in perpetuity.  These messages
    must also be taken a directly as possible to the United States
    bureaucratic decision-makers and the politicians.  We need to ensure
    that the decision-making that is now taking place truly reflects the
    needs of Alaskan and Canadian users of the Porcupine herd and to
    ensure that the precedent that could be established, if the
    Department of Interior report is accepted, does not destroy our
    ability to jointly manage the herd before the agreement to do so is
    even negotiated and signed.
    	Almost seven years ago, the United States government passed the
    Alaskan National Interest Lands Conservation Act after years of
    effort to protect the incredible wilderness resources of Alaska.
    Traditional subsistence activities were designed into the manage-
    ment of the Arctic National Wildlife Refuge, but the fact that the
    area became a wildlife refuge with only 50 percent zoned
    wilderness was the result of a major political compromise.  The
    coastal plain remained in limbo, and the Department of Interior was
    asked to study the oil and gas issue in more detail before any
    decisions were made.
    	Now, after seven years of wrangling and negotiating, their report
    basically states the well-known fact that heavy development will
    have negative effects on the Porcupine herd and obviously negate
    the wilderness characteristics of the coastal plain, but it is a value
    judgment.
    	Hard evidence of oil and gas is not available.  The preliminary
    results of seismic work and drilling on private land near Xaklovik
    were inconclusive, and the report says there is 93 percent chance of
    a relatively small oil field and a five percent chance of a large oil
    and gas field.  I basically think that the value judgment that we are
    discussing here, which is being made in other parts of the world, is
    a very critical one, and I think that when we do make that
    judgment, we have to balance the interests of the people of that
    area, the caribou and, as well, the wilderness values of that
    particular region.
    	It is ironic that for many years the Americans, specifically the
    Alaskans, have asked us to do something about joint protection.
    The Arctic International Wildlife Range idea was hashed over many
    years ago, and the US made most of the early tangible strides to
    gain real protection for the Arctic landscapes.  Now we are
    potentially faced with a real decrease in the level of US protection
    while we, in Canada, at this time have quite good and improving
    measures that are being incorporated onto our books on laws and
    regulations.
    	I have often mentioned that we need to speak about environment
    and development rather than always thinking in terms of environ-
    ment against development.  As Donald McDonald stated in the
    recent Commission on the Canadian Economy, "Although the
    Government of Canada has talked about balanced development, not
    enough has been done to protect areas of outstanding natural
    significance.  We must recognize the intrinsic values of the nortern
    ecosystem.  We must all learn to value the wilderness and the
    unspoiled aesthetic virtues of the north.  The environment is the very
    ground of our existence and intrinsicly wanting of our respect and
    even of our awe".
    	I want to express the theme once again and argue to all Members
    of this House to consider this motion and to give it unanimous
    consent.  In conclusion, I think that what the Leader of the Official
    Opposition has said about the intentions of his party to support this
    measure is welcomed by this side, particularly myself.
    	I would also like to convey a statement of congratulations to the
    Leader of the Official Opposition for the way in which he
    approached, and spoke to, this measure.  I believe the Leader of the
    Official Opposition when he says that he has the best interests of
    those people at heart.  I belive the Member has some very real
    honest concerns with respect to the whole question of the North

    Slope and its development.  I think it is an important statement
    today that over the last couple of days we may have been wrangling
    about what some may deem as to be petty and inconsequential
    administrative issues that we can come together on a substantive
    issue of policy and philosphy and make a joint statement.  I think
    that demonstrates to the people, whom we represent, that the
    system does work.
    	With respect to the motion before us, I would thank the Member
    for Old Crow for doing the work to bring this motion to the
    attention of the House.  I would like to thank all Members for giving
    their support to this issue.
    	Thank you.

    Motion No. 62
    Clerk:	Item number 7, standing in the name of Mr. Brewster.
    Speaker:	Is the Hon. Member prepared to deal with item
    number 7?
    Mr. Brewster:	Yes, Mr. Speaker.
    Speaker:	It has been moved by the hon. Member for Kluane
    Corporation and the Yukon Houseing Corporation to amend the
    current Rural and Native Demonstration Program to provide a
    thirty-year, no interest loan rather than an outright grant for
    building materials.

    Mr. Brewster:	I presented this motion to help straighten out the
    important housing situation that exists in Carmacks as a result of the
    Rural and Native Demonstration Program provided jointly by
    CMHC and YHC.
    	If Members have been reading the local newspapers, I am sure
    they have noticed a whole series of letters to the editor explainging
    both sides of this issue.  A major controversy about the program is
    currently raging in Carmacks.  I had a talk with many people about
    the program, and most people agree that there is considerable merit
    to it; however, where the problem comes in is how the program is
    implemented.
    	The major objections to the program concerns its giveaway
    nature.  There is no return to the taxpayers.  How can the program be
    perceived as being fair when outright grants are being given that
    enable the recipient to have title within five years.  The average
    homeowners are locked into a 25 to 30 year mortgage and have to
    pay a substantial amount of interest before they receive title to their
    house.
    	It should be remembered, as well, that it is the average
    homeowner who is paying for this program through their taxes.  The
    current program, besides being unfair, is seriously flawed.  Theore-
    tically, a person who receives one of these house could sell it after
    five years and make a substantial profit, courtesy of the taxpayers.
    this just should not be.
    	I have also heard that the people who will receive these houses
    effectively pay for them through their labour, something called
    sweat equity.  Well, I just do not buy that argument.  I know of very
    few homeowners with mortgages who have not done a great deal of
    work on their own home, and they are not getting any credit for
    their labour.
    	The program is well-intentioned, but it is flawed.  The motion I
    have presented to you for your consideration would correct the
    situation and make the program more acceptable to everyone.  The
    support of this House would certainly help the proposal being
    adopted, and I call upon you all for your unanimous support.

    Hon. Mr. McDonald:	As a Member for Kluane pointed out,
    the Rural and Native Demonstration Program has been the matter of
    some controversy in Carmacks and on the front pages of the paper
    and in the media generally over the past few weeks, largely because
    there has been some concern expressed by the criteria supporting
    the program, a program which is sponsored by CMHC.
    	The program, in its original incarnation, which was not particul-
    arly long ago, and is a pilot project after all, was sponsored
    primarily to encourage a self-help home ownership program in the
    interests of social housing.  Clearly, many of the programs across

    the country have not encouraged the home-ownership aspect in
    social housing and have not done enough to encourage the self-help
    approach to housing development.  This program was meant to be
    modelled after a similar program currently existing in the Northwest
    Territories to encourage both thos components: self-help and home
    ownership.
    	As the media has pointed out, and as the Concerned Resident of
    Carmacks Committee has pointed out in the media, there are some
    legitimate concerns with respect to the criteria associated with the
    program.  In order to ascertain what the concerns are in some detail,
    officials of the Yukon Housing Corporation have travelled to
    Carmacks to speak personally with the Concerned Residents of
    Carmacks Committee and also to speak to others in the teritory
    who have expressed a desire to make improvements to the program.
    	The motion before us today calls on the Canada Mortgage and
    Housing Corporation and on the Yukon Houseing Corporation to
    amend the program to provide specifically for a 30-year, no-interest
    loan rather than an outright grant for building materials.
    	The wording is very, very tight and very, very specific and
    clearly, as the Member for Kluane pointed out, there are a number
    of concerns with respect to the criteria upon which this program is
    based.  I have not heard any criticism with respect to the general
    principles supporting the program, but primarily the criteria.
    	The pointed points from the Member are well taken in that
    respect. I would recognize, however, that in the motion itself the
    recognition of the desireability of a no-interest loan is, in fact, a
    grant of a kind, but it certainly is something that is worth pursuing
    and doing some number crunching on to determine whether or not it
    is the best approach to take.
    	As the Member has pointed out, there are other criteria changes
    that may be worth altering in the interests of making this pilot
    project a worthwhile program for the territory.  The Yukon Housing
    Corporation has already cleared with CMHC the necessary steps to
    make sure that criteria can be changed and can make this program a
    true Yukon program.
    	The Housing Corporation Board of Directors has taken it upon
    themselves as well to review the program.  They have been making
    some suggestions for improvements to the program, recognizing
    that a financial analysis of the various options should be undertaken
    prior to any representation being made to CMHC.  I understand that
    they are currently reviewing a number of the criteria in order that
    the program can be made better.  Those include the payback
    provisions that the Member mentions, the eligibility requirements
    and the method of selection, which has also been expressed as a
    concern, as well as the flipover provision.
    	There has to be some obligation on the part of the Housing
    Corporation, and housing programs generally, to review, develop
    and implement programs with a mind to local market conditions in
    any community.
    	In response to the motion, we, as a government, have asked the
    Housing Corporation to ensure that consultation done for this
    program, and other programs in the future, be done thoroughly, and
    they have taken it upon themselves to do just that.  The Housing
    Corporation is currently in consultation with the concerned resi-
    dents of Carmacks, and there will be other meetings that will be
    addressing this and other issues.  I would, therefore, think it to be
    somewhat inappropriate to simply design amendments to the
    program without completing the consultation with people who
    brought many of the problems to our attention.
    	For that reason, I would be premature to impose a provision,
    whether it be the issue of payback, the issue of eligibility
    requirement, or the issue of method selection, on CMHC or the
    Yukon Housing Corporation, until such time as consultation has
    been conducted.
    	I do not think that there is any doubt in our minds that
    improvement can and should be made to this program.  I think that
    the general principles of self-hdlp and home ownership are valuable
    principles to promote.  For that reason, I would hate to see a good
    program go down because the criteria had not been altered to speak
    to the problems.
    	In the interests of ensuring that consultation does take place and
    so that people do not feel that we are simply imposing a solution or

                                            DEPARTMENT OF THE ARMY
                                            UA. ARMY 1ENGINCIER DISTRICT, ALASKA
                                                       P.D. Box 994
                                               ANCHORAGE, ALASKA N606-08913

                                                                                                                                   e. I want to point out the existing regulatory mechanisms (tools)
                 Regulatur7`Br`a`n*c`h'                                                                                        available to us to tailor our Regulatory role to that needed to serve the
                 Special Actions Section                                                                                       public interest. Our options, which we would coordinate closely with you
                                                                                                                               covers the full range of programmatic general permits, an Abbreviated
                                                                                                                               Processing Procedure (APP), advanced identification of generally suitable
                 Director, U.S. Fish and Wildlife Service                                                                      and unsuitable disposal sites with the Environmental Protection Agency,
                 Division of Refuges                                                                                           and a Special Area Management Plan (SAMP) option. All of these or any one
                 Room 2343 Main Interior Building                                                                              of them can be applied as appropriato to protect the public's interest in
                 l8th and C Street Northwest                                                                                   these areas.
                 Washington, U.C. 20240                                                                                            Your 1002 11 Report, with few exceptions, has presented a clear aod
                                                                                                                               reasonable picture of potential environmental consequences for
                 Dear Sir or Madaln*                                                                                           Congressional consideration. If Congross decides it is in the public
                     This letter is in response to the Draft Arctic National Wildlife                                          interest that the ANWR 1002 H area be developed for oil and gas
                 Refuge (ANWR), Alaska, Coastal Plain Resource Assessment, Report and                                          production, we agree it can be accomplished satisfactorily in a carefully
                 Recominendation to the Congress of the United States and Legislative                                          planned and regulated manner.     Together we have sufficient regulatory
                 Enviroolnental linpact Statement, published in'November 1986 (1002 H Report)                                  tools and restraints in place to minimize potential impacts and to ensure
                 and to your notice in the Federal Register on November 24, 1986.                                              the public interest will be protected.
                     The 3002 H Report is well written and overall is a good source of                                             We look forward to working with the USFWS to ensure our r@spective
                 reference for the ANWR area.   There are some points of uncertainty that                                      interests and authorities are well coordinated and to ensure concurrent
                 need clarification. Enclosed are detailed comments On various aspects of                                      and timely development decision if Congress gives the "go ahead" to
                 the report.                                                                                                   development.
                     In addition to the enclosed, I want to highlight several of the                                               I am forwarding a copy of this correspondence to the agencies on the
                 comments :                                                                                                    enclosed list.
                     a.  I support most of the expected impact conclusions (although in                                            If I may be of further assistance please contact me directly.         It your
                 some respects they are overly pessimistic) as being a worst case scenario                                     staff has Questions concerning the comments or Regulatory process they
                 for the on-shore development.   However, the potential for substantial                                        should contact Larry L. Reeder, Chief, Special Actions Section, Regulatory
                 impacts due to @Oarine development has been understated or avoided.                                           branch, at the address above or by telephone at    1 (907) 753-2712.
                 Additional discussion of potential causeway related impacts should be                                                                                    Sincerely,
                 included in the final report.
                     b.  I recoiniiend you avoid extensive monitoring programs to determine
                 mitigation by assessing expected impacts and required mitigation up-front
                 before allowing development, if possible.                                                                                                                Wilbuy T. Gregor , Jr.
                                                                                                                                                                          Colonel. Corps of Engin ers
                     C.  Needed mitigation should be part    of specific U.S. Fish and                                                                                    District Engineer
                 Wildlife Service (USFWS) authOrizdtions to the maximum extent possible and                                    Enclosures
                 not rely solely on our permitting process to determine and require
                 initigation as a permit condition,
                     d. We request to be a cooperating agency for any future Environmental
                 impact statement that may be prepared, This is due to our expected
                 regulatory role for most of the Projected development proposals.       As the
                 1002 " Report has correctly stated, a major portion of the 1002 H area is
                 under Department of the Army (DA), Clean water Act Jurisdiction and DA
                 permits will likely be required for most develoPMent activities-
                                                                                                                                                                                     Gregor
                                                                                                                                                                                    C . r. s , - H,,J, u i

    Commander
    U.S. Army Corps of Engineers
    ATTN:  DAEN-CWO-N
    20 Massachusetts Avenue, Northwest
    Washington, D.C. 20314-1000

    Mr. Robert Jacobson
    U.S. Fish and Wildlife Service
    Alaska Regional Office
    1011 Tudor road
    Anchorage, Alaska 99503

    Tony Booth, Assistant Field Supervisor
    U.S. Fish and Wildlife Service
    Fish and Wildlife Enhancement Ecological
       Services/Endangered Species Branch
    101 - 12th Avenue, Box 20
    Fairbanks, Alaska 99701-6267

    U.S. Fish and Wildlife Service
    Refuge Division
    Alaska Regional Office
    1011 Tudor Road
    Anchorage, Alaska 99503

    Alaska District U.S. Army Corps of Engineers
    Comments on ANWR 1002 H Report

    EFFECTIVE SUMMARY

    1.	Page 1, 2d column, 3d paragraph:  "...developing mitigation for
    	activities in the calving area..." and "...require compensation in the
    	event of significant unavoidable losses of habitat quality."

    	These statements imply a monitoring program would be established to
    	determine mitigation needed at a later date.  I recommend and urge
    	that expected impacts be determined up-front and that appropriate
    	mitigation be determined in advance of work authorizations being
    	granted.  Monitoring programs, in our experience, can be as costly as
    	the mitigation itself and indicate that you may not have enough
    	information available to make the development decision.  Avoid
    	monitoring programs, for the purpose of determining mitigation, if
    	possible.  I agree that monitoring should be done to ensure that
    	development is being accomplished as authorized and that required
    	mitigation has been accomplished (and to see if more may be needed),
    	but it is preferable that mitigation decisions be made in advance, not
    	after the development has occurred.

    	I also note on page 111, 1st column, 2d full paragraph, that
    	"Mitigation of the loss of caribou habitat in Resource Catergory 1...is
    	not possible."  This statement (which is likely correct) contradicts
    	the inference made in the Executive Summary.  A statement should be
    	made that expected losses will be mitigated to the maximum extent
    	practicable (obtainable?), however, some losses will occur that cannot
    	be compensated.

    2.	Page 1, 2d column, 5th paragraph:  "...some long-term effects on the
    	area's water resources..." (emphasis added)

    	This statement should be clarified to include loss of resources due to
    	both direct and indirect impacts of fill placement and dust and
    	disturbance impacts.  The 1002 H Report adequately covers these
    	impacts in its discussions, but the ambiguous  "some" needs to be
    	expanded in the Executive Summary.

    3.  	Page 2, 1st column, first full sentence:  "Most adverse effects would
    	be minimized or eliminated through carefully applied mitigation using
    	the lessons learned and technology acquired from development at
    	Prudhoe Bay..." (emphasis added)

    	While I agree that impacts can be minimized or avoided through
    	carefully applied onsite mitigation measures, this statement implies
    	that we already have "mitigation" techniques developed that will

                   compensate (eliminate?) unavoidable impacts; this is not the case.        In                                 Page 6, ENVIRONMENTAL CONSEQUENCES OF OIL DEVELOPMENT ON THE 1002 AREA:
                   fact, in light of industries' reluctance to deveI92 dad use                                                  No mention is made of the potential substantial effects of any needed
                   compensatory MiLigation/restoration techniques, none has been applied
                   on the North Slope of Alaska, except to a very limited experimental                                          causeway at the docking facilities. Even with substantial breaching,
                   extent. The technology has not been developed at present. Other than                                         adverse effects are expected. The magnitude will depend on specific
                   onsite, project specific design mitigation, what "carefully applied                                          siting and extent of extrusion into the marine system. Also see
                   mitigation" is hinted at to compensate for unavoidable losses that                                           convnent 4.
                   will occur? Also see comment 1.                                                                         COMMENTS ON THE REPORT
               4.  Page 2, lSt Column, lSt paragraph: "Hence, it is reasonable to assume
                   that development can proceed on the coastal plain and generate similar                                  8.   Page 9, Chapter 1, INTRODUCTION:
                   minimal effects."   (emphasis _aUdedT_                                                                       It appears that leasing the 1002 area would not be contrary to any of
                   While it can be supported that minimal effects should occur on-shore,                                        the stated purposes of ANWR per ANILCA. None of these purposes would
                   there is no mention here that the likely required near-shore -warine                                         prevent reasonable development for oil and gas if Congress chooses to
                   structures (causeways) to support the on-shore development has                                               allow development.   If so, the regulatory framework and tools already
                   potential for more than minor impacts. This is based on our                                                  exist to allow reasonable development to occur in a timely manner
                   experience with the existing causeways, pdrticularily West Dock, and                                         under the Clean Water Act.
                   the monitoring program which has not yet concluded that minimal
                   impacts have occurred. Depending on the location and extent of needed                                   9.   Page 11, 2d column, Ist partial paragraph:    "The FWS carefully
                   docking facilities, impacts could be substantial. This should not be                                         monitored all activities and no adverse effects to fish and wildlife
                   overlooked in the impact analysis for the final IU02 H Report.                                               were observed."  (emphasis added)
               5.  Page 3, Ist column, Ist two full sentences:    "Only a few large                                             Although this statement may be correct in the context of the
                   lakes..." and "A few shallow thaw lakes dre found..."     (emphasis added)                                   paragraph, it could be easily misread as applying to all exploration
                                                                                                                                activities or to other times of the year. Suggest you add to the
                   While the meaning of a lake may be semantical and rests with the                                             sentence, 11 ... from helicopter supported surface exploration during
                   aefinition used for "lakes", "a few" is a relative term and not very                                         the summer months." The need for this is supported by the statement
                   descriptive of the ared. The Coastal plain has numerous open water                                           on page 118, Ist column, first partial paragraph, which indicates that
                   bodies used as habitat by various species of wildlife.      his is                                           a female polar bear may have been disturbed from denning in the area
                   discussed in some detail on pages 34 and 35 under sections on BIRDS;                                         by winter time activity. Although it is not conclusive that winter
                   SWANS, GEESE, AND DUCKS; AND SEABIRDS AND SHOREBIRDS where tundra                                            exploration activity was the disruptive influence, the discussion in
                   wetlands and their value are described. The discussion on use of                                             tnis section should mention the possible disturbance to denning polar
                   these areas infers that there is open water or emergent marsh type                                           bears from even a carefully controlled exploration activity.
                   wetlands present. Whether they are lakes or not is moot--they are
                   important aquatic resources (see page 36, Ist column, first full                                        10.  Paqe 12, 2d column. STANDARD FOR ENVIRONMENTAL PROTECTIUN:
                   paragraph). Using the word "few" tends to either under emphasize the
                   importance of their occurrence or to over emphasize them because they                                        This section discusses the implementation of the FWS mitigation
                   are scarce, depending on the perspective of the reader.     I recommend                                      policy.  The FWS is encouraged to fully implement needed mitigation
                   "a few" be deleted from the second quotation and a sentence added that                                       into their respective development decisions.     If the determination
                   points to their significant resource value that should be protected,                                         for needed mitiqation is to be deferred until site specific
                   consistent with reasonable development, if allowed to occur.                                                 development is proposed, then the FWS special use permit should
                                                                                                                                include all needed mitigation measures. Per 33 CFR 325.4(a)(2). the
              6.   Page 4, 2d column, FISH:                                                                                     stipulations on the FWS authorization would be conditional on our
                                                                                                                                permits in that "material changes in, or failure to implement and
                   No mention is made of the important year-round fishery that exists at                                        enforce such program or agreement will be grounds for modifying,
                   the Sadlerochit Spring drea. Although it is discussed on page 26. a                                          suspending, or revoking the permit." The FWS Should seek needed
                   sentence stating its existence should be added to the Executive                                              mitigation through their own specific authority for refuge management
                   Summary.                                                                                                     rather than rely on the Department of the Army (UA) permitting
                                                                                                                                process under the Clean Water Act. This point is not made clear in
                                                                                                                                the referenced discussions.

                                                      2

                                                                                                                                                                 3

                                                                                                                                  If this gravel covering is not removed before breakup, there is a
                I].   Page 12, 2d column, last paragraph:    "Leasing and operations would be                                     potential for permafrost degradation to occur.    The discussion does
                      subject to all appropriate Federal and State Regulations..."                                                nut mention restoration of the exploratory pad.    If you are to allow
                                                                                                                                  a persistent, multi-year pad to remain in place, then a minimum of b'
                      I agree with this statement that proposed developiaLrit would be                                            of gravel or equivalent insulation will be needed to minimize
                      subject to Federal regulations under DA control. We have in place                                           perinafrost degradation.  The section should include a discussion of
                      the necessary regulatory framework and "tools" we need to ensure                                            restoration for both single-year and multi-year pads.
                      reasonabl,e and timely development.                                                                   lo.   Page Bl,'2d column, MARINE FACILITY:
                12.   Page 13, Ist column, second sentence: "...and a
                      development/production proposal will require a site-specific EIS."                                          Tnis section does not include any discussion of the expected need for
                                                                                                                                  causeways to be constructed in order to allow movement of heavy
                      Due to the Corps' expected regulatory role with DA permits being                                            modules from the dock to shore. Access to a sufficient water depth
                      required for most future development, the Alaska District should be                                         will be required and it Is likely that a gravel causeway will be
                      included as a cooperating agency in future ElSs. As mentioned on                                            industries' choice. The need for beaches in these facilities has
                      page 25, WETLANDS, a major Portion of the 1002 14 area is wetlands*and                                      been established.  This is mentioned on page 101 under conseqences.
                      -is thus under Corps jurisdiction.                                                                          However, tnis has been a controversial issue with past developments
                                                                                                                                  and should be discussed in this section. Also see comments 4 and 7.
                13.   Page 13, Ist coluion. 2d paragraph: " ... all applicable Federal and
                      State regulations would apply ... unless they were superceded by the                                  17.   Pago 85, Ist column, SUBSEA MARINE ROUTES, 2d paragraph:     "A marine
                      legislation enacted by Congress...".                                                                        pipeline presents significantly higher environmental risks than does
                                                                                                                                  an onshore pipeline."
                      While Congress does have the discretion to "supercede" application    of
                      the Clean Water Act regulations, and others, to the proposed 1002 H                                         This statement as written implies that in all circumstances an
                      development area, the DA already has in place the necessary                                                 onshore pipeline is to be preferred over a subsea pipeline. Although
                      regulatory framework and mechanisms (tools) to fine tune or tailor                                          this statement can be supported for the ANWR situation where a
                      our regulatory rule to allow timely development to occur. Through                                           pipeline of approximately 150 miles is involved and would cross many
           n          auorooriate use of orourammatic general permits, an Advanced                                                unknown or uncertain areas within the ocean, it Is not necessdirfly
                      I@ent*ification of Uene-rally Suitable and Unsuitable Disposal Sites                                        true for shorter routes in areas where shore fast ice exist and the
                      process, an Abbrev Iated Processing Procedure, and/or a Special Area                                        likelihood of deep ice gouge is remote. With the current level of
                      Management Plan (SAMP) process, important natural resources cdn be                                          state-of-the-art technology, the potential for a significant leak of
                      protected while allowing reasonable environmentally sound development                                       oil (oil spill) or failure of a properly bedded, deeply buried subsea
                      to proceed an a timely oasis. As experienced in the Prudhoe Bay and                                         pipeline is,almost nil, especially one where proper leak detection
                      Kuparuk developments, appropriate authorizations can be expedited if                                        monitors are used and automatic shut off valves are employed.     If
                      site conditions allow and the Process will aid orderly, well planned                                        these conditions are present it is unlikely that even a small leak of
                      development with full public participation.                                                                 oil would occur for a long enough period of time to allow a
                                                                                                                                  significant amount of oil to escape. Although it is correct there
                14.   Pages 34 and 35, discussions on avifauna:                                                                   are presently no subsea pipelines in the Alaskan Arctic, there are in
                                                                                                                                  fact the equivalent of subsea pipelines presently in use in the
                      As previously mentioned in cominent 5 above, the discussions on                                             Canadian Arctic in the Mackenzie River oil and gas fields.     It
                      "Tundra wetlandsP infers the inclusion of tundra ponds and other open                                       appears to be just a matter of time before industry will choose the
                      waterbudies. This should he clarified and expanded upon in                                                  subsea pipeline as their preferred means of transportation from
                      appropriate paragraphs.   In particular, page 34, 2d column, 3d                                             off-shure oil prospects.   It is premature to suggest these proposals
                      paragraph presents a fair description of the value of the lagoon                                            would in fact present "significantly higher" environmental risks than
                      system, but it fails to mention the value of the tundra ponds and                                           present on-shure pipelines until we have an opportunity to analyze
                      drained lake basins. Although probably not as important as the                                              proposed design criteria.   It is also worthy of note that the subsea
                      lagoon system, they should at least be mentioned.                                                           pipeline alternative was the environmentally preferred alternative"
                                                                                                                                  in the EIS for the Endicott proposal in 1984. It was themnanimous
                16.   Page 76, Ist column, last sentence:    "Because of uneven ground, the                                       choice of Federal resource agencies over a quasi (or at least similar
                      pad-cover thickness may range from 6" at one edge to 31-5* at the                                           to) on-shore buried pipeline within a proposed gravel causeway.     The
                      opposite edge."

                                                       4

                   causeway is a maimade peninsula of )and that provides access and the
                   pipeline would be buried in it.  This discrepancy should be clarified
                   for the record in the final report and not left as an emphatic
                   statement that cannot be supported by rigorous andlysis at this tinte.

                   The refildinder of the discussion does accurately reflect the unique
                   engineering challenges industry will need to ineet to successfully
                   design a subsea pipeline. However, indications are that with
                   favorable economics, the technology exists today.

              18.  Page 9b, Chapter VI, ENVIRONMENTAL CONSEQUENCES:

                   This chapter is well written and presents a supportable scenario of
                   developmental consequencLs. In some respects, with the projected
                   development given, expected impacts are over estimated to some
                   degree. However, the consequences described are usuable as a worst
                   case scenario and is therefore appropriate for Congressional
                   consideration.

                   Conclusions drdWO are supported by past experience with similar
                   development in other areas.

                                                   6

                                                                                                                                                                                                                          2
                               United States Department of the Interior
                                             BUREAU OF LAND MANAGEMENT                         FWS/RF (918)                        Two critical points have been missed or under emphasized in the draft that
                                                                                                                                   should be expanded in the final report. These points are 1) the timing of
                                                    Alaska State Office                                                            ANWR oil production in relation to TAPS through put and 2) the most likely
                                                    701 C StrLvt, Box 13                                                           exploration scenario for ANWR, which is that there is an 80 percent
                                                 Anchorage, Alaska 99513                                                           probability that no development and production will occur from the coastal
                                                                                                                                   plain. The case in point I is that if production does not occur soon after
                                                                                                                                   the year 2000, TAPS oil through put will rapidly decrease causing
                                                                                                                                   transportation tariffs per unit to increase. This increase would reduce the
                                                                                                                                   probability of economic oil development in ANWR.

                                                                    February 6, 1987                                               A fold out plate or full page size     map of the topography and physiography of
                                                                                                                                   the 1002 area is recommended. It should have more detail than the map on
                                                                                                                                   p. 15 of the report. It would be helpful when the text describes 'locations of
                                                                                                                                   gravel sources or deep lakes. We also recommend showing the location of the
                  MEMORANDUM                                                                                                       KIC.well on the map on page 52 of the report, even if no
                                                                                                                                   geological/geophysical information is available.
                  To:       Director, United States Fish and Wildlife Service
                                                                                                                                   Our specific comments are as follows.
                  From:     State Director, Alaska
                                                                                                                                   Page      Paragrap
                  Subject:  Arctic National Wildlife Refuge, Alaska; Coastal Plain        Resource
                            Assessment and Draft Legislative Environmental Impact Statement                                        49        Paragraph I      Delete "for the Department" in the 3rd sentence.         In
                                                                                                                                   the same  sentence, substitute "of that information" for "of that work".
                  Thank you for the opportunity to comment on the draft of the Arctic National                                     49        Paragraph 4      Change the second sentence to read "T    *hese 26 prospects
                  Wildlife Refuge, Alaska, Coastal Plain Resource Assessment. Our general                                          were subjected to petroleum engineering and economic considerations resulting
                  comments are listed first, followed by page specific comments.                                                   in estimates of conditional recoverable resources."
          Am
                  In Chapter Three there are very few references in the bibliography that                                          50        Paragraph 2      We recommend restating the time period considered in
                  support the discussions on geology, geophysics, and geochemistry. Most of the                                    the second sentence.
                  references listed are related to the quantitative resource assessment and the
                  economic analysis. This is a problem because the text introduces new or                                          50        Paragraph 2      Delete the word "economically" in line 4 of the first
                  uncommon stratigraphic nomenclature (such as the Canning formation and Hue                                       sentence.
                  Shale) for the Brookian rocks with nothing relating them to previous
                  terminology.                                                                                                     50        Figure 111-2     The shading in this diagram is misleading. The black
                                                                                                                                   shaded areas on the left and right hand sets are not equivalent as the shading
                  Chapter Three also suffers from the Jack of geologic and geochemical         data.                               suggests because the histograms are not dealing with the same kind of
                  One plate shows interpreted seismic iines with minimal annotation. The well                                      information. Only the histograms on the right are from McCasin, 1986; the
                  @ross section (plate 4) shows none of the structural deformation. We suggest                                     histograms on the left are PRESTO outputs from BLM, Anchorage. The word
                  inclusion of a plate showing a composite of geological and geochemical data                                      "recoverable" should appear under the left side of the figure and in the
                  (attached) to compare and contrast the petroleum potential of each rock unit                                     statement after "Figure 111-2".
                  in relation to the other information.
                                                                                                                                   51        Paragraph 1      Delete the word "extensive" in line 4 of the first
                  Chapter Four contains a formal determination for Alternative A with respect          to                          sentence.
                  ANILCA, Section 810. We are not familiar with the USF&WS format for
                  Section 810 compliance, but from our review the determinations are unclear for                                   51        Paragraph 6      In the  last sentence, insert the word "reservoir"
                  two of the alternatives, B and C, :nd missing for Alternatives D and E. We                                       after "Furthermore,".
                  recommend that specific findings b made for each alternative.
                                                                                                                                   51        Paragraph a      This paragraph is unclear and,appears internally
                  Max Brewer of the US Geological Survey should be added as an author of                                           inconsistent.    It states that "these rocks are not considered prospective for
                  Chapter IV.                                                                                                      oil and gas." Yet the paragraph goes on to point out that there are oil and
                                                                                                                                   gas reservoirs northwest of ANWR in similarly described basement rocks which
                                                                                                                                   implies that they are or should be prospective for oil and gas.

                                                                                                     3                                                                                                             4

                51        Paragraph 9     "At least 6,500 ft. of carbonate rocks     . . . . . .  Is                           62       Paragraph 1     The text in the geochemistry discussion makes no
                or could  tectonic thickening involved?                                                                        attempt to relate thermal maturity to structural domain; i.e., nothing is said
                                                                                                                               to the fact that the outcrop samples from allocthonous rocks are al I
                51        Figure 111-4    The figure does not show the Sabbath Creek                                           overmature, and cuttings samples from autothonous blocks are mostly immature
                conglomerate (over 10,000 feet thick) and does not show the Pt. Thomson sands,                                 or mature.
                a major play. Also, we question whether the basement rocks are shown properly
                as the Ellesmerian overlays both the Katakturuk Dolostone and Argillite on the                                 64       Paragraph 5     The text implies that oils with 21' to 27* API gravity
                North Slope near the ANWR 1002 area.                                                                           and one oil with 44* API gravity have the same source.      Without other data,
                                                                                                                               this information would indicate two distinct oil types and possibly oil from
                54        Paragraph 3     Change the penultimate line, "if most of the                                         two sources.
                to read "if the prime reservoir Elleswerian rocks are largely missing from the
                eastern 1002 area, both the in place and recoverable hydrocarbon reserve                                       65       Paragraph I     Oil in the Pt. Thomson-Kemik should have oil with a
                estimates will decline significantly.                                                                          35* to 45* API gravity,  or as low as 18* API gravity and is supposed to have
                                                                                                                               the same source rock as  oil in the turbidites which was described as 21* to
                54        Figure 111-5    Well data show truncation of Ellesmerian west of      ANWR,                          27* API gravity.   It does not follow that the source rocks are similar as the
                however, outcrops south of ANWR show no truncation. Both are from                                              two API ranges do not overlap.
                allocthonous blocks.
                                                                                                                               63-69                    This section describes the seven plays, based on
                55        Figures 111-6 The truncations may be incorrectly shown. Seismic data                                 stratigraphy, and six prospects. "potential" objectives, but does not explain
                and 111-7 show the strike of truncation to be more north-south trending, and                                   why or why not the terms sometimes overlap or are entirely different.
                there is only one outcrop of the Sadlerochit Mountains which may be
                truncated. Truncations should not extend much further east of Marsh Creek.                                     70       Paragraph 6     The terms "probability of occurrence" and "geologic
                                                                                                                               risk factor" should be more clearly defined.
                58        Paragraph 3     Change "the sea oscillated back and forth" to "the      sea
                level fluctuated" or "the depositional centers moved across the area".                                         76       Paragraph 4     The estimate of 10 acres of ground covered by the pad
                                                                                                                               may be overestimated. The Brontosaurus welt on NPRA was drilled from an
                58        Paragraph 4     In the second line substitute the word "extensively"                                 icepad with ancillary structures which encompassed 3.5 acres.
                for the word "complexly". In the third line delete the word "complexity."
                Also, the Brookian rocks may be more complexly folded and faulted because of                                   76       Paragraph 6     The material excavated from the reserve and flare pits
                multiple phases of faulting rather than because they are largely incompetent.                                  is not necessarily ice-rich. The phrase "ice-rich' should be deleted.
                The older rocks have undergone fewer phases of deformation and are less
                deformed. (See also paragraph 7)                                                                               76       Paragraph 7     The water shortage situation may be overstated,
                                                                                                                               especially where drilling operations are concerned. This scenario does not
                58        Paragraph 5     Fhe reference, Plate 5, depicts seismic sections.       A                            account for possible high tech drilling fluids or the use of sea water for
                structure map would be a better reference.      Also, "what is called a                                        drilling versus fresh water. Since the large quantities of water may be
                fold-and-fault belt" we suggest be "called a foreland fold-and-fault belt".                                    required. low water availability exploration scenario could be presented.
                Finally, the sentence beginning "The thrust faults originate . . . . " should
                be changed to read "The north verging thrust faults originate at depth, tend                                   76       Paragraph 8     Drilling from shorefast sea ice implies that the
                to cross shales at low angles and cut up-section more abruptly in overlying                                    drilling is done offshore.   Are offshore sites included in the area considered
                sandstone and siltstone layers."                                                                               in the report?
                58        Paragraph 6     As noted for paragraph 5, a structure map would make a                               77       Paragraph 5     This discussion on multi-winter drilling methods
                better reference than the seismic map used.                                                                    should include the method used by Chevron for drilling the KIC well near
                                                                                                                               Kaktovik. This well was drilled from a wood and timber platform, which
                58        Paragraph 7     Change the first sentence to read "Seismic reflections                               provided a thaw-stable base during the summer months without using gravel.
                as well as outcrops indicate that Cretaceous and Paleocene rocks are generally
                much more deformed than either the underlying pre-Kingak or overlying                                          78       Paragraph 8     Drilling technology has continued to advance on the
                post-Paleocene section."                                                                                       North Slope. The angle of deviation has probably. increased from 0 to
                                                                                                                               45 degrees to 0 to 60 degrees, and the maximum practical angle for drilling is
                58        Paragraph 8     The Eocene rocks are "only moderately deformed" in the                               90 degrees or horizontal drilling. The horizontal drilling technique is used
                beginning part of the paragraph, but are dipping 60' at the end of the                                         for improved oil production and recovery and would surely be used in the 1002
                paragraph.   This does not clearly state that the structural deformation was                                   area if production occurs.
                episodic and not the same across the ANWR area.

                   99       Paragraph 9      The reader may benefit from a brief but more specific
                   discussion of the nature of the adverse effects of a significant water loss in
                   the area.

                   100      Paragraph 3      The "button up" method of abandoning a wellsite is
                   incomplete and does not consider newer methods. Five feet of fill is required
                   in order to insulate the pit contents sufficiently to guarantee freezeback.
                   However, if revegetation can be accomplished over the reserve pit, less fill
                   is required for insulating the pit contents, due to the insulating properties
                   of vegetation. Reclamation'of the Brontosaurus wellsite included filling in
                   the reserve pit with excavated material, making sure that the original top
                   organic layer was put on last, thereby facilitating revegetation efforts.
                   Revegetation of the pit has been successful in the sort term, and it appears
                   that freezeback of the pit contents has been achieved. In any event, even if
                   freezeback is.not accomplished for a reserve pit, filling it with overburden
                   will prevent the formation of a long term pond with subsequent breaching of
                   the berms and loss of fluids to the tundra. The experience on NPRA with the
                   Button up technique may be limited because it was not common practice at that
                   time. The pit at the east Teshekpuk site was covered, and, although some
                   settling occurred. the site is the only one recently tested that has little to
                   no contamination locally. Other open reserve pits had local contamination
                   that do not meet EPA water quality criteria.

                   101      Paragraph 3      Part 2 should be expanded to include the     potential for
                   gravel mining adjacent to river beds affecting water recharge to       the river
                   bed. This would effect any fish eggs or overwintering fish that        may be found
                   at these sites.

                   102      Paragraph 7      Foam insulation can break down and erode     to smaller.
                   pieces that can be very   difficult to effectively remove from the     tundra.

                   145      Stipulation 3    We believe ice pads should be considered     preferable to
                   gravel, foam and timber   pads.

                                                                       Arthur Hosterman
                                                                       Chief, Office of 4anagement,
                                                                         Planning and Budget
                                                                       Acting

                   I Attachment:
                      I  Composite Geochemical Profile for ANWR (I p)

                                                           COMPOSITE f-EOCF1c*M:CA1. PROFILE FOR ANWR

                         VML CUTTIKGS MC            MJTCRCP TEIC          WCAMNS/KEROWN           TAI        VURMITE Rfr-ECTANCE  HYDRUGE4 1NDEX       GEMMC P[3-nrA'-
                                w                       W
                       0    5   10   15         a   5   io   15  20       8093 94          .1   2    3   4
                        TP, 11                                                              -Till I'              !I
                         4o
                                                                                       v

                                                                                                                o

                                                                                       v

                                                                                       v

        OD

                                                                                       mv
                                                                                                                                                                                 Em
               j3
                   :7
                                                                          a  A

               u

                                                                                                                       +
                                                                                                                     c%

                                                                             f
                                                                                                                -o

                                                                                                                                  -1-outcrop data + ou'Lrop data 1000 pp.
                                                                                                                                                                                            TOTALGC

                                                                                   PI A'F-      rnmDnz'Tc'   rrir,i7m-rA' Ppnr7,, r r-nQ ANY0

                             U.S. ENVIRONMENTAL PROTECTION AGENCY

                                                     REGION x

                                                 1200 SIXTH AVI NOT.
                           10               SEATTIL. -WASHING TON 91;    101
                07         1                                                                                                                                                2

                                                   February 6, 1987                                                                      In reviewing the Legislative EIS, EPA did not expect the document to
                   REFIV TO                                                                                                                                                                    -specific impact
                   @JIN Of:   M/S 635                                                                                               contain the level of detail normally found in project
                                                                                                                                    statements. That level of detail would be provided later in subsequent impact
                                                                                                                                    statements if Congress Were to approve, as a matter of policy, that the
                   Honorable William P. Horn                                                                                        leasing should proceed. However, for Congress to make its policy decision,
                   Assistant Secretary for Fish    and Wildlife and   Parks                                                         more information and discussion are necessary now.        Congress, EPA, and other
                                                                                                                                    regulatory agencies need to be fully aware of the environmental implications
                   United States Department of the Interior                                                                         of oil development in the refuqe.
                          C Streets, NW
                   Washington, D.C. 20240                                                                                                Because of the incomplete discussions in the Legislative EIS. EPA is
                                                                                                                                    rating the document in the following manner:
                   Re:. Arctic National Wildlife Refuge, Alaska,
                        Coastal Plain Resource Assessment                                                                                  Alternative A (full leasing): EO-2 (Environmental
                                                                                                                                         Objections-Insufficient Information)
                   Dear Mr. Secretary:
                                                                                                                                           Alternative B (limited leasing): EC-2 (Environmental
                        This letter and the accompanying enclosure provide the U.S. Environmental                                        Concerns-Insufficient Informat6n)
                   Protection Agency's comments on the draft Legislative Environmental Impact
                   Statement concernin the proposal to allow oil exploration, development and                                            - Alternative C (further exploration):       LO (Lack of Objection)
                   production within I Arctic National Wildlife Refuge.
                                                                                                                                         If the Department of Interior has questions about EPA's comments, please
          _n            EPA believes the Department of Interior needs to revise the Legislative                                     feel free to direct members of your staff to contact me or Alvin L. Ewing,
          AL       EIS so that our agency would have a better understanding of the environmental                                    FPA'c acci@tant rpninnal adminicteat- in Anchorage. We look forward to
          W1       impacts. A number of impacts are not discussed fully, -and some foreseeable
          (D                                                                                                                        answering your questions and helping you prepare a final Legislative EIS that
                   impacts are not discussed at all.                                                                                will enable Congress to make a reasoned decision.
                        There is no.discussion in the Legislative EIS of air quality                                                                                           Sinc re
                   deterioration, the effects of noise upon wildlife in the refuge, or of the
                   consequences of marine transportation facilities on fish populations. The
                   Legislative EIS acknowledges that water supplies may be inadequate to support
                   all the activities associated with oil develo ment within the refuge, but does                                                                               04 G -Rus ell
                   not discuss how overcoming these shortfalls Ml affect the available fresh                                                                                   Regional Adm n sitrator
                   water resources.
                                                                                                                                    Enclosure
                        EPA also believes more discussion is needed about impacts on the refuge's
                   core caribou calving area. The core calving area may be of concern to
                   Con ress when it considers the development proposal becausethe area has been
                   des?gnated by the'U.S. Fish and Wildlife Service (USFWS) as a unique and
                   irreplaceable wildlife habitat. Since it is clear from the LEIS.that the pro-
                   posal, if adopted, will result in loss of habitat, we believe that Congress
                   needs a more thorough discussion of the consequences of full leasing
                   compared with leasing on a smaller geographical scale, and how the proposal
                   relates to the USFWS Mitigation Policy, particularly concerning Category I and
                   Category 2 habitat.
                                                                                                                                                                               'i"    e
                                                                                                                                                                         Lkob
                                                                                                                                                                                      G       e 1
                                                                                                                                                                                      ai      n1st     1@r

                                                                                                                                                                      2

                                                   Review  Comments
                                                                                                                                            framework for the assessment of the terms "unnecessary. and
                                                                                                                                            significant.* What criteria are used to determine if impacts are
                                                                                                                                            unnecessary or significant? A discussion of the criteria used to
                        Our review has identified the following general informational needs which                                           establish either condition or a definition of each term, if
                  we believe are necessary for informed decision making.                                                                    possible, would facilitate the review of this draft LEIS and
                                                                                                                                            support the rationale for selecting a preferred alternative.

                  1. Analysis/Assessment: Clarification is needed in the assessment of the                                                The final LEIS needs an air quality disciission.   It should include
                  effects of  the alternatives addressed in this document. Some examples of                                               present estimates of the maximum mass emission rates for oxides of
                  areas that  need further analysis are:                                                                                  nitrogen, total suspended particulates, carbon monoxide, non-methane
                                                                                                                                          hydrocarbons, sulfur dioxide, and lead. as well as any potentially
                        -     The draft LEIS acknowledges (p. 6. Executive Summary) that there                                            h:zardous pollutants listed in EPA's Prevention of Significant
                              will be indirect effects from the proposal. Either of the leasing                                           0 terioration (PSD) regulation [40 CFR51.24(b)(23)(1)] or covered by
                              alternatives could cause increased pressure to develop the Canadian                                         the National Emission Standards for Hazardous Air Pollutants
                              Arctic, state lands to the west of the Arctic National Wildlife                                             (40tCFRtPart 61).
                              Refuge (ANWR), and portions of the Beaufort Sea outer continental                                           In addition, any existing ambient air quality data for the 1002 area
                              shelf (OCS). The potential development infrastructure in the 1002
                              area could provide the major impetus for development in these                                               should be presented and compared to the Alaska ambient air quality
                              adjacent areas. These Indirect effects are not truly discussed In                                           standards (AAAQS). Worst case ambient air quality modeling results,
                              the environmental consequences section.                                                                     using a suitable EPA approved model. should also be presented and
                                                                                                                                          discussed in the final LEIS. Modeling results should be compared to
                        -     Cumulative effects should he more   clearly defined and included as a                                       the AAAQS and available PSO increments. Mitigation measures
                              separate section with the report. For example, the report should                                            sufficient to show attainment of all standards should be presented.
                              address the cumulative effects of   existing North Slope facilities                                         Any pollutant emitting activity would need to comply with
                              combined with those being assumed   for ANWR.                                                               requirements of the Alaska State Implementation Plan.
                        -     Clarification is needed about the   relationship between displacement                                       The draft LEIS does not provide any discussion of the potential noise
                              or distribution change of caribou   versus population changes of                                            levels associated with exploration, development, and production..
                              caribou.                                                                                                    Noise can cause adverse impacts to many of the biological
                                                                                                                                          populations. Although disturbance is incorporated into the
                        -     The analysis of subsistence impacts Is focused primarily on                                                 environmental consequences discussion, the final LEIS should provide
                              Kaktovik with only general and brief mention of other native                                                a general discussion of present noise levels and the potential noise
                              settlements. The draft LEIS indicates that the primary reason for                                           levels associated with the oil and gas exploration, development, and
                              focusing on Kaktovik is its proximity to the 1002 area. Settlements                                         production.,
                              located further away (Arctic Village, Venetie Fort Yukon, and Old
                              Crow in Yukon Territory, Canada) are also   be Aependent upon the                                           A more detailed analysis of water supply is needed. Under the
                              caribou herds. According to the draft LEIS, residents from these                                            pro'posed development alternative. substantial quantities of fresh
                              settlements harvest the caribou when they have migrated out of                                              water may be required for construction of ancillary support
                              1002. However, the draft LEIS does not examine the dependence of                                            facilities, transportation systems, exploration drilling, and field
                              these inland settlements on caribou. Because of their inland                                                production facilities, including ice roads, ice airstrips and
                              location the residents of these settlements could he more                                                   drilling pads. The draft LEIS notes that water sources in the 1002
                              dependeni on the caribou since they do not have easy access to                                              area include surface resources and ephemeral lake sources.
                              coastal fishery resources. Thus, the final LEIS should fully
                              examine the effects on the inland settlements of a decline or                                               While the draft LEIS clearly states the potential for a major
                              change in distribution of caribou.                                                                          shortfall of natural water sources necessary for the construction of
                                                                                                                                          ancillary features and drilling needs, the document does not
                              In many instances, the draft LEIS uses the phrases "unnecessary
                              adverse effects' and "significant unavoidable losses" or
                              .significant adverse Impacts.' The final LEIS should provide some

                                                      3
                                                                                                                                                               4

                          adequately discuss the potential impacts of the schemes proposed to
                          supplement those resources. A generic discussion of the options for                                      The existing regulatory Process including examples of how existing
                          useahle water collection or production should be included in the                                         regulations are applied,on the North Siope for oil and gas
                          final recommendation document. In addition, an assessment of the                                         deveiooment.
                          effects on habitat of using the available water is needed. How might
                          the surface hydrology be changed, and how will that change affect                                        The Section 404 program, in particular the success  of the Abbreviated
                          waterfowl, shorebird and other habitats?                                                                 Permit Process. This procedure was specifically designed to expedite
                                                                                                                                   oil and gas development on the North Slope.
                          The notential effects of marine transportation facilities such as
                          docks, causeways, and staging areas on the near shore and on shore                                       The potential applicability and use of the advanced identification
                          environments need to be identified and assessed. Such analysis                                           process (40 CFR 230.901 for advanced planning.
                          should address individual imDacts, as well as cumulative effects,
                          with existing North Slope facilities, such as the causeways built                                        The draft.LEIS mentions that "deferred leasing" will be used to delay
                          into the Beaufort Sea. There should also be a discussion of whether                                      leasing in more sensitive habitat areas, the idea being that delaying
                          the deletion or change of a suggested marine scenario may alter the                                      leasing will allow more time for advancements in either mitigation
                          viability of any of the alternatives.                                                                    technology or oil and gas exploration, development, and production
                                                                                                                                   technology. The final LEIS should provide a more detailed discussion
                 2. Mitigation:   Clarification is needed to identify the net effect of                                            about what it means, how it will work, and what parts in the 1002
                 proposed mitigation. Each alternative component should he outlined without                                        area may be subject to this leasing approach.
                 mitigation, with mitigIation, and the two compared.                                                               We believe that the LEIS will be  the first in a number of
                     -    Any proposed mitigation that is being considered in the assessment   of                                  environmental documents that will examine the impacts and
                          inpacts, to offset negative effects, should a) be clearly identified,                                    consequences of the proposed oil  resource recovery activities in the
                          b) have effectiveness studies referenced, and c) identify requlatory                                     IM area of the Arctic National    Wildlife Refuge. It is our
        _n                responsibility (strategy) for implementation.                                                            recommendation that specific EIS  documentation for exploration,
        6)                                                                                                                         leasing, and production from oil  reserves in the area, and
                     -    Interrelationships between mitigation measures and subsistence uses                                      construction Of pipelines or marine docking facilities be performed.
                          should be identified and assessed.                                                                       To effectively address and protect the natural resource value in the
                                                                                                                                   1002 area, the USFWS should approach evaluation of these activities
                 3. Wetlands: Virtually the entire 1002 area can he classified as wetlands.                                        in a coordinated manner.  Such an approach would more clearly .
                 It appears the Legislative EIS only considered direct impacts from                                                delineate the cumulative impacts of the various interrelated aspects
                 construction and other development activities. Secondary and cumulative                                           of oil exploration and development in ANWR.
                 impacts such as those associated with road and pad construction should be
                 discussed in generalterms to identify their impact on the larger scale
                 hydrologic functions of wetlands in the 1002.area.

                 4. Regulatory Processes: The discussion of the regulatory process and its
                 relationshins to the alternatives needs to he exoanded. As charged in Section
                 1002 of AMILCA (p. 12, Executive Summary), the LEIS should Provide an
                 assessment that suoports the Secretary's recommendations and "...what
                 additional legal authority is necessary to ensure that adverse effects ... are
                 avoided or minimized." The discussion on this point is unclear, vis-a-vis,
                 the need for additional legal authority. Further clarification i.s needed
                 through discussion and assessment of:

                                                                                                                                      2

                                                                                                     habitat alteration in the Canadian Arctic and other parts of
                                                                                                     Alaska, might affect the size, age/sex structure, and productivity
                                                                                                     of the Beaufort Sea polar bear population;
                                                  6 February 1987                                         -- it is not known whether frequent or continuous V88B61
                                                                                                     operations would cause bowhead whales or other marine mammal
                                                                                                     species to abandon important habitat areas or lower their
           The Honorable William P. Horn                                                             reproductive fitness;
           Assistant Secretary for
                 Fish and Wildlife and Parks                                                              -- because the 1002 area has not been fully explored by means
           Department of the Interior                                                                such as exploratory drilling, reliable estimates cannot be made of
           18th and C Streets, NW                                                                    the nature and extent of the recoverable oil and gas resou    .rceS
           Washington, DC 20240                                                                      located there;

                                 Attention: Division of Refuge Management                                 -- because the nature and extent of the resources are not
                                                                                                     known, it cannot be precisely determined where or how much
           Dear Mr. Horn:                                                                            development is likely to occur in the area;

                 The Marine Mammal Commission, in consultation with its                                   -- an annual sea lift would be the most economical means of
           committee of Scientific Advisors on Marine Mammals, has reviewed                          transporting supplies, production/support modules, and other
           the Arctic National wildlife Refuge Coastal Plain Resource                                cargo. It therefore would be necessary to construct one or more
           Assessment. This report was prepared under section 1002(h) of the                         port facilities. At present, however, it is not possible to
           Alaska National Interest Lands Conservation Act (hereinafter                              determine precisely what or where port facilities would be'
           referred to as "ANILCAII). 16 U.S.C. �3142(h). It assesses the                            required; and
           fish and wildlife resources and oil and gas potential of the
           Arctic Refuge coastal plain (hereinafter referred to as the 111002                             -- development of port and other support facilities likely
           area") and sets forth recommendations to Congress for future                              would encourage other activities and additional exploration and
           management of the area. A legislative environmental impact                                development activities in adjacent offshore and onshore areas.
      r%3  statement has been integrated into the Assessment. The Assessment
           recommends that Congress open the entire 1002 area to oil and gas                              In consideration of these and other uncertainties concerning
           leasing, subject to environmentally protective restrictions.                              the nature, extent, and effects of exploration and development
                                                                                                     activities in the 1002 area, the Marine Mammal Commission believes
                 The Assessment indicates, among other things, that:                                 that additional studies and assessments should be conducted before
                                                                                                     the 1002 area is made available for oil and gas recovery and
                 -- fourteen species of marine mammals, including walrus,                            utilization. As discussed in greater detail below, we consider it
           beluga whales, polar bears, and the endangered bowhead whale                              necessary to conduct further analyses of the potential impacts,
           occur in or near the 1002 area and could be affected by oil and                           including cumulative and indirect effects, of exploration and
           gas exploration and development in that area;                                             development on marine mammal populations, especially polar bears,
                                                                                                     located in and near the 1002 area. Similarly, additional
                 -- many of the potentially affected marine mammal and other                         assessment of the impacts of the development scenarios on
           wildlife species are hunted by Alaskan Natives for subsistence.                           subsistence uses of the affected marine mammal populations appears
           purposes and the availability of these animals could be affected                          necessary. If exploratory drilling is to be conducted as part of
           by the proposed action;                                                                   the further assessment, we believe that it should be undertaken in
                                                                                                     a manner that would not interfere with these studies or
                 -- activities associated with exploration and development                           compromise the wildlife and other resource values that are subject
           could cause female bears to avoid or abandon important denning                            to the ongoing impact assessment.
           areas;                                             I                                           Section 1002 provides for a cautious, step-by-step analysis
                 -- those activities also could attract polar bears and                              of the fish and wildlife resources of the coastal plain of the
           jeopardize the welfare of both oilfield workers and bears;                                Arctic Refuge.' Consistent with that approach, the commission
                                                                                                     believes that further studies are necessary to determine the
                 -- it apparently is not known how many polar bears den     in or                    numbers of polar bears, bowhead whales, and other species that
           near the 1002 area or how disturbance and habitat alteration in                           could be affected by exploration and development, identify the
           the 1002 area, combined with subsistence hunting, disturbance and                         nature of those impacts, establish protective restrictions and

                                                 3                                                                                             4

              mitigating actions (if exploration or development is to occur),                               increased female mortality, the Assessment only addresses the
              and develop monitoring programs to detect possible unforeseen                                 prospect for such a problem developing within the 1002 area. As a
              effects before they reach unacceptable levels. In addition, if                                result, no information is provided on whether or not female polar
              exploratory activities can be authorized consistent with the                                  bears will experience population pressures and mortality as a
              resource protection guidelines described in this letter, more                                 result of industrial activity in other areas. Moreover, although
              reliable estimates of the quantities and locations of recoverable                             the Assessment notes on page.118 that a decline in polar bear
              oil and gas resoruces would be acquired. As a result, it would be                             natality is not likely to affect the species' overall survival "so
              possible to better determine how the resources of the coastal                                 long as similar intensive developments did-not occur along the
              plain of the Arctic Refuge can best be utilized in fulfillment of                             entire northern coast of Alaska and Canada," no information is
              the objectives specified in section 1002 of ANILCA, whether that                              provided on the amount of development that could occur outside         of
              be through wilderness designation, full leasing and development,                              the 1002 area.
              or some other alternative. In our opinion, there is insufficient
              information to make that judgment at this time.                                                     The Commission considers this information essential for an
                                                                                                            adequate review of the environmental consequences and subsistence
                                         GENERAL COMMENTS                                                   impacts of the alternatives presented in the Assessment. In
                                                                                                            addition, this information should be available to Congress when it
                   In both ANILCA and the Assessment, it is pointed out'that                                considers what action to take with respect to the future of the
              marine mammals are resources of special concern in the 1002 area.                             1002 area. If the analysis of cumulative impacts demonstrateg@
              As a general matter, and with respect to marine mammals and                                   that the Beaufort Sea region will be subject to intensive oil and
              subsistence uses of marine mammals in particular, the Assessment                              gas activity, it may be necessary to postpone or prohibit
              does not adequately analyze the possible cumulative impacts of oil                            exploration and development in the 1002 area to provide a
              and gas exploration, development and transportation along the                                 protected area for wildlife resources.
              coast of the Beaufort Sea. In addition to the activities that may
              occur in the 1002 area, a comprehensive assessment of the                                           In addition, consideration should be given to reasonably
              environmental consequences of the Recommended Action must         take                        foreseeable indirect effects. For example, no consideration is
              into account existing and reasonably foreseeable oil and gas                                  given to the effect that disturbances and Oil spills could have on
                                                                                                            the food web that is relied on by polar bears and other marine
        -n    activities in the region. This kind of analysis is required          by                                                                                         in
              the Council on Environmental Quality National Environmental Policy                            mammaiLs. Other indirect effects that should be evaluated           clude
              Act regulations and case law.                   0 C.F.R. 6�1502.9,                            possible changes in the behavior of seals and bowhead whales
                                 1508.25; Kle 'ee: 1                            390                         caused by industrial activity and marine traffic and the manner in
              1502.16, 1508.7,                 pe v . fer'a'Club, 427 U.S.
              (1976); North Slope Borough v. Andrus, 642 F.2d 549 (D.C. Cir.                                which these changes would effect the availability of the affected
              1980).                                                                                        populations for subsistence uses. Such an analysis is required by
                                                                                                            40 C.F.R. 11502.16, and we recommend that the required information
                   To satisfy this requirement, the Assessment should address                               be obtained and analyzed.
              the environmental impacts of industrial activities that presently
              are occurring and are reasonably foreseeable in the National                                        Finally, if additional seismic or other exploration is
              Petroleum Reserve - Alaska, Prudhoe Bay, state lands subject to                               undertaken, it should be designed and carried out in a manner that
              leasing and-development along the Beaufort Sea, and areas in         the                      would not interfere with the additional wildlife assessments being
              Canadian Beaufort that have oil and gas potential. If the                                     conducted by the Fish and Wildlife Service and other parties. In
              resource assessments necessary to analyze these cumulative impacts                            this regard, if it has not already been done, the Commission
              have not been conducted, this information should be required to be                            believes that it would be desirable to authorize a single
              obtained as part of the additional studies that we have                                       exploratory survey of this area, rather than allowing each
              recommended.                                                                                  interested entity to conduct separate surveys. In addition, we
                                                                                                            believe that the data obtained from this survey should be made
                   The Assessment's discussion of the impacts of the        Recommended                     available to and analyzed by the Department of the Interior. The
              Action on polar bears provides an example of why analysis of                                  resulting estimates of possible resource levels should be made
              cumulative effects is necessary. Page 118 of the Assessment                                   available to Congress and the general public. Furthermore, any
              states that, 11[b]iologists believe that the Beaufort Sea                                     exploratory work should be regulated and monitored by the
              population can sustain little, if any, increase in mortality         of                       Department so as to minimize environmental impacts.
              females-begmnsei,pppulAtiop qi4rveys and calculations show that the
              number of animals dying each year is approximately equal to the                                                          SPECIFIC COMMENTS
              population increase from reproduction." Even though the Beaufort
              Sea polar bear population is found throughout areas of existing                                     Page 1, column 1,                   ar:,r:ph -- For purposes of
                                                                                                                 ulating the "Net NaMnHmp          dc n fits" of
              and potential oil and gas activities that could result in                                     calc                      t       E12n:                    the projected.

                                                5                                                                                                    6

            recoVerable resources in the,1002 area, the Assessment uses values                                  be 100 or   more miles offshore. The resulting expanse of water
            of $33 and $40 per barrel as the price of oil. The present price                                    cannot be   correctly termed a shore lead.
            of oil is substantially below these estimates. As a result, it
            appears that the benefits of developing the 1002 area have been                                           Page  33, Cold=202       h complete paragraph -- This discussion
            overestimated.                                                                                      should be   expand        tAlcate how polar bears are rprotected"
                                                                                                                under the   Marine Mammal Protection Act. Such a discussion should
                  Pages 12  - 13, column    1, c        _rparagrao --- This                                     emphasize   the prohibition on taking (including harassment), the
                                   t th .    ,gi:r
                                                  gy
                                                    tRe
            paragraph states tha                        . nvIronmental impact                                   goal of the Act to restore and maintain marine mammal populations
            statement will suffice for      initial leasing and that future                                     at their optimum sustainable population levels, and the
            development will be tiered      on the present document. As noted in                                subsistence opportunities that are provided to Alaskan Natives.
            the general comments, this      document does not address the possible                              Because these requirements apply to all marine mammals, it may be
            cumulative effects and some of the important indirect effects of                                    useful to.insert this discussion at the beginning of the Marine
            oil and gas activity in the Beaufort Sea area. Until the                                            Mammal section on this page.
            information is incorporated into the document, it should not be
            used for lease issuance or other decision-making actions. In                                              Page 34, column 1, 1                        rip   -- This paragraph
                                                                                                                states that bearded seals           191:1
            addition, it should specify the actions that will be taken at the                                                                 B:r:o'c    f!-yR:r.:Zc atted with the pack ice
            leasing, exploration and development stages to ensure compliance                                    edge throughout the year. This statement is not accurate.                       ..
            with the requirements of section 7 of the Endangered Species Act.                                   Bearded seals are widely distributed over the shallow continental
                                                                                                                shelves of the Bering, Chukchi and Beaufort Seas.
                  Page 13, columnM1ti.1:tMc
                                             .=let
                                                    P;op
                                                        t:r
                                                          gloph -- The EndangerecA
            Species Act and the                                  Act should be added                                  :ag:JY34                      0             r h   __  This paragraph
                                                                                                                                                 c ll;t:cp rN           t Kaktovik.
                                                                                                                                              4:hwha
            to the list of statutes that apply to Federal oil and gas                                                               Whhnc           1 n     M
                                                                                                                refer         toc:ub.
            activities in Alaska.                                                                               Discussion should be added concerning subsistence activities at
                                                                                                                other-locations that could be affected if whales are adversely
                               1'm 1' let com lt'       parygph -- The Convention                                ffected by activities in the 1002 area. The same applies to the
                        Ntnc                            Spec     of Wild Fauna and
            an InfMat        .10 Md, in Edang' .. d                                                             :nalysis of subsistence impacts of other migratory wildlife
            Flora should be added to this discussion.                                                           populations that move outside of the Arctic Refuge. This approach
                                                                                                                has been followed for analyzing the effects on caribou (Bee, e.g.,
                  Page 33, column 1, 3rd complete paragraph -- This paragraph                                   page 39, column 1, 2nd complete paragraph), but not for bowhead
            indicates that 87% of the polar bear dons located in 1983-85 were                                   whales, seals and polar bears.
            offshore and that the most consistently used land denning areas
            were on and adjacent to the 1002 area. It does not indicate:                                              Page 39, column 1, lst     co            r        -- The subsistence
                                                                                                                                                   S;:11:: P
                                                                                                                      --lonsof the Endanger                 A: agraph
            what onshore and offshore areas were-surveyed; how dens were                                        provis                          ad             t and the Marine     Mammal
            located; whether dens that were located represent all, a known                                      Protection Act should be included in        this discussion.
            proportion, or an unknown proportion of the dens in the area
            surveyed; whether the proportion of bears denning onshore and                                             Pages 81 - 82,                 aragraph -- This paragraph
                                                                                                                                        c ry
            offshore is affected by ice and weather conditions or other                                         indicates that two aHnoRriplities           may be necessary underthe.'
            variables; whether exploration and development activities in                                        full leasing and development scenario. The two sites ident:ified
            Prudhoe Bay and other areas in the Alaskan and Canadian Arctic may                                  - Camden Bay and Pokok Lagoon -- also are known polar bear denning
            have resulted in more offshore denning; and how reproductive                                        sites and may be important bowhead feeding areas. The likelihood
            success might be affected by den location.                                                          that these two sites would be developed.,highlights the need for
                                                                                                                more detailed assessment of both polar bear and bowhead behavior
                  Without this information, it is not possible to make a                                        and habitat requirements. In addition, it suggests the need to
            meaningful assessment of the possible effects of the alternative                                    consider alternative locations for these activities. This is
            development and exploration scenarios on polar bears. Thus, a                                       especially important with regard to        'the requirements of the
            more complete description and evaluation of the existing                                            Agreement for the Conservation of Polar Bears, which directs
            information and uncertainties concerning denning locations and                                      member nations to take special steps to protect polar bear denning
            requirements should be provided. if information essential to such                                   locations. As noted an page 27 of the Assessment, section 303 of
            an assessment is not available, the necessary research and data                                     ANILCA requires that the.Arctic Refuge be managed to fulfill
            gathering should be conducted.                                                                      international treaty obligations. The Assessment should discuss,
                                                                                                                either here or in the Environmental Consequences section, how this
                  Page 33, colU520tt3                 ecp::aqr@ph -- This paragraph                             Treaty obligation and the concomitant duty imposed under ANILCA
                                           r:ac?:P!:: 0     red                                                  ould be satisifed with regard to the polar bear dens at Camden
            states that the Bea            S                    year round. This is                             W
            not accurate. During the summer, the southern edge of the ice can                                   Bay, Pokok Lagoon and elsewhere in the 1002 area.

                                            7                                                                                      8

                                                                                                    to some of the information gaps and concerns identified elsewhere
                           la.ble VI-1   This table defines long- and short-                        in this letter, the Commission regards the conclusion that "only
             term MUN         mpacts that last more than 20 years and less than                     one or two bears" would be excluded to be speculative.
             20 years, respectively. We believe that an effect that lasts up
             to 20 years cannot be considered short-term. A more appropriate                            On 25 April 1986, the Council on Environmental Quality
             approach would be to define short-term effects as those that last                      published a revised regulation to govern the consideration of
             for up to two years, intermediate-term effects as those that last                      issues for which there is incomplete or unavailable information.
             up to 10 years, and long-term effects as those that last more than                     51 Fed. Reg. 15,618 - 15,626. That revision to 40 C.F.R.
             10 years.                                                                              �1502.22 requires that impacts that have a low probability of
                                                                                                    occurrence but catastrophic consequences if they do occur should
                  In addition, neither the text of the Assessment  nor the                          be evaluated if the analysis is supported by credible scientific
             Table indicate what is meant by the terms "widespread," @local,ll                      evidence. 51 Fed. Reg. 15,625. The Commission believes that the
             and "considerable severity." To provide a more meaningful basis                        exclusion of additional polar bears has a sufficient degree of
             for judging what the Department of the Interior considers to be                        probability.and adverse environmental consequences to require
             major, moderate, minor, and negligible effects, these terms should                     analysis in the Assessment and recommends that appropriate steps
             be defined.                                                                            be taken to address this possibility, through additional research
                                                                                                    (if necessary) and revisions to the document.
                  Page 118, column 2, Mitigation -- This section should be
             expanded to nclude the following mitigating actions:                                       Page 1'.9.- column 2  onclusion -- This paragraph states that
                                                                                                    the behavior of IIdolphEnLsC, porpofses and seals in coastal marine
                  1)  Workers in the area should be instructed on polar bear                        habitats with high levels of industrial activity and marine
             behavior and habitat concerns and the procedures to use when bears                     traffic" suggests that behavioral changes by marine mammals using
             are encountered.                                                                       the Arctic coast would be minor as a result of development in the
                                                                                                    1002 area. Although it is true that some dolphins, porpoises and
                  2) Bears that come into contact with camps And development                        seals are able to live in areas with relatively high levels of
             sites should not be allowed to become habituated and lose their                        human activity, it does not necessarily follow that Arctic seals
              ear of humans. When possible, they should be frightened and                           and whales, which have had relatively little exposure to such
                                       by u-swe Of -0 e-now machine or helicopter.                      -Itles- also would be - naffected.
             ""I'M'n       nw" e"a h"
             In a d   o , e count rs s ould be discouraged by use of trip-wire
             alarm systems and other polar bear deterrents.                                             Page 127, column 1, Subsistence Use -- As noted above in our
                                                                                                    comment on Page 34, column 1, 4th complete paragraph, the
                  3) Seismic and exploratory surveys should be coordinated and                      Assessment should be revised to address the impacts on subsistence
             limited to the number necessary. Repetitive surveys by                                 uses of marine mammals in villages outside of the Refuge. This
             independent companies should be avoided.                                               would include, but is not necessarily limited to, Barrow and
                                                                                                    Nuiqsut.
                  The final sentence in this section, which states that only
             Natives may kill polar bears, is not accurate. There is limited                            I hope that these comments are useful. If you have any
             authority,under the Marine Mammal Protection Act for the lethal                        questions, please contact me. The Commission looks forward to
             taking of bears by government officials when necessary for the                         working clos.sly with the Service in addressing these concerns and
             welfare of the animal or for public health and welfare. 16 U.S.C.                      other marine mammal issues associated with the 1002 program.
             �1379(h). In addition, bears may be taken for scientific research
             and public display purposes. 16 U.S.C. 91371(a)(3). This
             sentence should be revised to read: "Except for purposes of
             scientific research or other authorized takings under the Marine                                                             sincerely,
             Mammal Protection Act, nuisance bears would have to be trapped and
             relocated, except in extreme situations where other methods of
             humane taking are necessary for either the welfare of the animal
             or the protection of the public health and welfare."                                                                         Robert J. Hofman, Ph.D.
                                                                                                                                          scientific Program Director
                  P:!Tuj1:j_ Z;lumn 2, Conclusion -- This paragraph states that
             the Ile       n   only one or two bears from areas consistently
             used for denning would be a moderate impact on that segment of the
             Beaufort Sea population . . . . 11 Lacking is a discussion of what
             the impact would be if more bears were excluded. In addition, due
                                   9

                            11111led slaws Depal              -111 1& lilt- hm-1101,                                                        COMMENTS BY THE MINERALS MANAGEMENT SERVICE     ON
                     6
                                         \11\1- RALS \IA\ \GI Nil \ 1 SENN ICU                                                                  DRAFT COASTAL PLAIN RESOURCE ASSESSMENT,
                                                                                                                                               ARCTIC NATIONAL WILDLIFE REFUGE, ALASKA
               777@                           \%.NSI I I N4, I ()V Im: 2112 111
                                                      I F8 - 6 ij8(                                                                                          General Comments
             Memorandum                                                                                                   We note that the draft document has been prepared to fulfill the requirements
                                                                                                                          of section 1002(h) of the Alaska National Interest Lands Conservation
             To:        Director, U.S. Fish and Wildlife Service                                                          Act (ANILCA) calling for a recommendation by the Secretary of the Interior to
                        Attention:   Noreen Clough, Division of Refuges                                                   the Congress on whether the coastal plain of the Arctic National Wildlife
                                                                                                                          Refuge (ANWR) in Alaska should be opened for oil and gas development. The
             From:      Director, Minerals Management Servic                                                              geographical area addressed by the document is referred to as the 111002 area."
             Subject:   Arctic National Wildlife Refuge, Alaska; Coastal Plain Resource                                   The Minerals Management Service (MMS) recently gained much relevant experience
                        Assessment and Draft Legislative Environmental Impact Statement                                   with the preparation of ANILCA section 810 subsistence analyses.        Accordingly,
             The Minerals Management Service (MMS) has reviewed the above document, and our                               we have focused our review on the suitability of the socioeconomic information
                                                                                                                          needed for such analyses. The information in this document is comprehensive;
             comments are attached.                                                                                       it properly includes the required analyses of the abundance and availability of,
                                                                                                                          and access to, subsistence resources. The document references much original
             The MMS fully supports   the Department of the Interior's (0011s) recommendation                             literature regarding the North Slope Borough (NSB), but we note that it
             to Congress for pursuing energy resources development in the coastal plain of                                unfortunately references only one study from the MMS Social and Economic Studies
             the Arctic National Wildlife Refuge (ANWR). This document has demonstrated that                              Program.
             development of the ANWR's oil resources is vital to our national interest and
             that mitigation measures are available to ensure minimal adverse effects on the                              In our specific comments that follow, we have noted, where appropriate, that
             environment.                                                                                                 additional information is available. To assist in making the information base
             In the attached comments, we have identified several sections of the document                                for this document more comprehensive, we have attached a current MMS studies
             that can be enhanced with additional discussions and/or clarifications.         In                           list for the Beaufort Sea Planning Area.
      0)     particular, we have concerns on two major topics discussed in the document.                                  As implied in this document, an ANILCA section BID analysis will be conducted
             First, the various sets of figures used for resource estimates and economic                                  prior to a lease sale.    Although the applicability of ANILCA to Federal offshore
             benefits, as discussed in Chapter 111, should be more clearly explained to                                   oil and gas lease sales in Alaska is still to be clarified by a pending
             indicate how these figures, which appear confusing and occasionally are                                      decision by the Supreme   Court, the MMS has, under the advice of the Office of
             inconsistent, were developed.     Second, the method for impacts assessment and                              the Solicitor, prepared   ANILCA section 810 analyses for several lease sales.
             discussions of potential environmental effects in Chapter VI should be                                       Our most recent analysis is found in the Beaufort Sea Sale 97 draft
             clarified to show how the conclusions are related to development scenarios and                               environmental impact statement (EIS) published on November 7, 1986.
             assumptions. We have provided in the attached comments specific references to
             those chapters, pages, and paragraphs where we have questions, concerns, and                                 Chapter IV
             suggestions.
                                                                                                                          A discussion of "Development and Transportation Infrastructure" should consider
             As a result of our responsibilities for overseeing energy resources development                              other oil development projects adjacent to the 1002 area that could affect
             on the Outer Continental Shelf, the MMS has considerable experience in oil and                               caribou and other wildlife on the refuge.      Federal and State offshore oil and
             gas leasing and environmental effects monitoring offshore Alaska.        To the extent                       gas activities as well as Canadian oil and gas activities should be considered.
             that any of our program activities or expertise may be of assistance to you in
             the furtherance of the 001's efforts for potential energy development in the                                 Chapter VI
             ANWR, please feel free to call on us. If you have questions concerning our
             comments, please direct them to John Goll, Chief, Offshore Environmental                                     The analysis of environmental consequences, as a whole, contains one major
             Assessment Division (Room 2042, Main Interior, 343-2097).                                                    methodological deficiency that should be corrected.      The potential impacts of
                                                                                                                          the proposed action are analyzed assuming mitigating measures are in effect.
                                                                                                                          The proposed action should be analyzed two ways, first without any mitigating
                                                                                                                          measures in place and then with mitigating measures because the inclusion of
                                                                                                                          mitigating measures in a lease is a discretionary action of the leasing
                                                                                                                          official.

             Attachment

                                                                                                                                                                                                                                3
                                                                                                          2
                                                                                                                                    The analysis Of environmental factors affecting the behavior patterns of the
                If the 1002 area is opened to hydrocarbon exploration, development, and                                             caribou and muskoxen herds in the 1002 area is well-documented, and the
                production at sometime in the future, it is very possible that the final leasing                                    discussions of how prospective exploration and development operations might
                decision may not include all of the 32 potential stipulations noted on                                              affect these herds are complete.       Also, the discussions on page Ill of possible
                pages 145-147.     If this happens, the subject resource assessment would not                                       mitigating measures for reducing disturbance to caribou herds and for enhancing
                present a true analysis of the potential impacts of the proposied action since                                      their migrations across roads and pipelines seem reasonable and well-supported
                all the 32 potential stipulations are assumed to be in place for the purposes of                                    by the analyses contained on pages 105 through 111.          These discussions provide
                the analysis.                                                                                                       invaluable information on how to manage oil and gas development activities to
                                                                                                                                    minimize disturbance to the species under consideration.
                Another reason for analyzing the proposal with and without mitigating measures
                is to facilitate evaluation of the effectiveness of each potential mitigating                                       We are concerned, however, that the conclusions about impacts to caribou and
                measure.    At the present time, there is no analysis of effectiveness in the                                       muskoxen contained on pages 112, 113, 132, and 144 do not seem to be substan-
                resource assessment.     If a mitigating measure is not effective in reducing                                       tiated by the analyses contained in the draft document.          What are presented on
                potential environmental impacts or facilitating lease administration, it is                                         these pages amount to "worst case" or catastrophic conclusions arrived at
                doubtful that it should be included in a lease.                                                                     without the support of sufficient information.         We suggest that the authors
                                                                                                                                    reexamine these conclusions in light of the revised Council on Environmental
                The discussion of effects does not adequately address oil spills, nor is oil                                        Quality and National Environmental Policy Act regulations on "Incomplete or
                spillage estimated. Pipeline spillage could be estimated from the trans-Alaska                                      Unavailable Information" (40 CFR 1502.22) that became effective on May 27, 1986
                pipeline system (TAPS) data held by the Bureau of Land Management.                                                  (51 FR 15618-15626).
                There are major analytical problems throughout Chapter VI.          The first is                                    Our specific concerns are as follows:
                in the last paragraph of page 95 which outlines the assumptions that guide the
                analysis of environmental consequences.        The paragraph states that the                                        Page 112, left column, 3rd and 4th paragraphs--These paragraphs refer to the
         -.n    scenarios for development in Alternatives A and B are treated as if all three                                       presence of up to 6,000 people, use of up to 25 Dercent of the Porcupine carihnn
                portions--western, eastern, and southern--of the 1002 area would be developed                                       herd (PCH) core calving area, and reduction or elimination of 29 percent of the
                concurrently.    The analysis then acknowledges that,                                                               coastal insect-relief habitat for the PCH.        These factors are based on an
                                                                                                                                    assumed scenario of concurrent development throughout the area, a scenario that
                      . . .   In         1weve                 w        kg'y oc   r sequentially.                                   the FWS has stated is unlikely.       The fourth paragraph concludes that these and
                                    kdh       hrl d:v   pm       u!ls'!n         quences may
                      [Empha  si sf:cdd.      eref r:!Oth:nlnaoly          co.,Ceu                                                  other factors "could result in a major population decline and change in
                      represent a higher level of development than may actually occur at                                            distribution of 20-40 percent, based on the amount of calving and insect-relief
                      any specific time if the area were opened to leasing.         This factor                                     habitat to be adversely affected."       There is no analysis in the report to
                      was recognized, and because any prediction as to the various stages                                           support this conclusion, and it is, therefore, conjectural. We note that on
                      of development at any given time on the 1002 area would be highly                                             page 106 the draft report cites a growth in the central Arctic caribou
                      speculative and perhaps misleading, the FWS chose to perform the                                              herd (CAH) population from 6,000 to between 12.000 to 14,000 individuals during
                      analysis as if concurrent development were to take place.                                                     the period 1978-1985--in spite of the range of CAH calving and insect-relief
                                                                                                                                    areas westward toward the vicinity of the TAPS and developed oil fields at
                We recognize the very real difficulty that,the authors undoubtedly have in                                          Prudhoe Bay. We recognize the draft report assertion on page 106 (left column,
                trying to second-guess the prospective development of the 1002 area, but we are                                     Ist paragraph) that "Analogies comparing the effects of current oil development
                concerned that the "concurrent development" assumption would simply overstate                                       on the CAM and the PCH must be drawn with caution." However, no clear reasons
                the extent of environmental consequences far beyond reason.                                                         were given on how the proposed development would result in seemingly dire
                                                                                                                                    consequences to the caribou in opposition to what is encouraging and objective
                There is a nearly 20-year.history of exploratory drilling and developmental                                         evidence.   Dire predictions also were made for the caribou prior to construction
                operations in the nearby Prudhoe Bay oil fields.         We believe that an examination                             of the TAPS, but the population of these animals has increased rather than
                of the Prudhoe Bay development history should provide some indications of how                                       declined.
                the 26 seismically mapped prospects in the 1002 area might be developed under a
                reasonable sequential development scenario. We acknowledge that the existence                                       Page 113, right column, first paragraph--This paragraph again uses the
                of the TAPS would likely help to speed sequential development of the 1002 area.                                     concurrent development scenario to argue that I'muskoxen would be displaced
                                                                                                                                    from approximately 53 percent" of their year-round habitat and up to
                                                                                                                                    75 percent of their "high use habitats in which calving occurs." Again,
                                                                                                                                    the analysis contained in the report does not fully support such negative

                                                                                                  4
                                                                                                                          Continental Shelf. The estimate of 3.2 billion barrels of economically

                                                                                                                          barrels estimated for the central Gulf of Mexico, where about 90 percent of all
              conclusions.  In fact, page 112 of the draft report indicates that from 1969 to                             producible oil for the 1002 area is significantly larger than the 2.66 billion
              1985, the muskoxen population of the ANWR grew from 69 to 476 individuals--                                 oil and gas production has occurred.    This comparison provides strong
              representing a nearly sevenfold increase--in spite of the development at
              Prudhoe Bay and construction of the TAPS.                                                                   encouragement to begin exploratory drilling in the 1002 area.
              These unsupported conclusions are evident as well in the executive summary of                                                                Specific Comments
              the draft report (page 6, right column, 4th paragraph) where it is stated:
                       Long-term losses in fish and wildlife resources, subsistence                                       Executive Summary
                       uses. and wilderness values would be the inevitable                                                Page 1, 4th paragraph--This paragraph should be revised to indicate the marginal
                       consequences of long-term commitment to oil and gas
                       development, production, and transportation.                                                       probability and amounts of both in-place and economically recoverable oil and
                                                                                                                          gas. This paragraph could be misleading to the reader. There is not merely a
                                                                                                                          5-percent chance of finding 29.4 billion barrels of oil and 64.5 trillion cubic
              We do not see any convincing analysis in the draft report to    indicate the                                feet of gas.   There is a 19-percent chance that hydrocarbons will be found.        If
              long-term losses in or consequences to these resources and uses would be                                    hydrocarbons are found, there.is a 5-percent chance that the estimated resources
              "inevitable" as a result of oil and gas development in the 1002 area. We
              suggest that the experience of the past 20 years indicates otherwise.                                       will be found.
              Chapter VII                                                                                                 The 113.2 88 of recoverable oil resources" in the 12th line should be "3.2 so
                                                                                                                          conditional mean of recoverable oil resources." The net national economic
                                                                                                                          benefits resulting from development of these recoverable resources are estimated
              In view of the fall in oil prices in 1986 and the   unpromising view for increases                          to be from $79.4 billion, based on an oil price of $33 per barrel.      In light of
              in the near future, the resource and economic benefit methodology and
                  ptions should be reviewed and perhaps redone to reflect more realistic                                  the recent decline in per-barrel prices, the net national economic benefits
              numbers. Also, some of the tables need to be updated and care taken concerning                              would be about half of $79.4 billion.
              the fact that Prudhoe Say was a major discovery; other areas may not be, i.e.,
              "'Sum                                                                                                       Page 1. 6th paragraph--"Exploratory wells" should be "stratigraphic test wells".
              Mukluk.

              This chapter should include a discussion of the enormous investaients--billions                             Page 4. 2nd paragraph--" . . . . their cubs probably spend more time . . . .
              of dollars in private investment and millions of dollars in Federal                                         How much more?
              administrative costs--that truly make the TAPS a national resource of tremendous                            Page 4, 6th paragraph--"           are of lesser importance             to the
              value. Although the report correctly notes that the productivity of Prudhoe Say                             ecosystem or to humans?
              oil fields will begin to decline in a few years, it fails to consider the
              ramifications of this fact.                                                                                 Page 5,.6th paragraph--It is incorrect to say "Federal Lease Sale 71 in 1980
              Letting the TAPS lie idle for even a few months would inevita  .bly result in                               resulted in two discoveries." Sandpiper was the only discovery from this sale.
              physical deterioration of the system under harsh Arctic conditions.                                         The authors may be referring to the Seal Island discovery which is on Sale BF
              Reconditioning the system to transport production from the 1002 area after     only                         leases.
              a short period could require expenditures of millions of dollars. Idling the
              TAPS during a year or more of public debate until a decision is made to produce                             Page 8. last paragraph--The 1115 billion"   in line 6 is different from that
              the oil could result in scrapping sections of the TAPS and spending billions of                             discussed on page 1. An explanation should be provided concerning the method of
              dollars to build new sections. Congress should be made aware of this through an                             deriving these estimates.
              analysis in the final report that describes the ramifications of idling the TAPS                            Chapter 11
              prior to development of 1002 area oil fields. If a decision were made now to
              proceed with leasing and development of the 1002 area, the hydrocarbon resources                            Page 33, 2nd paragraph--Under "Marine Mammals," humpback whale, fin whale, and
              from that area could begin to flow into the TAPS at a time when production                                  hooded sea] should be deleted from the sentence that states they are only rarely
              activities at Prudhoe Bay would be down significantly.                                                      seen. It is doubtful that they are seen at all in the region.
              We note that Table 111-1 on page 50 compares the estimated mean economically
              recoverable oil resources of the 1002 area with planning areas of the Outer

                                                                                                  6
                                                                                                                                                                                                                7
              Page 34, 2nd paragraph--Stoker (1983, cited in Braund et al., 1984) shows seals
              comprising 11.5 percent of the Kaktovik subsistence diet.     This conflicts with                            1985'.11 Also, there should be a column for the corresponding MPhc; otherwise,
              information stated in this paragraph.                                                                        the table is somewhat misleading since the planning areas estimates do not
              Page 38-Decreases in NSB revenues, decreases in capital-improvement-projects                                 compare directly.
              employment, lack of diversification in community economics, and other factors                                Page 51, 2nd par'agraph--Should state minimum accumulation size assessed.
              will probably cause an outmigration as families leave to seek employment. The
              rate of outmigration will probably be higher than the rate of natural population                             Page 52, Figure 111-3.   Should plot location of the Japo River well drilled by
              growth. Many communities will experience net population losses. This analysis
              should be incorporated under the discussion on population.                                                   Chevron on Native lands (KIC lands) east of Kaktovik and about 14 miles east of
                                                                                                                           Barter Island. Chevron spudded the well in mid-February 1985 and drilled to
                                                                                                                           below 11,000 feet before suspending operations due to spring ice breakup.
              Page 39--Under "Subsistence Use," it should be   noted that the residents of                                 Chevron has not released any drilling and testing results, because the well is
              Nuiqsut also harvest caribou of the central Arctic herd for subsistence uses.                                a "tight hole."
              There appear to be omissions in the sociocultural information.     The Inupiat                               Page 60, Figure.III-9--Should plot location of theJago River well.
              culture should be discussed to include such things as social organization,
              cultural values, and political systems.    A discussion of the current                                       Page 61, Table III-2--For prospect 3, it appears that the lowest closing contour
              sociocultural system is necessary in order to assess changes caused by oil-      and                         should be 14,000 instead of 14.
              gas-related activities within the 1002 area. Because subsistence is the central
              core of the Inupiat way of.life, major effects on subsistence would cause
              effects on the sociocultural system.                                                                         Page 62, 8th paragraph--It would be extremely useful if the "information on the
                                                                                                                           size, distribution, and numbers of petroleum accumulations" was provided. This
              Chapter III                                                                                                  information is critical and would be invaluable in making judgments concerning
                                                                                                                           the in-place resource potential.
              Page 49, Ist paragraph--The marginal probability (MPhc) for these estimates                                  Page 68, 2nd paragra .ph-'-Should.read "no current economic interest" instead of
              should be given in the text.                                                                                 "not current economic
              Page 49, 4th paragraph -_ The chance that economically recoverable oil is present                            Page 68, 3rd paragraph--The chance that economically recoverable oil is present
              is stated as 19 percent. on page 68, while the probability given on this page is                             is given as 19 perc6nt.while the same probability is shown as "about 20 percent"
              20 percent.
                                                                                                                           on.page 49.
              Page 50, Figure 111-2--The caption should read "Conditional oil resources of the                             Page 69, Figures 111-17 and 111-18--Regarding the mean estimates and pie
              eight largest prospects in the 1002 area assuming commercial resources exist in                              diagrams for plays 1-7, this is only justified for the risked estimates, but we
              each prospect ... . ." Also, the end of the caption has I'M, mean."     It appears                           assume MPhc=l has been used for each play in the calculations.
              that something is missing. This figure could be misleading to the reader.
              Marginal probabilities should be provided for individual prospects in the                                    Page 70, 8th paragraph--Regarding the last two sentences, prospect risk, that
              1002 area.
                                                                                                                           is, the probability that the prospect does not contain hydrocarbons as modeled,
              Page 50, 3rd paragraph--Obviously, these comparsonsm:re valid only if each                                   should be assessed at the threshold.    For additional discussion, see R.A. Baker,
              prospect has commercial resources; therefore, some     ntion.should be made of                               H.M. Gehman, W.R. James, and D.A. White, "Geologic Field Number and Size
              prospect risk.  There is a remote chance of the 5-percent case occurring.      The                           Assessments of Oil and Gas Plays,' AAPG Bulletin, volume 68, no. 4, pp. 426-437.
              second sentence should read "If oil resources are present in the prospects,
              there is about a 5-perceni chance . . . ." Also, according to Figure 111-2, the                              Page 70, last paragraph--Area geologic risk should be based solely on the
              largest prospect, if productive, has greater than a 5-percent chance of having                               probability of at least one accumulation, as modeled, existing in the area under
              more resources than Prudhoe Bay, and the second largest prospect has less than a                             consideration. Economic risk is handled by the model based on tests of minimum
              5-percent chance of having more resources than Prudhoe Bay.                                                  economic field sizeand presented as a model Output.
              Page 50 Table  111-1--The first part of the caption should end with " . . . and                              Page 72, Tabl e 1114w-We have comparedthe constant oil prices generated with
              elsewher'e (unleased ]an.ds)." The last sentence in the second part of the                                   those forecasted by the Department of Energy (DOE) for the Annual Energy Outlook
              caption should read "Data for Outer Continental Shelf resources from Cooke,                                  1986 and by Data Resources, Inc. (DRI), in the Autumn Energy Review (1986).       All
                                                                                                                           figures are in 1966 dollars. If they were in 1984 dollars, the numbers would be
                                                                                                                           even smaller.

                                                                                                      8                                                                                                             9

                                             Oil Prices (1986 dollars)                                                       social groups, as groups of whales sometimes scattered when a vessel approached.
                                                                                                                             Generally, bowheads stopped swimming away from a vessel within minutes after the
                                              DRI                   DOE                                                      vessel had passed, but scattering persisted for a longer period. Based on these
                                                                                                                             observations, bowheads appeared.to be more sensitive to vessel traffic than
                1990                         17.61                  17.84                                                    some other whale species and could be displaced by repeated vessel disturbance
                1995                         22.37                  26.61                                                    (Richardson et a]., 1985). Occasional vessel disturbance would not be expected
                2000                         32.73                  32.87                                                    to seriously disrupt or displace the bowhead-migration corridor or cause
                Thus, $33 and $40 per   barrel are much too high. Also, the inflation figures do                             significant adverse effects on the bowhead population.
                not make sense. Generally, the higher the     inflation, the higher the oil price;                           Page 125, 2nd paragraph--Arctic char should be analyzed more similarly to
                the lower the-inflation, the lower the oil    price. This document shows a higher                            grayling, since new U.S. Fish and Wildlife Service research (funded by the MMS)
                inflation rate for the lower oil price and    vice versa. As for the discount                                indicates that individual river stocks occur. This finding suggests the
                rate, somewhere in between 0 and 8 percent    is more realistic than 10 percent.                             separate stock is more vulnerable to local disturbance.
                The use of 10 percent should be justified. Also, the marginal probability of
                19 percent differs from 20 percent on page    49.                                                            Page 125, 7th paragraph--Docks and causeways are mentioned as potential parts of
                                                                                                                             the scenario at Camden Bay and Pokok port sites; however, only docks are
                Chapter IV                                                                                                   mentioned in Chapter IV. Since the potential effects of causeways on anadrdmous
                                                                                                                             fishes are not clear--and this is a major issue in the Beaufort Sea--the           _
                Page 84, 2nd paragraph--The discussion under "Oil Spill Contingency, Including                               discussion should be clarified with supporting analysis regarding causeways that
                Leak Detection" should state the minimum daily leak rate that would not be                                   may be built.    In the last sentence, location should be added to the dependent
                detected under the automated system.                                                                         variables of time, amount, and type oT -material spilled.-
                Chapter V                                                                                                    Page 126, last paragraph--Decreases in NSB revenues, decreases in capital
                                                                                                                             improvement-projects employment, lack of diversification in community economics,
                Page 91, 1st paragraph--The specific boundaries of Alternative B (Limited                                    and other factors will probably cause an outmigration as families leave to seek
                Leasing) are not adequately presented. Plate 2A is not specific enough. We                                   employment. The.rate of outmigration will probably be higher than the rate of
                recommend adding a half-page-size map showing the boundaries of Alternative B at                             natural population growth. Many communities will experience net population
                the beginning of the discussion of Alternative 8 here and on page 132.                                       losses.   This analysis should be incorporated under the discussion on
                                                                                                                             population.
                Page 91, Ist paragraph--How were these estimates derived? If they were
                developed by PRESTO, they should have a different MPhc from those on page 49.                                Page 127--There is no analysis ot sociocultural effects under "Subsistence Use."
                                                                                                                             If moderate to major effects are anticipated on the CAH, it is unclear how
                Chapter VI                                                                                                   Nuiqsut (not mentioned) would be affected.
                Page 119, 2nd paragraph--Finley and Davis (1984) reports a strong avoidance by                               Page 129, 3rd paragraph--As stated in the first stntence, development activities
                beluga whales to icebreaker noise at 35 to 50 kilometers. This is in conflict                                could substantially increase employment and cash flow in Kaktovik.        It would be
                with the information reported in this paragraph.                                                             useful if a description of these employment opportunities were included.         This
                                                                                                                             document states that effects (from employment and cash flow) would be unevenly
                Page 119, 3rd and 4th paragraphs--The reports by Fraker and others (1981,.1,982)                             distributed within the community.     However, because of the cultural value of
                are somewhat outdated.    Bowhead whale reaction to closely approaching vessels                              sharing (subsistence food, etc.). these effects would probably be experienced to
                appears greater than their reaction to any other industrial acfivities except                                some degree throughout the community.
                marine-seismic surveys. Based on sound measurements in the-Alaskan Beaufort
                Sea, Miles et al. (1986) estimate that ab9ut 50 percesA 'of bowheads exposed to                              Page 130--Reference is made to State and local economic benefits.        Depending on
                tug noise would react to the noise at a distance of.2.5-13 kilometers                                        what system is used for leasing (i.e., Mineral Leasing Act or separate
                (1.6-8.1 miles) from the source.    In the Canadian Beaufort Sea, some bowheads                              legislation), the economic benefits would be quite different. Under the
                observed in vessel-disturbance experiments began to orient away from an oncoming                             Mineral Leasing Act, the State of Alaska currently receives 90 percent of rents,
                vessel at a range up to 4 kilometers (2.5 miles) and to move away at increased                               bonuses, and royalties from Federal leases.      Under a separate congressional act,
                speeds when approached closer than 2 kilometers (1.2 miles). Closely                                         leasing of the National Petroleum Reserve-Alaska provides 50 percent of rents,
                approaching vessels temporarily disturbed activities and sometimes disrupted                                 bonuses, or royalties to the State of Alaska.

                                                                                                10                        Beaufort Sea Environmental Studies List
              Page 132, 2nd paragraph--This paragraph repeats the unsubstantiated conclusion of                           Identification, Documentation and Delineation of Coastal Migratory Bird
              a 20-40 percent reduction in caribou population and distribution cited in our                               Habitats in Alaska, Alaska Department of Fish and Game, NOAA/OCSEAP Research
              general comment for page 112.                                                                               Unit Nos. 3/4, September 1980.
              Page 132, 4th and 5th paragraphs--These paragraphs basically repeat the                                     Distribution, Abundance, Community St  ructure and Tr6phic Relationships of the
              unsubstantiated conclusions on impacts to muskoxen that are described in our                                Nearshore Benthos, University (if Alaska, NOAA/OCSEAP Research Unit No. 5,
              general comment for page 113.                                                                               December 1981.
              Page 138--This document would   be strengthened in its analysis under "Effects   on
              Socioeconomic Environment" if   specific numbers for population increases and                               Distribution, Composition, and Variability of Western Beaufort and Northern
                                                                                                                          Chukchi Sea Benthos, Oregon State University, NOAA/OCSEAP Research Unit No. 6,
              employment estimates were provided. A sociocultural analysis should be included                             June 1584.
              in this section.
              Page 142--Under "Biological Resources." effects (due to causeway construction)                              Summarization of Existing Literature and Unpublished Data on Distribution,
              on planktonic and benthic organisms are discussed. Fish should also be                                      Abundance, and Life Histories of Benthic Organisms of the Beaufort Sea,    -Oregon
              discussed, and a sentence regarding the migration of anadromous fish (i.e.,                                 State University, NOAA/OCSEAP Research Unit No. 7, January 1977.    .
              Arctic cisco) should be included.                                                                           Assessment of Potential     Interactions of Micro-organisms      and Pollutants
                                                                                                                          Resulting from Petroleum Development on the OCS in the Beaufort Sea,
              Page 144, right column, 2nd paragraph--This paragraph basically repeats the                                 University of Louisville, NOAA/OCSEAP Research Unit No. 29, December 1982.
              erroneous conclusions concerning caribou and muskoxen described previously.
                                                                                                                          Analysis of Marine Mammal Remote Sensing Data, Johns Hopkins University,
              Page 145--There is a summary of recommended mitigation for the 1002 area that                               NOAA/OCSEAP Research Unit No. 34, April 1977.
              includes safety and environmental stipulations applicable to oil and gas
              exploration, development, production, and transportation on the 1002 area.      A                           Trace Hydrocarbon Analysis      In Previously Studied    IMatrices and Methods
        71    stipulation concerning oil spills should be added. On page 84 of this document,                             Development for (a) Trace HC Analysis in Sea Ice and at the Sea Ice/Water
              there is a discussion on the requirement that oil spill contingency plans      .                            Interface and (b) Analysis of Individual High Molecular Weight Aromatic      I HC,
              include provisions for oil spill control.    A stipulation to address concerns of                           National Bureau of Standards, NOAA/OCSEAP Research Unit No. 43, January 1980.
              oil spills would enhance a positive leasing program.
                                                                                                                          Environmental Assessment of Alaskan Waters - Trace Element Methodology -
              Chapter V11                                                                                                 Inorganic Elements, National Bureau of Standards, NOAA/OCSEAP Research Unit
                                                                                                                          No. 47, May 1977.
              Page 162, Table VII-2--The numbers   should be updated.
                                                                                                                          Coastal Morphology, Sedimentation, and Oil Spill Vulnerability, RPI, Inc. ,
              Page 163, Table VII-3--The finding   rates should be updated if available.                                  NOAA/OCSEAP Research Unit No. 59, April 1980.
              Additional source information, if available, should be provided.
                                                                                                                          Migration, Distribution, and Abundance of     Bowhead and Beluga Whales in the
              Page 164, last paragraph--The Federal deficit and import.numbers should     be                              Arctic Oceans, National Marine Fisheries Service, NOAAIOCSEAP Research Unit
              updated.                                                                                                    Nos. 69/70, October 1981.
              Chapter VIII                                                                                                Lethal and Sublethal Effects On Selected Alaskan Marine Species After Acute
                                                                                                                          and Long-Term Exposure to Oil. National Marine Fisheries Service, NOAA/OCSEAP
              Page 169, 6th paragraph-How were the figures of economic benefits at $8.1 and                               Research Unit No. 72, April 1983.
              $14.6 billion developed? There is no explanation of the methodology used for
              economic benefits.   Also, it should be stated that 3.2 BBO are conditional [Dean                           Sublethal Effects of Petroleum as Reflected By Morphological, Chemical,
              estimates.                                                                                                  Physiological, Pathological and Behavioral Indices, National Marine Fisheries
                                                                                                                          Service, NOAA/OCSEAP Research Unit No. 73, June 1982

                                                                                                                          Identification of Major Processes in B iotr ans formations of Petroleum HC and
                                                                                                                          Trace Metals, National Marine Fisheries Service, NOAA/OCSEAP Research Unit
                                                                                                                          No. 74, June 1982.

            Assessment of Available Literature: Oil Pollution Effects on Biota in Arctic                                 The Natural History and Ecology of the Bearded Seal and the Ringed Seal,
            and Subarctic Waters, National Marine Fisheries Service, NOAA/OCSEAP Research                                Alaska Department of Fish and Game, NOAA/OCSEAP Research Unit No. 230,
            Unit No. 75, November 1976.                                                                                  May 1979.

            Beaufort Shelf Surface Currents, United States Coast Guard, NOAA/OCSEAP                                      Trophic Relationships Among Ice Inhabiting Phocid Seals and Functionally
            Research Unit No. 81, April 1977.                                                                            Related Marine Mammals in the Arctic, Alaska Department of Fish and Game,
            Interaction of Oil With Sea ice in the Beaufort Sea, University of Washington,                               NOAA/OCSEAP Research Unit No. 232, February 1982.
            NOAA/OCSEAP Research Unit No. 87, May 1982.                                                                  Beaufort Sea Estuarine Fishery Study, Alaska Department of Fish and Game,
                                                                                                                         NOAA/OCSEAP Research Unit No. 233, October 1977.
            Dynamics of Nearshore Ice, U.S. Army-CRREL, NOAA/OCSEAP Research Unit No. 88,
            Ongoing Study.                                                                                               Study of Climatic Effects on Fast-Ice Extent and its Seasonal Decay Along the
                                                                                                                         Beaufort Sea/Chukchi Sea Coasts, University of Colorado, NOAA/OCSEAP Research
            Current Measurements in Possible Dispersal Regions of the Beaufort Sea,                                      Unit No. 244, March 1979.
            University of Washington, NOAA/OCSEAP Research Unit Nos. 91/151, January 1981.
                                                                                                                         Relationships of Marine Mammal Distributions, Densities, and Activities to Sea
            Dynamics of Nearshore Ice, Flow Research Co. , NOAA/OCSEAP Research Unit                                     Ice Conditions, Alaska Department of Fish and Game/University of Alaska,
            No. 98, March 1979.                                                                                          NOAA/OCSEAP Research Unit Nos. 248/249, June 1980.

            Delineation and Engineering Characteristics of Permafrost Beneath the Arctic                                 Mechanics of Origin of Pressure, Shear Ridges, and Hummock Fields in Landfast
            Seas, U.S. Army-CRREL, NOAA/OCSEAP Research Unit No. 105, May 1982.                                          Ice, University of Alaska, NOAA/OCSEAP Research Unit No. 250, Ongoing Study.

            Seasonality and Variability of Streamflow Important to Alaskan Nearshore                                     Subsea Permafrost, Probing, Thermal Regime and Data Analysis, University of
            Coastal Areas, University of Alaska, NOAA/OCSEAP Research Unit No. 111,                                      Alaska, NOAA/OCSEAP Research Unit No. 253, Ongoing Study.
            March 1977.
                                                                                                                         Morphology of Beaufort. Chukchi, and Bering Seas Nearshore Ice Conditions By
       T    Natural Distribution of Trace Heavy Metals and Environmental Background in                                   Means of    Satellite and Aerial Remote Sensing,         University   of   Alaska,
       '4   Three Alaskan Shelf Areas, University of Alaska, NOAA/OCSEAP Research Unit                                   NOAA/OCSEAP Research Unit Nos. 257/258, September 1978.
            No. 162, May 1979.
                                                                                                                         Experimental Measurements of Sea-Ice Failure Stresses Near Grounded Struc-
            Shorebird Dependence on Arctic Littoral Habitats, University of California,                                  tures, University of Alaska, NOAA/OCSEAP Research Unit No. 259, June 1978.
            NOAA/OCSEAP Research Unit No. 172, September 1982.
                                                                                                                         Baseline Study of Historic Ice Conditions in Bering Strait, Chukchi Sea, and
            Study of Microbial Activity and Crude Oil/Microbial Interactions in the Waters                               Beaufort Sea, University of Alaska, NOAA/OCSEAP Research Unit No. 261,
            and Sediments of Cook Inlet afid the Beaufort Sea, Oregon State University,                                  September 1977.
            NOAA/OCSEAP Research Unit No. 190, December 1980.
                                                                                                                         In Situ Measurements of the Mechanical Properties of Sea Ice, University of
            Morbidity and Mortality of Marine Mammals, University of Alaska, NOAA/OCSEAP                                 Alaska, NOAA/OCSEAP Research Unit No. 265, Ongoing Study.
            Research Unit No. 194, December 1980.
                                                                                                                         Operation of an Alaskan Facility for Applications of Remote Sensing Data to
            Distribution, Abundance, and Feeding Ecology of Birds Associated with Sea Ice,                               OCS Studies. University of Alaska, NOAA/OCSEAP Research Unit No. 267, Ongoing
            College of the Atlantic, NOAA/OCSEAP Research Unit No. 196, January 1983.                                    Study.

            Offshore Permafrost Studies, U.S. Geological Survey, NOAA/OCSEAP Research Unit                               Arctic Offshore Permafrost Studies, Michigan Technical University/University
            Nos. 204/473, Ongoing Study.                                                                                 of Alaska, NOAA/OCSEAP Research Unit Nos. 271/610, September 1982.
            Geologic Environment of the Chukchi and Beaufort Sea Shelf and Coastal                                       Hydrocarbons:   Natural Distribution and Dynamics on the Alaskan OCS, Univer-
            Regions, U.S. Geological Survey, NOAA/OCSEAP Research Unit No.       205, Ongoing                            sity of Alaska, NOAA/OCSEAP Research Unit No. 275, February 1981.
            Study.
                                                                                                                         Preparation of Illustrated Keys to Skeletal Remains and Otoliths of Forage
            Avifaunal Utilization of the Offshore Islands Near Prudhoe            Bay Alaska,                            Fishes in the Beaufort Sea, University of Alaska, NOAA/OCSEAP Research Unit
            University of Alaska, NOAA/OCSEAP Research Unit No. 215, March 1977.                                         No. 318, March 1977.

                                                     2                                                                                                            3

               Determine the Frequency and Pathology of Marine Fish Diseases in the Gulf of                                   Characterization of Organic Matter In Sediments from the Gulf of Alaska,
               Alaska, Bering, and Beaufort Seas,        National Marine Fisheries Service,                                   Bering and Beaufort Seas, University of California, NOAA/OCSEAP Research Unit
               NOAA/OCSEAP Research Unit No. 332, January 1980.                                                               @No. 480, June 1981.
               Transport of Pollutants in the Vicinity of Prudhoe Bay, Environmental Protec-                                  Evaluation of Earthquake Activity and Seismotechnic Studies of Northern and
               tion Agency, NOAA/OCSEAP Research Unit No. 335, March 1976.                                                    Western Alaska, University of Alaska, NOAA/OCSEAP Research Unit No. 483, March,
                                                                                                                              1980.
               Seasonal Distribution and Abundance of Marine Birds, U.S. Fish and Wildlife
               Service, NOAA/OCSEAP Research Unit No. 337, October 1978.                                                      Natural Distribution and Environmental Background of Trace Heavy Metals in
                                                                                                                              Alaskan Shelf and Estuarine Areas, Battelle Pacific Northwest Laboratories,
               Review and Analysis of Literature and Unpublished Data     on Marine Birds, U.S.                               NOAA/OCSEAP Research Unit No. 506, 1979.
               Fish and Wildlife Service, NOAA/OCSEAP Research Unit No. 339, December 1980.
               Migration of Birds in Alaskan 'Aarine Waters Subject to Influence by OCS                                       A Geographic Based Information Management System for Permafrost Predictions in
                                                                                                                              th Beaufort and Chukchi Seas Part I and 11, University of Colorado, NOAAJ
               Development, U.S. Fish and Wildlife Service, NOAA/OCSEAP Research Unit                                         OC;EAP Research Unit No. 516, 1978.
               No. 340, May 1978.
                                                                                                                              Nearshore Meteorologic Regimes in the Arctic, Occidental College, NOAA/OCSEAP
               Feeding Ecology and Tfophic Relationships of Alaska Marine Birds, Population                                   Research Unit No. 519, 1984.
               Dynamics of Marine Birds, and Catalog of Seabird Colonies, U.S. Fish and
               Wildlife Service, NOAA/OCSEAP Research Unit Nos. 341/342/343, October 1978.                                    Characterization of the Nearshore Hydrodynamics of Arctic Barrier Island-
                                                                                                                              Lagoon System, University of Alaska, NOAA/OCSEAP Research Unit No. 526, March
               Marine Climatology of the Gulf of Alaska, Bering and Beaufort Seas, Arctic                                     1981.
               Environmental Information and Data Center/National Climatic Center, NOAA/
               OCSEAP Research Unit Nos. 347/496, December 1977.                                                              Sediment Characterization, Stability, and Origin of Barrier            Island-Lagoon
                                                                                                                              Complex,  North Arctic, Alaska, University of Alaska, NOAA/OCSEAP     Research Unit
               Literature Search and Data Conversion on Density   Distribution of Fishes of the                               No. 529.  August 1982.
               !
               eaufort Sea, University of Alaska, NOAA/OCSEAP      Research Unit No. 34a, March
               9
               -77.                                                                                                           Geology   and, Geomorphology of the Barrier Island-Lagoon System Along the
                                                                                                                              Beaufort  Sea Coastal Plain, University of Alaska, NOAA/OCSEAP Research Unit
               Environmental Assessment of Selected Habitats       in Arctic Littoral Systems,                                No. 530,  July 1981.
               Western Washington State University, NOAA/OCSEAP Research Unit No. 356,
               Ongoing Study.                                                                                                 Oceanographic Processes in a Beaufort Sea Barrier Island-Lagoon      ,System and its
               Beaufort Sea Plankton Studies, University of Washington, NOAA/OCSEAP Research                                  Surroundings;  Numerical Modeling and Current Measurements, Kinnetic Labora-
               Unit No. 359, February 1981.                                                                                   tories, Inc., NOAA/OCSEAP Research Unit No. 531, June 1982.
                                                                                                                              Nutrient Dynamics and Trophic System Energetics in Nearshore Beaufort Sea
               A Study of Beaufort Sea Coastal Erosion, Arctic Research, NOAA/OCSEAP Research                                 Waters, University of Alaska, NOAA/OCSEAP Research Unit No. 537, Ongoing
               Unit No. 407, September 1976.                                                                                  Study.
               Influence of Petroleum on Egg Formation and Embryonic Development in Seabirds,                                 Oil Pooling Under Sea Ice. U.S. Army-CRREL, NOAA/OCSEAP Research Unit No. 562,
               University of California, NOAA/OCSEAP Research Unit No. 423, May 1979.                                         March 1980.
               Zooplankt6n and Micronekton Studies in the Ber ing-Chukch i /Beaufort Seas,                                    Transport and Behavior of Oil Spilled In and Under Sea Ice (Task I), Flow
               University of Alaska, NOAA/OCSEAP Research Unit No. 426. March 1977.                                           Research Co. , NOAA/OCSEAP Research Unit No. 567, January 1983.
               Ice Edge Ecosystem Study: Primary Productivity, Nutrient Cycling and Organic                                   Transport and Behavior of Oil Spilled In and Under Sea Ice (Task Il and 111),
               Matter Transfer, University of Alaska, NOAA/OCSEAP Research Unit No. 427,                                      ARCTEC Incorporated, NOAA/OCSEAP Research   Unit No. 568, September 1980.
               .March 1979.
                                                                                                                              Multivariate Analysis of Petroleum Weathering in the Marine Environment-Sub
               Modeling of Tides and Circulations, Rand Corporation, NOAA/OCSEAP Research                                     Arctic, Science Applications, Inc. , NOAA/OCSEAP Research Unit No. 597, 1983.
               Unit No. 435, Ongoing Study.
                                                                                                                              Baffin Island Oil Spill Project, Environmental Protection Service (Canada),
               Beaufort Sea Barrier Island-Lagoon Ecological Process Studies, LGL Ecological                                  NOAA/OCSEAP Research Unit No. 606, February 1984.
               Research Associates, NOAA/OCSEAP Research Unit No. 467, March 1980.

                                                                                                                                                                        5
                                                        4

                                                                                                                                       A Markov Model, for Nearshore Sea-Ice Trajectories, University of Washington,
               Biodegradation of Aromatic Compounds by High Latitude Phytoplankton, Univer-                                            NOAA/OCSEAP Research Unit No. 654, February 1985.
               sity of Texas, NOAA/OCSEAP Research Unit No. 607, April 1982.
                                                                                                                                       Lethal, and Sublethal Effects of Oil on Food Organisms of the Bowhead Whale,
               Arctic Offshore Permafrost Studies, Michigan Technical University, NOAA/OCSEAP                                          Fishman Environmental Services, NOAA/DCSEAP Research Unit No. 662. 1986.
               Research Unit No. 610, September 1982.                                                                                  Remote Sensing Data Acquisition, Analysis. and Archival for Alaskan OCS,
               Biological Investigation of Beluga Whales in the Coastal Waters of Alaska,                                              University of Alaska, NOAA/OCSEAP Research Unit No. 663, Ongoing Study.
               Alaska Department of Fish and Game, NOAA/OCSEAP Research Unit No. 612,
               December 1983.                                                                                                          Ringed Seal Monitoring, Alaska Department of Fish and Game, NOAA/OCSEAP
                                                                                                                                       Research Unit No. 667, Ongoing Study.
               Investigations of Marine Mammals in the Coastal Zone During Summer and Autumn,
               Alaska Department of Fish and Game, NOAA/OCSEAP Research Unit No. 613,                                                  Marine Meteorology Update, National Climatic Data Center, NOAA/OCSEAP Research
               September 1982.                                                                                                         Unit No. 672, Ongoing Study.

               Baffin Island Oil Spill Project.           Hydrocarbon Bioaccumulation and Histo-                                       Arctic Ocean Buoy Program. University of Washington, NOAA/OCSEAP Research Unit
               pathological and Biochemical Responses of Mollusks, Battelle Northwest                                                  No. 674, Ongoing Study.
               Laboratories, NOAA/OCSEAP Research Unit No. 615, Ongoing Study.
                                                                                                                                       Ocean Circulation and Oil Spill Trajectory Simulation, Applied Science Asso-
               The Nature and Biological Effects of Weathered Petroleum, NOAA/Northwest and                                            ciates, NOAA/OCSEAP Research Unit No. 676, Ongoing Study. (See RU 435.)
               Alaska Fisheries Center, NOAA/OCSEAP Research Unit No. 619, December 1983.
                                                                                                                                       Oil-Ice-Sediment Interactions During Freeze-up and Break-up, Science Applica-
               Storm Surge Modeling, University of Alaska, NOAA/OCSEAP Research Unit No. 627,                                          tions Inc., NOAA/OCSEAP Research Unit No. 680, Ongoing Study.
               May 1984.                                                                                                               Effects of   *Petroleum-Contaminated Waterways on the Spawning Migration of
               Belukha Whale Responses to Industrial Noise in Nushagak Bay, Alaska, 1983;                                              Pacific Salmon, Battelle Laboratories N.W., NOAA/OCSEAP Research Unit No. 681,
         .n    Hubbs-Sea World Research Institute, NOAA/OCSEAP Research Unit No. 629, June                                             Ongoing Study.
         4     1984.
        -ph                                                                                                                            Arctic Fish Habitats and Sensitivities, No Contractor Yet, NOAA/OCSEAP
               Geophysical and Biological Reconnaissance of Rock Habitats in Eastern Camden                                            Research Unit No. 682, Ongoing Study.
               Bay, University of Alaska, NOAA/OCSEAP Research Unit No. 630, July 1983.
                                                                                                                                       Interpolation, Analysis and Archival of Data on Sea-Ice Trajectory and Ocean
               Fish Survey:     Shoreline From Harrison Bay to Point Barrow, LGL Ecological                                            Currents from Satellite-Linked Ins       .truments, Ice Casting Inc., NOAA/OCSEAP
               Research Associates, NOAA/OCSEAP Research Unit No. 631, Ongoing Study.                                                  Research Unit No. 683, Ongoing Study.

               Ecosystem Characterization:       Eastern Beaufort Sea, LGL Ecological Research                                         Investigation of the Occurrence and Behavior Pattern of Whales in the Vicinity
               Associates, NDAA/OCSEAP Research Unit No. 632. September 19B3.                                                          of the Beaufort Sea Lease Area, Naval Arctic Research Laboratory, MKS Con-
                                                                                                                                       tract, 1980.                                                                                J
               Direct Effects of Acoustic Disturbance Sources on Ringed Seal Reproductive
               Behavior, Vocalization, and Communication, Alaska Department of Fish and Game,                                          Aerial Survey of Endangered Whales in the Beaufort, Chukchi, and Northern
               NOAA/OCSEAP Research Unit No. 636, Ongoing Study.                                                                       Bering Seas, Naval Ocean Service Center, MMS Contract, Ongoing Study.

               Permafrost: 4th International Conference, NOAA/OC          SEAP Research Unit No. 637,                                  Development of Large Cetacean Tagging and Tracking Capabilities in OCS Lease
               July, 1983.                                                                                                             Areas - 1, Oregon State University, MMS Contract, May 1981.
               Predictive  Model for the Weathering of Oil in the Presence of Sea Ice, Science                                         Computer Simulation of the Probability of Endangered Whale Interaction with
               Application, Inc., NOAA/OCSEAP Research Unit Nos. 640/664, 1984 and 1986.                                               Oil Spills, Applied Science Associates, MMS Contract, Ongoing Study.
               Oceanographic Data, Brown and Caldwell, NOAA/OCSEAP Research Unit No. 642, May                                          Tissue Structure Studies and Other Investigations on the Biology'of Endangered,
               1984.                                                                                                                   Whales in the Beaufort Sea, University of Maryland, MMS Contract. June 1981.

               Beaufort Sea Monitoring Program, Proceedings of a Workshop and Sampling DAs1gn
               Recommendation,     MMS-National Oceanic and Atmospheric Administration, NOAA/
               OCSEAP Research Unit No. 652.

                                                           6                                                                                                                        7

                                                                                                                           Beaufort Sea Region - Man Made Environment, Alaska Consultants, Inc., MMS
             Environmental Assessment of the Alaskan Continental Shelf: Interim Synthesis                                  Technical Report No. 8, April 1978.
             Report Beaufort/Chukchi, NOAA/OCSEAP, 1978.
                                                                                                                           Beaufort Sea Region Sociocultural Systems, Worl Associates, MMS Technical
             Beaufort Sea (Sale 71) Synthesis Report, NOAA/OCSEAP and USDOI/BLM, December                                  Report No. 9, June 1978.
             1981.
                                                                                                                           Beaufort Sea Region Natural Physical Environment, Dames & Moore, KMS Technical
             Historical Review of Eskimo Information - Bowhead Whale, Alaska Eskimo Whaling                                Report No. 10. May 1978.
             Commission, MMS Contract, 1979.
                                                                                                                           Beaufort Sea Region Socioeconomic Baseline, Peat, Marwick, Mitchell & Co., MMS
             Beaufort Sea Seismic Monitoring and Bowhead Whale Behavior Studies, Naval                                     Technical Report No. 11, July 1978.
             Ocean Service Center, MMS Contract, October 1985.
                                                                                                                           Anchorage Socioeconomic and Physical Baseline, Policy Analysts Ltd., MMS
             Oil/Suspended Particulate Matter Interactions and Transport, Science Applica-                                 Technical Report No. 12, June 1978.
             tions Inc. , MMS Study, Ongoing Study.
                                                                                                                           Anchorage Impacts of the Beaufort Sea, Petroleum Development Scenario, Policy
             Coastline and Surf Zone Oil Spill Smear Model.       Application, BPI, MMS Con-                               Analysts Ltd. , 14MS Technical Report No. 13, August 1978 (out of print).
             tract, Ongoing Study.
                                                                                                                           Governance in the Beaufort Sea Petroleum Development Region, Institute of
             Vertical Turbulent Dispersion of Oil Droplets        and Oiled Part!cles, Delft                               Social and Economic Research, University of Alaska, MMS Technical Report No.
             Hydraulics Laboratory, MMS Contract, Ongoing Study.                                                           16, July 1978.

             Development of Large Cetacean Tagging and Tracking Capabilities in OCS Lease                                  Economic and Demographic Impacts of the Beaufort Sea Petroleum Development
             Areas - II, National Marine Mammal Laboratory, M11S Contract, March 1981.                                     Scenarios,. Institute of Social and Economic Research (1SER), University of
                                                                                                                           Alaska, MMS Technical Report No. 18, June 1978.
             Effects of Whale Monitoring System Attachment Device in Whale Tissue, Woods
             Hole Oceanographic Institution, MMS Contract, 1982.                                                           Man Made Environmental Impacts of the Beaufort Sea Petroleum Development
                                                                                                                           Scenarios, Alaska Consultants, Inc. , MMS Technical Report No. 19, August 1976.
       U1    Effects of Oil on the Feeding Mechanism of the Bowhead Whale - Baleen. Fouling,
             Brigham Young University, MMS Contract, June 1983.                                                            Transportation Impacts of the Beaufort Sea Petroleum Development Scenarios.
                                                                                                                           Dennis Dooley & Assocs. , MMS Technical Report No. 20, August 1978.
             Investigations of the Potential Effects of Acoustic Stimuli Associated With
             Oil and Gas Exploration/Development on the Behavior of Migratory Gray Whales,                                 Natural Physical Environment Impact of the Beaufort Sea Petroleum Development
             Bolt Beranek and Newman, Inc., M11S Contract, August 1984.                                                    Scenarios, Dames and Moore, MMS Technical Report No. 21, June 1978.

             Beaufort Sea Monitoring Program Analysis of Trace Metals and Hydrocarbons from                                Sociocultural Systems Impacts of the Beaufort Sea Petroleum Development
             Outer Continental Shelf (OCS) Activities, KMS Contract, Ongoing Study.                                        Scenarios, Worl Associates, MMS Technical Report No. 22, April 1978.

             Possible Effects of Acoustic and Other Stimuli Associated With Oil and Gas                                    Summary of Socioeconomic Systems Impacts of the Beaufort Sea Petroleum Devel-
             Exploration/Development an the Behavior of the Bowhead Whale, LGL Ecological                                  opment Scenarios, James Lindsay and Associates, MMS Technical Report No. 23,
             Research Associates, MMS Contract, 1985.                                                                      December 1978.

             Beaufort Sea Basin Petroleum Development Scenarios for the Federal Outer                                      Socioeconomic Impacts of Selected Foreign OCS Developments, Habitat North,
             Continental Shelf, Interim Report, Dames & Moore, USRA, CCC/HOK, MMS Technical                                Inc. , MMS Technical Report No. 28, April 1979.
             Report No. 3, December 1977 (out of print).
                                                                                                                           Beaufort Sea Statewide & Regional Demographic & Economic Systems, Institute of
             Prudhoe Bay Case Study, CCC/HOK, MKS Technical Report No. 4, February 1978.                                   Social and Economic Research, University of Alaska, MMS Technical Report
                                                                                                                           No. 62, August 1981.
             Beaufort Sea Baseline Studies:    Interim Report, CCC/HOK, MMS Technical Report
             No. 5, December 1977 (out of print).                                                                          Beaufort Sea Sociocultural Systems Update Analysis, Worl Associates, MMS
                                                                                                                           Technical Report No. 64, November 1981.
             Beaufort Sea Petroleum Development Scenarios, Dames & Moore, MMS Technical
             Report No. 6, April 1978.

                                                                                                                                                                    9

            Forecasting Enclave Development Alternatives and their Related Impact on                                               Technology Assessment and Research Program Technical Reports
            Alaskan Coastal Communities as a Result of OCS Development, Louis Berger and                                                          for Offshore Minerals Operations
            Associates, Inc.,    MMS.Technical Report No. 76, December, 1982.                                             Information regarding the status of the TA&RP reports may be obtained by
            Beaufort Sea Transportation Systems Analysis, Peter Eakland and Associates,                                   telephone from Mr. Charles Smith, Program Manager, Technology Assessment and
            MMS Technical Report No. 65, December, 1981.                                                                  Research Branch, (FTS) 928-7865 or (703) 860-7865.
            A Description of the Socioeconomics of     the North Slope Borough, Institute of                              Underwater inspect ion/Test ing/Monitoring of Offshore Structures, Busby Asso-
            Social and Economic Research, University of Alaska, MKS Technical Report No.                                  ciates, Technology Assessment and Research Program (TA&RP) Project No. 1.
            85, September 1983.
            A Description of the Socioeconomics of the       North Slope Borough: Appendix:                               Dynamic Response of Offshore Structures, Massachusetts Institute of Techno-
            Transcripts of Selected Inupiat Interviews,     University of Alaska, ISER, MMS                               logy. TWP No. 2.
            Technical Report No. 85a, April 1983.                                                                         Incipient Crack Detection in Offshore Structures, Dsedalean. Associates, TA&RP
            Diapir Field Statewide and Regional Economic and Demographic Systems Impacts                                  No. 3.
            Analysis, University of Alaska, ISER,  MMS Technical Report No. 88, June 1983.                                Cavitating Water Jet Cleaning Nozzle, Daedalean Associates, TA&RP No. 4.
            Diapir Field Anchorage Impacts, Kevin Waring Associates, MKS Technical Report
            No. 94, March 1984.                                                                                           Attenuation of Surface Waves in Localized Region of the Open Ocean, Stevens
                                                                                                                          Institute, TA&RP No. 5.
            Nuiqsut Case Study, Research Foundation, SUNY Binghamton, 14MS Technical Report                               Research Program Advisory, Marine Board, TA&RP No. 6.
            No. 96, January 1984.
            Nuiqsut Case Study Summary, Al Dekin Jr. , MKS Technical Report No. 96a,                                      Unmanned Untethered Inspection Vehicle Technology, Naval Ocean Systems Center,
            November 1985.                                                                                                and Cold Regions Research and Engineering Laboratory (CRREL), University of
       -n                                                                                                                 New Hampshire, TA&RP No. 7.
            Barrow Arch Transportation Systems Impacts Analysis, BRE Systems, Inc., MMS
            Technical Report No. 104, Ongoing Study.                                                                      Blowout Prevention Procedures, Louisiana State University, TA&RP No. 8.
            Diapir Field Transportation Systems Impacts, Analysis, Louis Berger, Inc.,                                    Ultrasonic Flowmeter Evaluation, Harry Diamond Laboratories, TA&RP No. 9.
            MMS Technical Report No. 105, February 1984.
                   f                                                                                                      Subsea Inspection, Harry Diamond Laboratories, TASRP No. 10.
            Beaufort Sea Area Monitoring Study, Kevin Waring Associates, MMS Technical
            Report No. 107, January 1985.                                                                                 Portable Data Recorder for USGS Inspectors, Harry Diamond Laboratories, TA&RP
                                                                                                                          No. 11.
            Review of Cumulative Impacts Assessment Literature and North Slope Borough
            Development Projects, Maynard& Partch at al., HMS Special Report No.,                                Jrd      Technology Assessment, Harry Diamond Laboratories, TA&RP No. 12.
            February 1985.                                                                                                Fluidic Pulser for Mud Pulse Telemetry. Harry Diamond Laboratories, TA&RP
            Monitoring Methodology and North Slope Institutional Change, Chilkat Insti-                                   No.13.
            tute, MMS Technical Report No. 117, September 1985.                                                           Fluidic Sensor for Hydrocarbon and Hydrogen Sulfide Gas, Tri Tek, TA&RP
            Economic and Demographic Systems of the NSB, University of Alaska, ISER, MMS                                  No. 14.
            Technical Report No. 120, June 1986.                                                                          Hardhat Communicator, Harry Diamond Laboratories, TA&RP No. 15.
            Alaska Statewide and Regional Economic and Demographic Systems:        Effects of
            OCS Exploration and Development,        1986, University of Alaska, ISER, MMS                                 Technology Assessment for OCS Oil and Gas Operations in the Arctic Ocean,
            Technical Report No. 124, July 1986.                                                                          Energy Interface Associates, TA&RP No. 16.
            Barrow Case Study, Chilkat Institute, MMS.Technical Report No. 125, 1986.                                     Fire Suppression Technology, Harry Diamond Laboratories, TA&RP No. 17.
            Workshop Proceedings:    Monitoring Sociocultural and Institutional Change in                                 Overpressured Marine Sediments, Texas A&M University, TA&RP No. 18.
            the Aleut !an-Pribi lof Region, Impact Assessments, Inc., MMS Technical Report
            No. 126. 1985.

                                                     10

               Hurricane-Driven Ocean Currents, Shell Oil Co., TA&RP No. 19.
                                                                                                                                       Mechanical Properties of Sea lee, CRREL, TA&RP No. 40.
               Toxic Effects Of Drill Muds on Coral, USGS, TA&RP No. 20.
                                                                                                                                       Ultrasonic Inspection of. Underwater Structural Joints, Drexel                 University,
               Underwater Acoustic Telemetry, Ocean Electronic Applications, TA&RP No. 21.                                             TA&RP No. 41.

               Pattern Recognition Technology, General Sensors, TA&RP No. 22.                                                          Arctic Underwater Structural Inspection, Busby Associates. TA&RP No.          42.
               Incipient Structural Failure by the Random Decrement Method. University of                                              Ice Forces Against Arctic Structures, University of Alaska, TA&RP No.          43.
               Maryland, TA&RP.No. 23.
                                                                                                                                       Environmental Effects of Wellhead Removal by Explosives, Woods Hole -Oceano-
               Technology Assessment for Estimating Hydrocarbons L            ost During a Blowout,                                    graphic Institution, TA&RP No. 44.
               Coastal Petroleum Associates, TA&RP No. 24.
                                                                                                                                       Field Study of the Dynamic Response of Single Piles and Pile Groups in Stiff
               Overpressures Developed by Shaped Explosive Charges Used to Remove Wellheads,                                           Clay, University of Houston, TA&RP No. 45.
               Naval Surface Weapons Center, TA&RP No. 25.
                                                                                                                                       Behavior of Piles and Pile Groups in Cohesionless Soils, Texas A&M Research
               Detection And Suppression Of Wellhead Fires, National Bureau of Standards                                               Foundation, TA&RP No. 46.
               (KES), TA&RP No. 26.
                                                                                                                                       Study of Method of Design of Piles in Clay Soils Under Repeated Lateral Loads,
               Technology Assessment for Cementing Shallow Casings, Maurer Engineering, TA&RP                                          University of Texas. TA&RP No. 47.
               No. 27.
                                                                                                                                       A Study of Structural and Geotechnical Aspects of Tension-Leg Platforms,
               Casing Wall Thickness Technology, NDE Technology, Inc., TA&RP No. 28.                                                   Sandia Laboratories, TA&RP No. 48.
               Deepwater Structures Technology Assessment, Battelle-Houston, TA&RP No. 29.                                             Fitness -For - Service Criteria for Assessing the Significance of Fatigue Cracks
          .n   (Cancelled.)                                                                                                            in Offshore Structures, TA&RP No. 49.

               Acoustic Imaging Techno     logy. for Underwater Inspection, Naval Ocean System                                         Development and Testing of an Ice Sensor, CRREL, TA&RP No. 50.
               Center, TA&R? No. 30.
                                                                                                                                       Engineering Properties of Subsea Permafrost, CRREL, TA&RP No. 51.
               Technology Assessment for Offshore Pile Design, Carnegie-Mellon University,
               TA&RP No. 3 1.                                                                                                          Dynamics and Reliability of Compliant Drilling and Production Platforms, and
                                                                                                                                       Oregon State University, TA&RP No. 52.
               Recapture Of   Oil from Blowing Wells, Massachusetts Institute of Technology,
               TA&RP No. 32.                                                                                                           Behavior of Concrete Offshore Structures In Cold Regions, TA&RP No. 53.
               Vibration Monitoring of Offshore Structures,       Aerospace Corporation, TA&RP                                         Pile Foundation Design for Ocean Structures, Naval Civil Engineering
               No. 33.                                                                                                                 Laboratory, TA&RP No. 54.

                                                                                                                                       Fracture Analysis and Corrosion Fatigue in Pipelines, Lehigh University, TA&RP
               NDE Round Robin, Mega Engineering, TA&RP No.      34.
                                                                                                                                       No. 55.
               Powering The Cavitation Erosion Cleaning Nozzle, Naval Surface Weapons Center,
               Daedilean Associates, TA&RP No. 35.
                                                                                                                                       Assessment of Structural Icing, CRREL, TA&RP No. 56.

               Marine Riser Strumming Experiment, Massachusetts Institute of Technology,                                               Static Lateral Load Tests on Instrumented Piles in Sand, Earth                  Technology
               TA&RP No. .36.                                                                                                          Corporation, TA&RP No. 57.

               Structural Materials for Arctic Operations       NBS, TA&RP No. 37.                                                     Wave Forces on Ocean Struz;tures, Oregon State University, TA&RP No. 59.
               Statistical   Risk Analysis for Determining BAST, Massachusetts             Institute of                                Foundation Stability of Jackup Platforms, Det Norske Veritas, TA&RP No. 59.
               Technology, TA&RP No. 38.
                                                                                                                                       Tension Pile Test, Joint Industry Project, Conoco Oil, TA&Rp No. 60.
               Cryogenic Control of Blowing Wells, BOM, TA&RP No. 39.

                                                           12,                                                                                                                     13

               Superstructure Icing Data Collection and Analysis, CRREL, TA&RP No. 61.                                        Fatigue of Selected High Strength Steels in Seawater, Florida Atlantic Univer-
                                                                                                                              sity. TA&RP No. 81.
               Southern Bering Sea Production System Study, PMB Systems Engineering, TA&RP
               No. 62.                                                                                                        Numerical Wave Force Simulation, Massachusetts Institute of Technology, TA&RP
                                                                                                                              No. 82.
               Assessment Criteria for Environmental Cracking of High-Strength Tensioned
               Members, Naval Research laboratory, TA&RP No. 63.                                                              Modeling of Ice-Structure Interaction, Massachusetts Institute of Technology,
                                                                                                                              TA&RP No. 83.
               Caisson Monitoring Project. W. S. Atkins, Inc., TA&RP No. 64.                                                  Surface Oil Spill Containment and Cleanup, Veritas Technical Services, Inc- ,
               Deicing and Prevention of Ice Formation on Offshore Drilling Platforms,                                        TA&RP No. 84.
               Clarkson College of Technology, TA&RP No. 65.                                                                  Subsea Collection of Blowing Oil and Gas, Brown and Root Development, Inc.,
               Evaluation of Structural Concepts for Norton   Sound, Chevron Oil, TA&RP No. 66.                               TA&RP No. 85.
               Rig Mooring Reliab ility, EG&G Washington Analytical Services, TA&RP No. 67.                                   ATOS (Antiturbidity Overflow System) Experiment, USGS, TA&RP No. 86.
               SeAfloor Seismic Data Study, Sandia National Laboratories, TA&RP No. 68.                                       Mechanical Properties of Saline Ice, Dartmouth College, TA&RP No. 87.
               Reliability of Gravel Mat Foundations for Arctic Gravity Structures, TA&RP                                     Inspectability of Tension Leg Platform Tendons, John E. Halkyard and Company,
               No. 69.                                                                                                        TA&RP No. 88.
               Trace Elements for Detecting Cracking in Weldments, Colorado School of Mines,                                  Wave Erosion of a Frozen Berm, Arctec, Incorporated, TA&RP No. 89.
               TA&RP No. 70.
                                                                                                                              Evaluation of Short, Large-Diameter Piles for Arctic Applications, The Earth
               Assessment of Analysis Techniques for Compliant Structures, Naval Civil                                        Technology Corporation, TA&RP No. 90.
               Engineering Laboratory, TA&RP No. 71.
                                                                                                                              Underwater Subsea Production System Inspection, Busby Assoriates, TA&RP
               Torsional Evaluation of Stiffening Members in Marine Structures, Lehigh                                        No. 91.
               University, TA&RP No. 72.                                                                                      A Theoretical Investigation on The Behavior of Compliant Risers, Massachusetts
               Soil Flow on Pipelines, Texas A&M University, TA&RP No. 73.                                                    Institute of Technology, TA&RP No. 92.
               Drag and Oscillation of Marine Risers and Slack Cables, Naval Research Labora-                                 Site-Response, Liquefaction, and Soil-Pile Interaction Studies Involving the
               tory, TA&RP No. 74.                                                                                            Centrifuge, The Earth Technology Corporation, TA&RP No. 93.
               Remote Corrosion Monitoring of Offshore Pipelines, Tradco Chemical Corpora-                                    Dynamic Motion Study of a Large-Scale Compliant Platform, Naval Civil Engi-
               tion, TA&RP No. 75.                                                                                            neering Laboratory, TA&RP No. 94.
               Damage Mechanisms in the Placement and Repair of Pipelines in Deep Water,                                      Structural Icing Study, St. George Basin, CREEL, TA&RP No. 95.
               Starfire Engineering, Inc. , TA&RP No. 76.                                                                     Probability Based Design Criteria for Ice Loads on Fixed Structures in the
               Ice Stress Measurements, CRREL, TA&RP No. 77.                                                                  Beaufort Sea, Det Norske Veritas, TA&RP No. 96.
               Structural Concepts for Lease Sale 87, Brian Watt Associates, Inc. , TA&RP                                     Engineering Properties of Multi-Year Ridge Sea Ice, GEOTECH, TA&RP No. 97.
               No. 78.                                                                                                        Punching Shear Resistance of Concrete Offshore Structures for the Arctic,
               Offshore Pipeline Transportation Study for Lease Sale 87, R. J. Brown and                                      TA&RP No. 98.
               Associates, TA&RP No. 79.                                                                                      Measurement of Ice Stress Around a Cassion Retained Island in the Beaufort
               Development of a New Philosophy for Effective Underwater Inspection, Under-                                    Sea, K. R. Croasdale and Associates, TA&RP No. 99.
               water Engineering Group, TA&RP No. 80.                                                                         Feasibility of Production, Loading and Storage Systems for the North Aleutian
                                                                                                                              Basin, Brian Watt Associates, Inc.. TA&RP No. 100.

                                                        14                                                                                                             15

               Residual Strength of Offshore Structures after Damage, Lehigh University,
               TA&RP No. 101.

               Analysis of Oil-Slick Combustion, Center for Fire Research, TA&RP No. 102.

               Ocean Wave Simulation Model, University of Wyoming, TA&RP No. 103.

                                                     16

                                                                                                                                                                                                                  2

                                                                                                                              We hope these comments will be helpful to you in preparing the final document.
                                                                                                                              If you have any questions regarding our comments, or would like additional
                                                                                                                              information, please contact me at FTS 776-8765.

                January 20, 1987

                N3615(475)
                                                                                                                              jo@hnC'hristiano

                Memorandum

                To:        Division of Refuge Management, Fish and Wildlife Service

                From:      Chief, Air Quality Division

                Subject:   Draft Arctic National Wildlife Refuge, Alaska, Coastal Plain
                           Resource Assessment and Legislative Environmental Impact Statement

                The Air    Quality Division has reviewed the draft Arctic National Wildlife
                Refuge,    Alaska,   Coastal    Plain   Resource    Assessment    and Legislative
                Environmental Impact Statement (LEIS). We offer the following comments.

                The discussion of air quality impacts of the proposal is inadequate. Air
                quality effects are dismissed as minor -- gaseous and particulate emissions
                which will "temporarily degrade local air quality". No data are Included in
                the LEIS regarding emissions of specific pollutants such as sulfur dioxide,
                hydrogen sulfide, particulate matter, n     -Itrogen oxides, and volatile organic
                compounds (the latter two being precursors of ozone).       The proposal includes
                several sources of such pollutants -- either six or seven large central
                processing facilities. two small central processing facilities, between 30 and
                60 permanent drilling pads, diesel engines, motor vehicles, and between 35 and
                50 million cubic yards of gravel for construction, operation, and maintenance.
                There is also no discussion of any mitigating measures to be applied in order
                to reduce the air pollution from those sources.

                The Arctic National Wildlife Refuge is a class 11 clean air area.         The Clean
                Air Act has established increments for sulfur dioxide and particulate matter
                which cannot be exceeded once baselines have been established for those
                pollutants. Those haselines may have been established through monitoring data
                obtained from the energy related activities at Prudhoe Bay.

                The final LEIS should be revised to Include a more detailed air quality
                analysis.    Monitoring and modeling data should be used to calculate existing
                background air pollutant concentrations and to determine the potential
                additional impacts     of emissions      resulting from the proposal and all
                alternatives. The analysis should also include a discussion of the possible
                impacts of the air pollution on the physical environment, Including in
                particular, impacts on sensitive plant and animal species.        In addition, the
                analysis should include a discussion of the mitigating measures to be applied
                to reduce or eliminate air pollution.

                    01
              '4@ -;
                          United States Deparlment of'. file Interior

                                      NATIONAL I'ARK SI:HVICE                                                                                                             2.
                                           1,A). H(PX .17127
                                      WASHINGION, DA. 20013-7127                                       3.   Chapter II ("Existing Environment"), Biological Environment,
              L1716 1.7(76.2)                                                                          Coastal and Marine Environment, p. 27; add the following new
                                                                                                       paragraph  at the end of the Section:
            FEB @ 4 1987                                                                                          In the northeasternmost corner of the 1002 section, the
              Memorandum                                                                                          133,729-acre Kongakut River-Beaufort Lagoon area was
                                                                                                                  identified as a potential National Natural Landmark,
              To:        Director, U. S. Fish and Wildlife Service                                                because it contains: (1) a unique offshore bar and
                                                                                                                  lagoon ecosystem which supports a relatively diverse
                         Attention:   Noreen Clough                                                               marine biota and terrestrial biota using the area for
                                                                                                                  nesting and migration rests; and (2) an arctic river
              From:      ,O"Ociate.Director, Planning and Development                                             which flows from the mountain front and enters the
                                                                                                                  lagoon, ecosystem, perpetuating the unique marine.
              Subject:   Arctic National Wildlife Refuge, Alaska Coastal Plain                                    conditions of freshwater throughout most of the summer,
                         Resource Assessment   (DES 86/0045)                                                      and the presence of spruce-trees in the upper course of
              In response to your November 24, 1986,        memorandum, we have                                   the river, accompanied by elements of the boreal flora
              reviewed the subject assessment and have the following comments.                                    (Koranda and Evans, 1975).    In addition, nearby Angun
                                                                                                                  Plains was identified as a potential National Natural
              We recommend the following changes and additions         to subject                                 Landmark, as a good example of glacial gravel outwash
              assessment.  Our recommended changes to the draft text are under-a                                  plains found near the areas of maximum Pleistocene
              lined.                                                                                              glaciation (Detterman, 1974).
                                                                                                       4. Chapter VI (NEnvironment Consequences'), References Cited for
              1.    Executive Summary, Vegetation and Terrain Types, p. 3; change                      Biological Environment (Chapters II and VI), pp. 152 and 155;
              second sentence of last paragraph  to:                                                   add:
                         located in the foothills in the southern part of the                                     Detterman, R. L., 1974, The Arctic Lowland Region:
                         .1002 area, the spring and its surrounding area of                                       Potential lifeform and lifeform natural landmarks-
                         approximately fiAJ acres have been identified as a                                       report prepared for the National Park Service by the'
                         P.otential National Natural Landmark.                                                    U.S. Geological Survey, 418 p.
              2.    Chapter II ("Existing Environment"), Biological Environment,                                  Koranda, J. J., and Evans, C. D., 1975, A discussion of
              Sadlerochit Spring Special Area, p. 25; change the first three                                      sites recommended as potential natural landmarks in the
              sentences  of the first paragraph to:                                                               Arctic Lowland Natural Region, northern Alaska: report
                                                                                                                  prepared for the National Park Service by the Tundra
                         Sadlerochit Spring and its surrounding area (approxi-                                    Biome Center, University of Alaska, Fairbanks, Alaska,
                         mately 6" acres), in the southern part of the 1002                                       189 P.
                         area, west of the Sadlerochit River pl.. IA) have been
                         identified as a ROtential National Natural Landmark                           In addition, we have attached a list of all potential National
                         (Detterman. 19741 see also Bliss and Gustafson, 1981).                        Natural Landmarks located in the entire Arctic National wildlife
                         The National Natural Landmarks Program was established                        Refuge.  No sites have et been designated within the refuge.
                         to encourage the preservation of natural areas illus-                                                 y
                         trating the diverse geological and ecological character
                         of the  United States.    Areas qualifying as National
                         Natural Landmarks must constitute best examples of
                         natural communities or geologic features characterizing
                         one of  the 33 Physiographic t)rovinces composing the
                         Nation, and should be relatively free of human distur-                        Attachment
                         bance:  designation of a site as a National Natural
                         Landmark does not affect its ownership, management, or
                         use, however,

                                                                                          m         Ch     a,      C?%
                                                                                                                                                   44                                                     CF%   Cp%                                        0%
                              .4                                                                                                                                                                                                                           C4

                                                                                                                                                                                         u 0
                                                                                                                   sd
                              go

                        14                                                                                                                                                                        94
                                                                                                                                                                                            a

                                                                                                                             14
                        0     0                                                                                                                                                                                                                  cc
                                                                                                                                                                                                  &j
                                           aj      &j                                                                                              0                                     41 v     rA
                                                   1*4
                                                                                                                                                                                                                                       to
                        u     0       v
                                                                      Sa CC    S          4-11S     Is     S       4-1 S                                                                                                                         0,
                                      64                              4A       4,         j4        aj                                                                                   v  (D            4-1
                                                                                                                                                                                         0-0
                                                                                                                                                                                                                                                -0-01

                                                   P.        w        A. 96    ILI        0c  Ow                                                                                                                                 4;
                              tic     96                                                                           no        93 c          96
                                                                                          0                            0     0  0,                 4                                        :3    W       0.    P.                     06
                                                                      1*                  0a  0     14,    44      10, 44    440           0       0                                        1
                                                                      0  0     0          4 4 0
                                                                0     14 -4               41                                                                                                                              0.
                                                                                                                             41                    100                                                    4     4
                                                                                                                             4                                                                    W       0     a
                                                                         4j                                2                                                                                      *a                                   0
                                                                                          A                                                                                                                               .4     .4    14
                                                             bo       a  a     a          uu               u       co  u     li li                                                          0                   .
                                                             9: .4    u  u     u          -A  U     14             u   @4                  u                                                44                            go                               u
                                      64   64                            W     14             $4                   M                       14                                                             u     u         u      u     9
                              :2                             Q X:                                                      xj:      x-                                                       Iwo 11
                                                                                                                                                                                         0 @              A     I         I      I     I
                        41
                                                                      00                  00  0     0    .8                  00
                                      w                      C4       UN                  C4 In                              00                                                                                                        (Y.
                                      :t                     -                            - -                      .   Ct    Ct C@                                                       @4 0                                    C4    C4
                                      M                               'n                                           1-1 %0    " -                                                         3 -a     ,
                                      t4                              en                                           94        M                                                           0
                                           cli
                                                                                                                                                                                                          C4    M

                                                                                                                                                                                            41
                                                                                                                                                                                            u

                                                                                                                                                   lu                                    61
                                                                                                                                                                                            0
                                                       Ph
                                                                                                                             v             Icc     ou                                                                                               .0
                                           91      a                                                                                                                                                                        co   44        0        1.1    4
                                                                                                                                                                                                                          1 "1   0
                                                   0                  96                                                                                                                                                  A
                                                                                                                                                                                                                                 ;01   1. too
                                                                                                                       po.   P. P. r                                                                                      8 a    a     0.3          '&     C'q
                                                                                                                   :h              0                                                                      co    000.      bo     m     D.           C13
                                                                                                                                                                                                                30        1,,4
                                                             @4                                            -0      1-0                                                                                    -,4
                                                                                                                                            0
                                                             H
                              64      4
                              14      N                                        ce                                            :3 0 Fj       2 44                                                                                            0
                              93           0                                   u                                                           .90                                                    -,4     P.                     4)
                                                   0                                                                               .0
                                                                                                                                                                                                  ca
                                                                                                                                                                                                                143
                                                                                          w                        ow
                                                                                                                                           M0
                                      bo   a u                        -0
                                                                                          14
                                                   60        In                           04
                                                                                                                                           41

                                                                                          Key

                                  Bliss/Gustaf.    - Lawrence C. Bliss and Karen M. Gustafson, "Proposed Ecological Natural Landmarks in the
                                                       Brooks Range, Alaska," National park Service, March 1981.

                                  Canning River    - U. S. Geological Survey topographic quadrangle, 1:250,000 series.

                                  Dean             - Dr. Frederick C. Dean, University of Alaska

                                  Demarcation Bay  - U. S. Geological Survey topographic quadrangle, 1:250,000 series.

                                  Demarcation Pt.  - U. S. Geological Survey topographic quadrangle, 1:250,000 series.

                                  Detterman        - Robert L. Detterman , "The Arctic Lowland Region: Potential Landform and Lifeform Natural
                                                       Landmarks," U. S. Geological Survey. November 1974.

                                  HCRS, 1979         Backlog review of potential natural landmarks by the Heritage Conservation and Recreation
                                                       Service staff in the spring of 1979.

                                  Koranda/Evans      John J. Koranda and Charles D. Evans, "A Discussion of Sites Recommended as Potential Natur-
                                                       al Landmarks In the Arctic Lowland. Natural Region, Northern Alaska, Tundra Biome Center.
                                                       University of Alaska, Fairbanks, Alaska, April 1975.

                                  Lent               Dr. Peter C. Lent, Assistant Leader, Alaska Cooperative Wildlife Research Unit.

                                  Mt. Michelson    - U. S. Geological Survey topographic quadrangle, 1:250,000 series.

                                  Murray           - Dr. David F. Murray, Professor of botany, Institute of Arctic Biology, University of Alaska,
                                                       Fairbanks, Alaska.

                                      Indicates   positive reco mme ndation
                                      indicates   negative recommendation

                                  The significance  and protection status of  theme study  sites are rated according to the following scheme:

                                      Priority    I-High degree of national  significance;  recommended without reservation.
                                      Priority    2-Definitely eligible and  recommended, but not quite as good as Priority 1.
                                      Priority    3-A good site, but not quite nationally significant.
                                      Priority    4-Not recommended.

                                      Priority    A-Site in serious Impending da nger.
                                      PriorIty    B-Site in some jeopardy.
                                      Priority    C-Site In no apparent danger.
                                      Priority    D-Relative jeopardy unknown.

                                                                      F-84

                                                                        Comments from State and Local Governments (S)

                                                                                                                                                                        Page

                                                                 State of Alaska      .............  ....................................................................................  S-1

                                                                 Alaska State. Legislature (Rep..Sam Cotten)                  .................................................. 16

                                                                 Arctic Village Council        ..........................................; ............................................. 17

                                                                 California Department of Fish and Game                    ..................................................... 18

                                                                 City of Kaktovlk      ..............................................  ................................................... 19

                                                                 Massachusetts Department of Fisheries, Wildlife &

                                                                   Environmental Law Enforcement                 .................................................................. 20

                                                                 North Slope Borough           .................. .......... ....................................................  ...... 22.

                                                                 University of Maska, Geophysical Institute                 ......;....................  ........................ 37

                                                                 Venetia \Allege     ...........................  ........................................................................ 41

                                                                              STEVE COWPER, GOVERNOR
                 ONE                 or RMM
                                                                              CENTRAL OFFICE                             Mr.  Robert Gilmore                     2                    February 6, 1987
                               OFFICE OF THE "VERNO11                         P.O. BOX AIN
                                                                              JUNEAU. ALASKA 99811-0165
                                                                              PHONE: (90) 465-3562
                                OFFICE OF MANAGEMENT AND BUDGET                                                          Congress failed to act on the        recommendations within the ten-year
                           DIVISION OF GOVERNMENTAL COORDINATION                                                         period, the recommendation of        the Secretary and Governor would-be
                 SOUTHEAST REGIONAL OFFICE    SO-UTHCENTRAL REGIONAL OFFICE NORTHERN.REGIONAL OFFICE                     implemented.
                 431 NORTH FRANKLIN           2600 DENALP STREET            675 SEVENTH AVENUE
                 P.C. BOX AW. SUITE 101       SUITE 7W                      S TA TION H                                  it is imperative that the recommendations from the Governor of
                 JUNEAU. ALASKA 99811-016S    ANCHORAGE'ALASKA 99503-2798   FAIRBANKS, ALASKA 99701-4596                 Alaska be included with those of the Secretary of the Interior
                 PHONE: (9D7) 465-3562        PHONE (9071274-1581           PHONE: (907) 456-W4                          given the significant interests of the state involved in both the
                                                                                                                         leasing.and protection of resources in the 1002 area. Not only
                                                        February 6,    1987                                              is the state a sovereign steward of natural resources with
                                                                                                                         regulatory responsibilities in the area, it is the principle
                                                                                                                         owner of lands which any ANWR production transportiitiofi@systdm
                                                                                                                                   Sam-

                 Mr. Robert Gilmore
                 Regional Director                                                                                       This recommendation is based on several salient facts. First,
                 U.S. Department of    the   interior                     FEB   607                                      Congress has mandated that fish and wildlife populations in ANWR
                 U.S. Fish and Wildlife     Service                                                                      receive a very high level of protection. Because of this man-
                 1011 East Tudor Road                                                                                    date, USFWS is required to take a conservative approach when
                 Anchorage, AK 99503                                                                                     making decisions regarding the impact of development activity on
                                                                                                                         the refuge's fish and wildlife populations. Second, while a
                 Dear Mr. Gilmore:                                                                                       sizable amount of information has been collected on the impact of
                                                                                                                         oil and gas activity on the Central Arctic Caribou Herd,
                 T                                                                                                       questions remain regarding the potential impact of the oil and
                 he state has reviewed the       Draft Arctic National Wildlife Refuge                                   gas,activity on the Porcupine Caribou Herd population because of
                 (ANWR), Alaska, Coastal Plain Resource Assessment 1002(h) Report.
                                                                                                                         its larcer size. distribution and movement Patterns. and popula
           L     We appreciate the additional time granted the stateto review
                                                                                                                         tion dynamics.. Contrary to the statements            made on page 112 of
                 this important report. Based                      aw of the substantial                                 the draft 1002(h) report, at this point in            time there is
                                                  .2_9jL_QgL_x=
                                                        in the draft 100A2h)
                 amount of information contained                                   report, we                                                                                                       ould
                 strongly s            e conclu_s-ion`-tTIia_toi                                                         inadequate information to predict what population impacts w
                                                                land gaas e-      ora on _e                              occur'if oil and gas development were to take place in the core
                 a I          NNE consistent with the chiet,                                 6
                                                                  f-,-p:urpose
                                                                     Purpose    ahj @ef                                  calving area. Third, protection of the herd and its habitat is
              _L0_                                                                                                       of great concern to our Canadian neighbors, and the deferral and
                 The State of Alaska recommends that Congress immediately open               the                         studies will respect those concerns.
                 1002 area to oil and gas leasing, with the exception of the area                                        Special Values of      AHWR
                 described by U.S. Fish and Wildlife ServidV"1MFWST-as tne -core--
                      ou ca v*              The state strongly recommends that leasing                                   We predicated our      review on two fundamental facts inherent to
                 Carib      I i     area.
                        49;L4caMiNg@aarea be deferred for a ten-year period.                                             ANWR. First, the       fish and wildlife resources of ANWR are of
                 During this ten-year period, the Department of the Interior (DOI)                                       significant state, national, and international importance               .  The
                 should establish an ANWR Caribou Impact Assessment Study Group                                          Porcupine Caribou Herd, which numbers some 180,000 animals,
                 composed of federal, state, university, and private researchers                                         annually migrates between Canada's Northwest Territories and
                 to further study the potential impacts of oil and gas activities                                        Alaska's arctic.coastal plain where it spends a portion of each
                 in the calving area on the Porcupine Caribou Herd. The study                                            summer. These animals are of great importance to both the people
                 should be conducted over a seven-year period following                                                  of Alaska and Canada. The Porcupine Caribou Herd and other fish
                 commencement of the first exploratory well and result in a report                                       and wildlife of the ANWR coastal plain arethe foundation of the
                 to the Secretary of the Interior and Governor of Alaska. The                                            subsistence way of life to the residents of Kaktovik, Arctic
                 report would seek to document the biological importance of the                                          Village, Venetie, and Fort Yukon in Alaska and Old Crow in the
                 core calving area, the effects of oil and gas activities in the                                         Yukon Territory of Canada. Furthermore, within the refuge, "The
                 1002 area on the Porcupine Caribou Herd, and the effectiveness of                                       1002 area is the most biologically productive part of the Arctic
                 mitigation measures employed in the 1002 area to minimize.adverse                                       Refuge for wildlife and is the center of wildlife activity on the
                 impacts to caribou. Based on the report findings, the Governor                                          refuge." (Draft 1002(h) report, page 46.) The Alaska Department
                 and Secretary would recommend to Congress to extend the deferral                                        of Fish and Game has conducted an extensive review of ANWR fish
                 or open the core calving area to oil and gas leasing. If                                                and wildlife information which is available on request to USFWS

       01-A35LH

    Mr. Robert Gilmore			- 3 -				February 6, 1987

    and other interested parties.  The department's data on
    distribution and abundance of fish and wildlife and areas of
    special concern confirm the great importance of ANWR's nenewable
    resource base.

    The second intrinsic feature of ANWR is that is has high oil and
    gas potential.  The state concurs with the draft 1002(h) report
    findings on page 1 that the 1002 area, "... is clearly the most
    outstanding oil and gas frontier remaining in the United States,
    and could contribute substantially to domestic energy supplies."
    As you know, the Alaska Department of Natural Resources has
    recently made public a preliminary appraisal it conducted of
    petroleum resource potential in ANWR's coastal plain.  Alaska's
    report confirms DOI's conclusion that ANWR's coastal plain has
    the potential for an unusually large accumulation of oil.

    Past Lessons Learned from Oil and Gas Activities in Alaska

    As indicated in the draft 1002(h) report, development of ANWR's
    coastal plain will alter the existing environment and to some
    degree affect the Porcupine Caribou Herd.  It is critical that
    appropriate and effective measures be taken to minimize the
    potential adverse effects of oil and gas activities on ANWR's
    coastal plain.  Alaska has nearly two decades of experience in
    dealing with oil exploration, and lessons of the past will serve
    as a guideline for development in the future.  In the event
    Congress permits exploration, the state would encourage that the
    best and latest technology be used.

    The state assumes the draft 1002(h) report was not intended to be
    all inclusive, and that more detailed performance, standards would
    be developed in concert with the state prior to any lease sales
    or any transfer of subsurface rights.  Clearly, additional time
    will be needed in order to develop an adequate set of terms and
    conditions designed to ensure protection of air and water quality
    and fish and wildlife resources.  With this understanding, our
    general comments on the proposed mitigation measures summarized
    in the draft 1002(h) report are included in Enclosure A.

    Federal/State Consultation and Resolution of Issues

    The state is encouraged to read on page 97 of the 1002(h) report
    that "The FWS would emphasize early and continuous consultation
    and coordination with leaseholders, permittees, and state and
    federal agencies at the start of planning."  Consistent with this
    federal intent, the state feels it is essential that DOI estab-
    lish a formal consultation process with the state and other
    parties in order to clearly establish at what points in the
    process and what level of detail different issues and authorities
    will be addressed.  This process would also allow the opportunity
    for the parties to clarify their respective authorities.

    Mr. Robert Gilmore			- 4 -				February 6, 1987

    permitting, and field procedures to avoid duplication or
    conflicting efforts.  These consultants should identify or
    acknowledge existing regulatory requirements and authorizations
    at federal, state, and local levels.  At a minimum, it should
    address different agencies' review times and public notice
    requirements.  Issues that should be addressed are the timing of
    the various phases of review for specific projects; the level of
    detail to be addressed at each; and the coordination of
    permitting, review of plans of operations, field surveillance,
    and field approvals.  Experiences associated with the development
    of the Trans-Alaska Pipeline System (TAPS) and the proposed
    Alaska Natural Gas Transportation System (ANGTS) from Prudhoe Bay
    to the Canadian border could provide useful models for
    cooperative management programs.

    A coordinated interagency process for planning, design review,
    permitting, field surveillance, compliance and enforcement, and
    reclamation would serve the state, DOI, and industry well.  The
    state's existing coastal management consistency process as well
    as the jurisdiction of state agencies such as the Departments of
    Fish and Game, Environmental Conservation, Natural Resources and
    the Alaska Oil and Gas Conservation Commission need to be
    acknowledged and effectively implemented in the review and
    permitting of each stage of the overall project.  Lack of suffi-
    cient and effective coordination could lead to each agency
    dealing independently with applicants and could result in permit-
    ting inefficiencies with duplicative and inconsistent compliance
    and enforcement actions.

    Topics Needing Further Discussion in the Final 1002(h) Report

    Overall, the State finds that USFWS did an excellent job in
    compiling and summarizing a large amount of biological and
    geological information in the draft 1002(h) report.  Considerably
    more work needs to be directed to the following eight issues of
    major importance to the state.

    1.	Standards for Air and Water Quality Protection

    	The draft 1002(h) document focuses primarily on a discussion
    	of habitat and wildlife issues and petroleum potential.  The
    	document is considerably weaker with respect to air, land,
    	and water quality issues.  DOI must acknowledge and accu-
    	rately reflect in the final 1002(h) report state authority
    	in this area and the body of regulations and requirements
    	associated with sound environmental practices.  A list of
    	pertinent state authorities is included in Enclosure B for
    	your reference.

    	a)	Air Quality Management

               Mr. Robert Gilmore                 5                  February 6, 1987                        Mr. Robert-Gilmore                  6                  February 6, 1987

                          Particular attention should be paid to emissions                                               Hazardous Waste Management
                          associated with start-up and upset flaring, emissions
                          of nitrogen oxides, and the best available technology                                          No discussion of hazardous waste management is included
                          review process associated with "prevention of signif-                                          in the draft 1002(h) report. Hazardous waste
                          icant deterioration" review.                                                                   management is governed by stringent requirements under
                                                                                                                         the federal RCRA., Transportation of hazardous mate-
                           rilling Wastes and Solid Waste Management                                                     rials is regulated by the federal Department of
                    9)Major waste streams include garbage, drilling wastes,                                              Transportation. Proper management must be addressed.
                          metal wastes, and oily wastes. our experiences on the                                          Oil Spill Prevention and Response
                          north slope verify that it is very important that
                          proper management of all these wastes be addressed from                                        The draft 1002(h) report refers to the need to address
                          the beginning.                                                                                 oil spill control requirements at page 84. more
                          Drilling wastes are of particular concern.        Improper                                     detailed plans will be required under the cited state
                                                                                                                         and federal statutes. Provision for a coordinated
                          management of drilling wastes can result in the contam-                                        response capability should be provided by stipulation.
                          ination of adjacent habitats with potential negative
                          effects to the vegetation and fish and wildlife                                    2.    Provisions for Offshore Support Facilities
                          species. Management of drilling wastes should involve
                          development of best practices to minimize waste                                          It is important that the final 1002(h) report and management
                          generation and to ensure total containment or injection                                  alternatives address the siting in ANWR of oil and gas
                          of all produced wastes. Best practices should be based                                   facilities needed to support offshore oil and gas develop-
                                                                                                                                                                          uliffidi7gC
                          in part on a thorough evaluation of the effectiveness                                    ment occurring adjacent to ANif @on st@ate-:6Wh-e`d' s        ad
                                                                            in Alaska.
         CP               of past practices of drilling waste disposal
                          Recent efforts by the
                                                  Aldbrkd Ut2PCtLr_111e11r UL r,11-                                wr = en, none of the alternatives specifically state that
                          vitonmental Conservation to develop a workable      set of                               support facilities, if needed, would be permitted.
                          regulations governing these activities are nearing
                          completion and should be viewed as the framework for                               3.    Alternative Development and Transportation Scenarios
                          developing specific requirements. In addition, the
                          U.S. Environmental Protection Agency is currently                                        Statements in the draft 10 2(h)     report refer to 'atranspor-
                          studying the issue of proper drilling waste disposal                                     tation corridor (road and pipeline) between ANWR and TAPS
                          and should soon have a report available.                                                 Pump Station 1 in Prudhoe Bay. The state recognizes that
                                                                                                                   the scenario which was analyzed is only one of many poten-
                          Provisions for pickup of windblown litter and other                                      tial alternatives. The actual alignment of transportation
                          debris must be addressed by stipulation. Early plan-                                     faci  1ities if, in fact, discoveries are made and any facil-
                          ning for sound disposal of each waste stream will lead                                   ities  are required, will be dependent upon many factors
                          to the best environmental results.                                                       including the location and size of any reserves discovered,
                                                                                                                   the need to accommodate delivery of any additional nearby
                    c)    Liquid Waste Management.                                                                 reserves, terrain constraints, habitat considerations, and
                          Possible liquid waste discharges include domestic                                        project economics. we suggest that the final report reflect
                                                                                                                   the interrelationship of these factors in determing the size
                          wastewater, reserve pit fluids, produced water dis-                                      and location of needed transportation facilities.         In
                          charges, hydrostatic test discharges, vessel rinsates                                    addition, we suggest that the report describe the 1eve3 of
                          and radiographic wastes. Each needs to be identified                                     any review that will proceed these decisions.         Interagency
                          And provisions made for proper disposal. The existing                                    and public reviews of TAPS and ANGTS projects provide a good
                          local, state and federal regulatory structure, ranging                                   model of the scope of analysis which accompanies the review
                          from plan review to the use of the best practicable                                      and approval of a major transportation project.
                          technology, needs to be addressed. Reinjection of
                          produced waters and non Resource Conservation and                                  4.    Subsistence ANILCA 810 Analysis
                          Recovery Act (RCRA) regulated liquid wastes is
                          routinely practiced on state lands on the north slope.
                    C)

            Mr. Robert Gilmore               7                February 6, 1987                     Mr. Robert Gilmore               8                 February 6, 1987

                  The draft 1002(h) report does not address the process by                              water reservoirs that have been developed. The majority of
                  which the impacts of oil and gas development on subsistence                           these reservoir*sites are depleted deep gravel mine sites
                  activities will be identified and mitigated. Such an                                  that have been flooded with surface water. Other sites are
                  analysis is required by Section 810 of the Alaska National                            shallow tundra lakes that have.been deepened to provide
                  Interest Lands Conservation Act (ANILCA).                                             winter water supplies. These water reservoirs are filled
                                                                                                        either passively or actively from nearby drainages during
                  impacts of oil and gas activity in the 1002 area on fish and                          the,spring breakup period and are, in general, isolated from
                  wildlife resources can adversely affect human uses of these                           river and stream systems during the remainder of the year.
                  resources. This is true both in the 1002 area and in other                            DOI should initiate a more thorough analysis of similar
                  Canadian and Alaskan communities that rely on wildlife which                          alternatives for industrial water use in the 1002 area.
                  use the 1002 area, most notably the Porcupine Caribou Herd.
                  The draft 1002(h) report does not present a complete picture                     6.   Gravel Use
                  of subsistence uses in the area. The discussion focuses
                  principally on subsistence uses in the community of                                   Gravel sites in ANWR should be sited, developed, and re-
                  Kaktovik, and makes only passing reference to some but not                            claimed in such a manner that overall impacts to water
                  all other communities that use the Porcupine Caribou Herd.                            quality and fish and wildlife resources are mitigated.
                  A more comprehensive discussion of subsistence uses by                                Plans for gravel removal should include detailed plans for
                  communities that use Porcupine Caribou Herd is required in                            the reclamation of the site to be conducted in phases
                  order to better assess the future impacts of development in                           concurrent with the removal of gravel. Gravel sites may
                  the coastal plain. The potential impacts associated with                              also be developed in such a manner that they can be used as
                  oil and gas exploration and development in the 1002 area,                             water sources for both exploration and development.
                  like the siting and design of transportation facilities,
                  cannot be addressed with certainty until exploration has                         7.   Disputed Acreage
                  confirmed the existence and location of potential oil-and
                  gas fields and some understanding of the scope of                                     Although the draft report references the submerged lands
                  development is known.   Enclosure C describes the basic re-                           ownership dispute between the state and federal government
                  quirements of ANILCA 810, and provides a recommended                                  regarding the coastal lagoons between the mainland and
                  approach for meeting these requirements.                                              offshore barrier islands, it does not address the ownership
                                                                                                        status of the beds of nontidal naviqable waters. The state
                  Water Availability and Use                                                                                      submerged lands underlying the
                                                                                                        Aichilik, Jago,'Okpilak, Hulahula, Salerochit, Staines,     d
                  The draft 1002(h) report correctly notes that water re-                               Canning rivers within the 1002 area.
                  sources in the 1002 area are very limited and confined to
                  the surface. Most of these water sources freeze solid by                         8.   Decision Rules and Mitigation Policy
                  late winter. Given the paucity of fresh water for indus-
                  trial use within the 1002 area, the draft report concludes                            The terms "avoidable adverse impacts" and "unnecessary
                  that adjacent marine waters must be viewed as a water                                 adverse effects" are not defined and do not appear in USFWS
                  resource. Little attention is given to other alternatives                             Mitigation Policy (Federal Register, Vol. 46, No. 15).
                  used elsewhere on the north slope, such as snow melters and                           Adding further to the confusion is a list of "unavoidable
                  deep thaw lake reservoirs.                                                            effects" on page 101 that includes a mix of those that are
                                                                                                        truely unavoidable (e.g., loss of habitat by gravel overlay
                  Fresh water for use in the Prudhoe Bay oilfield was taken                             for roads and pads) with many that are avoidable with proper
                  from the@Sagavanirktok River adjacent to the Deadhorse                                design (e.g., erosion and ponding along roads, water storage
                  industrial area during the early years of that field's                                pits in streambeds).
                  development. This removal of water from the Sagavanirktok
                  River resulted in dewatering of fish overwintering habitats                           There also appear to be discrepancies  between the explana-
                  with documented mortality of large numbers of fish. As a                              tion regarding Resource Category 1 and 2 in the draft
                  consequence, the state no longer allows the use of water                              1002(h) report and the explanation for both of these cat-
                  from this and similar sources. Currently, in order to                                 egories in the federal mitigation policy regulations.
                  provide fresh water for industrial uses in the Prudhoe Bay                            Further, the draft 1002(h) report makes no mention of the
                  area, the state requires the use of several large surface                             requirement for "no significant adverse affect" is provided
                                                                                                                                                                    @
                                                                                                                                                                    -p
                                                                                                                                                                    t)e

              Mr. Robert Gilmore                9                 February 6, 1987

                    under Section 1002(h) of  ANILCA.  DOI chould address theta
                    apparent inconsistencies  With USFWS Mitiqation policy in the                       Mr. Robert Gilmore               110                February 6, 198 7
                    final 10021h) report.
                 @__A, discussed earlier in our comments, the Alaska Coastal                            bcc's continue:
                    management Program standards and review procedures need to
                    be addressed in the final 1002(h) report. in particular,                                 Bob Arnold, DNR, Juneau
                      fe   ce should be made to the Habitat Standard                                         Tom Hawkins, DNR, Anchorage
                     6 AAc ito.1301 which requires habitats to be managed an a*                              Jim Eason, DNR, Anchorage
                    to maintain or enhance their characteristics and that uses                               Bob Butts, DNR, Juneau
                    and activities which will not conform to this Ahandard may                               Gary Gustafson, DNR, Anchorage
                    @: allowed if there in a significant public need and there                               Norman Cohen, DFG, Juneau
                     6 no feasible acid Prudent alternative to most the public                               Bruce Baker, DFG, Juneau
                    need.                                                                                    Al Ott, DFG, Fairbanks
                                                                                                             Lance Trasky,.DFG, Anchorage
              CoAclusion                                                                                     Amy Kyle, DEC, Juneau
                                                                                                             Keith Kelton, DEC, Juneau
              R00ognizinq the  important renewable and nonrenewable resource                                 Doug Redburn, DEC, Juneau
              Values found in  ANWR, the state fully supporta the opening of the                             Larry Diedrick, DEC, Fairbanks
              coastal plain to oil and gas leasing subject to appropridto and                                Bob Martin, DEC, Juneau
              effective mitigation b4sed on our firm belief thdL expluration,                                Mike Wheeler, DEC, Anchorage
              development, and production can occur in a manner consistent wil;h
              the established purposea of ANWR. we look forward to reviewing                           vh87011201kfi
              the final 1002(h) report and actively pursuing a joint consulta-
              tion process in the near future   to resolve specific aspects of
              Concern to the state of Alaska.

                                                sincerely,

                                                Robert L. Grogan
                                                Director

              Enclosure

              eel   Lieutenant Governor Steve McAlpine
                    Commissioner Dan Collinsworth, DFG, Juneau
                    Commissioner Judy Brady, DOR, Juneau
                    Commissioner Dennis Kelso, DEC, Juneau
                    John Katz, Office of the Governor, Washington DC
                    Rod Swope, Office of the Governor, Juneau
                    Mayor George Ahmeogak, North Slope Borough,   Barrow
                    Mayor Loren Ahlers, Kaktovik

      M

                                         ENCLOSURE A                                                 Enclosure A                      2
                         State Comments  on Summary of Recommended
                             Mitigation  for the 1002 Area                                           and clarification is needed in order to interpret how and when
                                                                                                     they will be used and implemented.

                                                                                                     Stipulation 1        Sensitive Habitats and Species:
             The following comments are provided within the context of the
             federally proposed stipulation package summarized on pages                                                   As written it is unclear how this stipulation
             145-147 of the draft 1002fh) report. Our comments represent the                                              would be enforced. DOI should define what is
             state's position in response to the specific federal proposal and                                            included in the term "non essential facil-
             do not represent the state's total concern regarding mitigation                                              ities."
             requirements. The state reserves the right to comment further on
             stipulations not yet included or discussed with DOI. in addition                        Stipulation 2        Road and Drainage Designs:
             to the following major comments on the specific stipulations,
             there are a number of terms and conditions which should be added.                                            Roads and other facilities should be de-
                                                                                                                          signed, constructed, and maintained in such a
             First, there are mitigative measures for certain "non evaluation"                                            manner that the following performance stan-
             species mentioned in the species discussions in the                                                          dards are achieved: natural drainage is
             "Environmental Consequences" chapter of the draft 1002(h) report                                             maintained; free passage of fish is provided;
             that are not contained in the summary section. These mitigative                                              gravel fills are stable; upslope ponding and
             measures should be added to the summary section. Second, there                                               downslope dewatering is prevented; the number
             are a number of factors which are either not addressed or not                                                of stream crossings is minimized; natural
             handled in sufficient detail in order to provide for an overall                                              floodplains and flow patterns are maintained;
             effective mitigation program. Examples include the following:                                                spring areas are avoided; and road alignments
             coordinated state/federal process for design review, permitting,                                             are perpendicular to stream flows and sited
             field surveillance, compliance, and enforcement; rehabilitation;                                             in areas of minimal floodplain width. Design
             maintenance of public fish and wildlife resource use; material                                               criteria and specifications to satisfy these
             exploration, extraction, and rehabilitation; solid waste                                                     performance standards should be developed by
             management; timing restrictions on activities, and setbacks                                                  the industry and should be approved by the
             required for the use of explosives; liquid waste management;                                                 appropriate federal and state agencies.
             hazardous waste management; stream crossings and fish passage;
             water management; bonding and financial responsibility; right of                        Stipulation 3   Exploration Pad Construction:
             access; erosion control; oil spill contingency planning; penalty
             provisions for non-compliance; definitions of key terms;                                                     The state strongly supports the objective of
             identification of information needs; design criteria and                                                     this stipulation to minimize gravel require-
             compliance plans; quality assurance/quality control; air   quality;                                          ments for exploration activities.
             and support service industries. These subjects need to be
             addressed in a comprehensive manner and appropriate mitigative                          Stipulation 4   Rehabilitation Plan:
             measures described.
                                                                                                                          The need for rehabilitation plans is clear,
             in addition, the DOI stipulations do not clearly differentiate                                               but the timing of their submittal and defini-
             between stipulations or restrictions applied to exploration                                                  tion of measures necessary to ensure that
             versus development. The state suggests that the DOI reorganize                                               they will be implemented needs further
             the entire mitigation section into two distinct components: .                                                consideration. Separate rehabilitation plans
             exploration, and development. Implementation of the stipulations                                             for exploration and development, including
             should be tied to the type of activity proposed. Stipulations                                                abandonment should be required. Also,
             referring to area specific closures may be effective forms of                                                requirements for conducting necessary re-
             mitigation during exploratory activities but may be ineffective                                              search to develop techniques and measures for
             or inappropriate during development. For example, the stipu-                                                 the rehabilitation of specific sites (e.g.,
             lation on no activity within 112 mile of a documented polar bear                                             gravel pads, seismic lines, material sites,
             den could be useful and effective during exploration, but it is                                              etc.) should be addressed.
             unclear how it would be implemented during development when
             facilities are fixed and certain*activity levels are required.                          Stipulation 5   Off-Road vehicles:
             There are other stipulations that fall into a similar category

             Enclosure A                        3                                                        Enclosure A                        4

                                   Should be modified to prohibit off-road                                                     of the site and rehabilitation must    be
                                   vehicle use, except for travel by      .                                                    conducted in phases concurrent with the
                                   snowmachines, unless otherwise specifically                                                 removal of gravel. The importance of reha-
                                   permitted.                                                                                  bilitation cannot be overemphasized. At a
                                                                                                                               minimum, any gravel site, whether upland
             Stipulation 6    Limits on Oil Exploration:                                                                       and/or floodplain, should be sited and
                                                                                                                               designed to conform to the guidelines as
                                   while we agree in principle with this stipu-                                                defined in the Gravel Removal Guidelines
                                   lation, as written it may be too restrictive.                                               Manual for Arctic and Subarc_---------1-ins
                                   Exploration includes both surface disturbing                                                (USFWS, Woodward-Clyde consultants, 19001.
                                   and non surface disturbing activities. The
                                   stipulation should limit any surface distur-                          Stipulation 8    Pipeline Elevation:
                                   .bance activities to the winter months and
                                   allow only non surface disturbing activities                                                we recommend this stipulation be modified by
                                   during the summer, provided there are no area                                               adding a general statement of intent and then
                                   or timing restrictions that would dictate                                                   incorporate stipulations 8 thru 11 under that
                                   otherwise.                                                                                  statement, and add an additional item regard-
                                                                                                                               ing traffic control. Suggested language is
             Stipulation 7    Gravel and Water Removal:                                                                        as follows:
                                   The state recommends  that DOI address gravel                                                    (a)   Include language as proposed in
                                   removal and water removal separately. In                                                               stipulation
                                   addition, DOI should prohibit winter w   ,ater                                                         No. 9.
                                   removal from fish-bearing waters, springs and                                                    (b)   Include language as proposed in
        (n                         tributaries. We also recommend that DOI
                                   modify summer/fall water removal language to                                                           stiDulation
                                   read:  "During summer and fall, water removal                                                          No. 10 except pipelines should be
                                   shall be restricted to those operations that                                                           buried where "feasible and prudent"
                                   will maintain instream flows at levels                                                                 not just where "possible."
                                   necessary to provide optimum fish passage and
                                   rearing habitat, and water quality. In.                                                          (c)   Roads and pipelines should be
                                   addition, large surface water reservoirs                                                               separated. Offset distances shall
                                   should be created to provide an adequate                                                               be optimum for preventing the
                                   supply of fresh water for oil and gas related                                                          synergistic effect of roads and
                                   industrial activity." Deep pit type exca-                                                              pipelines on caribou movement,
                                   vations adjacent to active channels of the                                                             based on most current relevant
                                   streams identified as lacking suitable fish                                                            research.
                                   overwintering habitat could provide a winter
                                   water source and provide overwintering fish                                                      (d)   A surface traffic control plan
                                   habitat. These reservoir sites should                                                                  should be prepared, approved by.the
                                   incorporate features that will enhance     their                                                       Regional Director, and implemented.
                                   value as fish and wildlife habitat (e.g.,                                                              The plan should consider such
                                   areas of shallow water, varying shoreline,                                                             measures as convoying, pulsed
                                   provide for free movement of fish in and out                                                           traffic, and seasonal or daily
                                   of sites).                                                                                             restrictions.
                                   With respect to gravel removal, prohibit                              Stipulation 12    Restrict Surface occupancy within 3 Miles of
                                   removal in all fall spawning fish and over-                                             Coastline:
                                   wintering areas. Additionally, prohibit
                                   gravel removal from all fish-bearing riv-                                                   The blanket 3-mile buffer for facilities
                                   ers/streams unless approved on site-specific                                                adjacent to the coast is too stringent as
                                   basis. Plans for gravel removal should                                                      written. Provisions must be made to allow
                                   include detailed plans for the rehabilitation                                               drill pads, flow stations, and other

            Enclosure A                       5                                                       Enclosure A                       6

                                 essential support facilities for offshore                                                 This stipulation should be expanded to
                                 development, in this buffer strip. In                                                     require an annual fall monitoring program to
                                 addition, measures must be taken to ensure                                                follow bears moving ashore and identify den
                                 free passage of caribou along the coast.                                                  site locations.
                                 Criteria must be established to determine
                                 which facilities will be allowed in the                              Stipulation 20    Construction Near Coastal Bluffs:
                                 buffer area.
                                                                                                                           Support language as proposed.

            Stipulation 13   Monitoring and Research Requirements:                                    Stipulation 21    Discharge of Firearms:
                                 Modify to make two separate terms. One     that                                           Restrictions on the discharge of firearms in
                                 states:   "The DOI should be responsible   for                                            the vicinity of structures is necessary to
                                 ensuring appropriate monitoring of popu-                                                  protect human safety and oil field op-
                                 lations, productivity, movements, and general                                             erations, however, the five-mile prohibition
                                 health of key species in relation to overall                                              may be excessive. Further discussion is
                                 oil and gas activities in ANWR." Then add a                                               needed on the subject and the potential
                                 separate requirement to read: Where there-is                                              effects on human use of resources in the 1002
                                 a possibility that an activity could adverse-                                             area.
                                 ly affect fish and wildlife, "Lessees and
                                 permittees may be required to monitor the                            Stipulation 22    Prohibit Surface occupancy in Sadlerochit Spring
                                 impacts of the activity on selected species,                                           Special Area:
                                 their habitats, and human uses; to evaluate
                                 impact hypotheses and the effectiveness of-                                               In addition to the Sadlerochit Spring Special
                                 specific mitigation measures employed; and to                                             Area, surface occupancy should be prohibited
                                 develop corrective actions, including im-                                                 in the area within 1/2 mile of the Fish Hole
                                 proved mitigative techniques, as necessary."                                              No. 1 spring outlet located in the Hulahula
                                                                                                                           River, and extend for 1/4 mile on either side
            Stipulation 14   Watercourse Setbacks:                                                                         of mean high water for a distance of 3 miles
                                                                                                                           downstream of the outlet.
                                 The blanket 3/4-mile buffer for all permanent
                                 facilities is too stringent as written.                              Stipulation 23    Protection of Thaspi arcticum:
                                 Provisions must be made to allow drill pads,
                                 flow stations, and other essential facilities                                             it is not known how widespread this plant is,
                                 within this 3/4-mile buffer. Criteria must                                                so it is impossible to determine how large an
                                 be established to determine which facilities                                              area will be placed off limits by this
                                 will be allowed in the buffer area.                                                       stipulation. Until the plant is placed on
                                                                                                                           the endangered species list and more is known
            Stipulation 15 thru  18 - Peregrine Falcon and other Raptors Pro-                                              regarding its areal extent, it is premature
                                      tection:                                                                             to impose such a restriction.

                                 The state concurs with the need for special                          Stipulation 24    Causeways:
                                 protection for the peregrine falcon, however,
                                 stipulations should be modified to incorpo-                                               Based on the state's case-by-case review and
                                 rate language developed by the federal                                                    experience in authorizing the Westdock,
                                 peregrine falcon recovery team.    In addition,                                           Endicott and Lisburne causeways, we recommend
                                 the same level of protection provided to the                                              that the proposed stipulation be revised such
                                 endangered peregrine falcon should not be                                                 that the construction of docks and causeways
                                 provided to all raptors.                                                                  minimize nearshore hydrographic changes and
                                                                                                                           avoid significant adverse effects on fish
            Stipulation 19    Polar Bears:                                                                                 populations and movements.

                                                                                                      Stipulation 25    Time and Area Closures for Wildlife:

             Enclosure A                       7                                                         Enclosure A                        8

                                   Although the state generally supports the                                                   development is conducted in accordance with
                                   language as proposed, it should be made clear                                               environmental standards appropriate for the
                                   that the stipulation applies only to explor-                                                coastal plain of ANWR.
                                   atory activities, vehicle movements, and
                                   other activities that can reasonably be re-                           Stipulation 32    Environmental orientation Programs:
                                   scheduled for another period of time.
                                                                                                                               Support the language as proposed.
             Stipulation 26    Overflight Restrictions:
                                                                                                         Enclosure A/kfi
                                   Expand to include aircraft overflight re-
                                   striction above barrier islands, lagoons,
                                   river deltas, and wetlands within one mile of
                                   coast between May 15 and September 30 (ex-
                                   cluding take-offs and landings). Also make
                                   clear that human safety takes precedence over
                                   the restrictions.

             Stipulation 27    Reduction of Human/Bear Conflicts:

                                   Modify to read, "Measures must be taken to
                                   minimize human/bear interaction and conflict.
                                   These measures may include, but not be
                                   limited to, the use of bear-proof fencing
                                   around certain facilities, special solid
                                   waste management plans Isuch as incineration
                                   of putrescible wastes), and employee educa-
       (b                          tion programs.'

             Stipulation 28 - Limit Use of Infrastructure to Official Busi-
                                ness:

                                   Support language as proposed.

             Stipulation 29 - Inventory Areas for Cultural Resources:

                                   Support language as proposed.

             Stipulation 30 and 31 - Air and Water Quality Provisions:

                                   As discussed in our cover letter, the
                                   proposed stipulations represent a very small
                                   step toward defining what will be needed to
                                   provide an appropriate.level of air and water
                                   quality protection as leasing moves forward.
                                   Further consultation between DOI and the
                                   state is needed on this subject to jointly
                                   develop a workable package of specific
                                   measures. Such a process would better ac-
                                   quaint DOI with the extensive body of en-
                                   vironmental regulation and provide appropri-
                                   _@@t-e-forums for decisions about stipulations,
                                   plans of operations, and permits. It is
                                   crucial to ensure that exploration and

                       Enclosure B                                                                                   Page 2 of 4

                            Type of Waste               Statutes             Definitions               Regulations Definitions

                       4)   OIL and HAZARDOUS           AS 46.03.740                                   18 AAC 20
                                SUBSTANCES*                       758-760                              18 AAC 75
                                                                  780-790
                                                                  822-826
                                                        AS 46.04
                                Oil                                          AS  46.03.758(6)
                                                                             AS  46.03.826(4)
                                                                             AS  46.04-126(9)
                                                                             AS  46.08.900(7)
                                Hazardous Substan  ces AS 46.03.826(3)       AS  46.08.900(6)
                                                                             AS  46.09.900(4)

                       5)   WASTEWATER                  AS 46.03.100-120                               18 AAC 72

                                Domestic Wastewater                                                                  18 AAC 72.99006)

                                Graywater                                                                            18  AAC 72.990(24)

                                Non-domestic
                                   Wastewater                                                                        !Ft AAC 72.990(29)

                                Other Wastes                                                                         18  AAC 72.990(32)

                                .Septage                                                                             18  AAC 72.990(44)

                                Sludge                                                                               18  AAC 72.990(50)

                                Spoils                                                                               18  AAC 72.990(52)

                            Note new legislation adding AS 46.08, AS 46.09, and        amending AS 46.03.745, 758(k), 760(a), 765,
                            780(a), 790(FO (b) (d) and AS 46.04.010 and 090(b).

                                                                       ENCLOSURE B

                                               SUMMARY OF MAJOR STATE AUTHORITIES PERTINENT TO ANWR

                       The State of Alaska defines and regulates the following:

                            Program                     Statutes             Definitions               Regulations Definitions

                       1)   SOLID WASTE                 AS 46.03.100-120                               IS AAC 60
                                                                  800-810    AS 46.03.900(24)             (draft)    18 AAC 60.910(49)

                                Construction Waste                                                                   (Not defined)

                                Industrial Waste                             AS 46.03.900(10)

                                other Wastes                                 AS 46.03.900(16)

                                'Drilling Wastes"                            AS  46.03.900(31-32)                    ISAAC 60.910(16)

                                Putrescrible Waste                                                                   18  AAC 60.910(40)

                                Septage, Sewage                                                                      18  AAC 60.910(46)
                                Sludge   Sludge                                                                          to (48)

                                Sanitary Waste

                       2)   LITTER                      AS 46.06             AS  46.06.150(4)

                       3)   HAZARDOUS                   AS 46.03.296-308     AS  46.03.299(a)-(b)      18 AAC 62
                                                                  830-833

                                                                             S-10

                    Enclosure B                                                                                    Page 4 of 4

                          type of waste              Statutes              Definitions              Regulations Definitions

                    13) SURFACE LEASES                                                              11 AAC 62

                            a. Near Shore            AS 38.05.070-075
                            b. Navigable Rivers      AS 38.05.070-075

                    14) LAND USE PERMITS

                            a. Near Shore            AS 38.05.850                                   11 AAC 62
                            b. Navigable Rivers      AS 38.05.850

                    15) CLASSIFICATION

                            a. Near Shore            AS 38.04.065-900                               11 AAC 55
                            b. Navigable Rivers      AS 38.04.065-900

                    16) ACCESS ALONG HISTORIC
                            TRAILS                   RS 2477

                    Enclosure 3/kfi

                    Enclosure B                                                                                    Page 3 of 4

                          Type of Waste              Statutes              Definitions              Regulations Definitions

                    6)    TOXIC MATERIALS and WASTES are a "special class regulated under the Federal Toxic Substances
                          Control Act and National Emission Standards for Hazardous Air Pollutants.

                    7)*   HABITAT PROTECTION

                             Fish Habitat Permit AS 16.05.840
                                                     AS 16.05.870

                                         EMENT                                                      6 AAC 50       6 AAC 50.190
                                                                                                    6 AAC 80       6 AAC 80.900
                                                                                                    6 AAC 85       6 AAC 85.900

                    9)    WATER USE                 'AS 46.15                                       11 AAC 9

                    10) GRAVEL SALES                                                                11 AAC 76

                            a. Near Shore            AS 38.05.110-120
                            b. Navigable Rivers AS 38.05.110-120

                    11)   PIPELINE RIGHT OF WAY LEASES                                              11 AAC 80

                            a. Near Shore            AS 38.35
                            b. Navigable Rivers      AS 38.35

                    12) OIL AND GAS LEASES                                                          11 AAC 83

                            a. Near Shore            AS 38.05.180
                                                                                                    6 AA      @6 @AA5         '90
                                                                                                                             .9'0
                                                                                                    6 AA             AA  8
                                                                                                        C              C 0
                                                                                          L@@                            8
                                                                                                      AAC 85       6 AAC 5.900

                                                                                                     1 AAC 93

                            b. Navigable Rivers      AS 38.05.180

                                                                          S-11

                                        ENCLOSURE C                                                    Enclosure C

                                 A Recommended Approach to                                             are needed to determine the scope of potential effects on
                               Implementation of ANILCA S810                                           subsistence.   information about the specific subsistence uses of,
                                                                                                       and needs related to, these resources and areas is required to
                                       March 14, 1986                                                  identify and evaluate these effects.    This includes data on:

                                                                                                            1.   Who uses the resources which could be affected;
            S810 of ANILCA requires federal agencies to consider the effects
            of proposed land actions upon people engaged in subsistence uses.                               2.   Where, when, and how the resources are harvested;
            Specifically, it requires agencies to:
                                                                                                            3.   How much they use; and,
                  1.   Evaluate the effects of the proposed action on subsis-
                       tence uses and needs;                                                                4.   The significance of the harvested resources for meeting
                                                                                                                 socioeconomic and cultural needs.
                  2.   Determine the availability of other lands for the
                       purposes sought to be achieved and assess whether other                         flaps of community subsistence use areas can provide valuable data
                       alternatives are available which would reduce or                                about which communities and groups of people use fish and
                       eliminate the use, occupancy or disposition of public                           wildlife that could be affected. Each S810 evaluation should
                       lands needed for subsistence purposes;                                          include a map and list of communities that use the stocks and
                                                                                                       populations of resources potentially affected by a proposed
                  3.   Determine whether the proposed action would "signifi-                           action. The Alaska Department of Fish and Game routinely
                       cantly restrict" subsistence uses;                                              develops maps of subsistence use as it conducts community
                                                                                                       subsistence studies. The state welcomes opportunities to
      CP          4.   If the proposed action would significantly restrict                             cooperate with federal agencies in improving the subsistence data
                       subsistence uses, to:                                                           base.

                       a.   meet certain public notice and hearing require-                            once the area and communities which could be affected by an
                            ments.                                                                     action are identified, an assessment must be made of the
                                                                                                       potential effects of the action on uses of fish and wildlife.
                       b.   Determine that such  a restriction meets certain                           The potential linkages between the proposed action, fish and
                            standards, including involving the minimum amount                          wildlife resources, and subsistence uses need to be clearly
                            of public lands and minimizing adverse impacts                             described. This can be accomplished through developing
                            upon subsistence uses and resources.                                       hypothetical scenarios, and tracing their implications out
                                                                                                       through the biological system to the people who rely on
            This paper describes the basic requirements of �810    and provides                        subsistence uses.
            a systematic approach to meeting these requirements    when making a
            decision on an OCS oil and gas lease sale.                                                 The evaluation of  effects should address   potential positive,
                                                                                                       neutral, and negative effects, as well as direct and indirect
            Evaluating Effects on Subsistence Uses                                                     impacts on subsistence uses resulting from a proposed lease sale.
                                                                                                       The guidelines for implementation of �810 developed by the Alaska
            ANILCA 5810 provides, as a starting point, that "in determining                            Land Use Council are helpful in identifying several effects which
            whether to ... lease-public lands ... the head of the federal                              would restrict subsistence uses:
            agency having primary jurisdiction over such lands ... shall
            evaluate the effect of such use, occupancy, or disposition ... on                          1.   A reduction in subsistence uses due to direct
            subsistence uses and needs...."                                                                 impacts on the resource, adverse impacts on habitat,
                                                                                                            increased competition for the resources, or other factors;
            This section is clearly intended to require a specific assessment
            of impacts on subsistence uses. An adequate 5810 evaluation must                           2.   A reduction in the subsistence uses due to changes
            include complete  *and accurate information about the proposed                                  in availability of resources caused by an alteration in
            action and about the subsistence uses of potentially affected                                   their distribution, migration, or location; and
            wild resources.
                                                                                                       3.   A reduction in subsistence uses due to limitations
            Information about the wildlife populations, fish stocks, and
            geographic areas which could be affected by the proposed action

              Enclosure C                                                                               Enclosure C

                   on the access to harvestable resources, such as by physical                          Determining Whether Actions Would "Significantly Restrict"
                   or legal barriers.                                                                   SuFs1stence use

              An adequate S810 assessment must consider the potential effects                           Once the potential effects of the    lease sale upon subsistence
              of the proposed action in each community which would be affected.                         uses have been described, the next step required by �810 is to
              In some circumstances, however, it may be necessary to examine                            determine whether these effects could "significantly restrict
              effects on the subsistence uses of "typical" communities or                               subsistence uses....'
              groups of people within the affected zone.
                                                                                                        The legislative history of ANILCA giveg no clue to the intended
              Biological and socioeconomic data need to be.at a level of detail                         meaning of "significantly restrict." The closest parallel to the
              which will allow a meaningful assessment of potential impacts on                           significantly restrict" standard appears   to be the requirement
              the people who use resources for subsistence.    These effects.can,                       of the National Environmental Policy Act   (NEPA) to analyze
              occur at the individual, household, community and regional level.                         actions which may "significantly affect" the environment.
                                                                                                        Regulations of the Council on Environmental Quality (CEQ) for
              A working document has been developed by the Alaska Land Use                              implementing NEPA state that both the context and intensity of
              Council which identifies minimum data standards for makingan                              impacts must be considered in deciding significance.
              adequate �810 assessment. (Alaska Land Use Council, Working
              Group II; November 28, 1984, Draft Standards and Guidelines for                           The people who would be affected, and the roles that the
              the Collection, Analysis, and Presentation of Subsistence Use                             particular resources play in their lives provide the obvious
              Information for ANILCA �810 Determination, pp. 5-6.)     In some                          context for evaluating significance in relation to restrictions
              cases existing data on subsistence uses may not be adequate to                            on subsistence uses.   The "intensity" of effects also has to be
              conduct a 9810 analysis. Agencies must anticipate these special                           evaluated in relation to use of specific resourcei by people.
              data needs at the earliest stages in the EIS process. Public
              meetings may be useful in compiling additional data on                                    In 9810 Congress recognized.thaf subAiRtence uses are essential
              subsistence uses and needs.   Additional research may also be                             to many rural Alaskans, and intended federal land actions to have
              necessary to address particular data gaps.    New studies should be                       the least adverse impact possible upon them.
              closely coordinated with the State of Alaska as required by
              ANILCA �812.                                                                              When considered in relation to this mandate, a "significant"
                                                                                                        restriction to subsistence uses is an effect which imposes a
              The �810 evaluation must thoroughly describe and document data                            meaningful burden or hardship on particular people.
              about subsistence resources and uses so that all concerned
              parties can ascertain which resources and subsistence uses could                          A determination pf "significance" therefore requiresdiscussion
              be affected by a proposed action.                                                         of such factors as socioeconomic circumstances, the degree to
                                                                                                        which harvest of particular resources could be reduced by the
              Identifying Alternatives                                                                  proposed action, and the consequences of the frequency, timing,
                                                                                                        and location of restrictive effects..1 These need to be-evaluated
              �810(a) also requires federal agencies to evaluate ` ... the                              in the context of the people who actually harvest and use the .
              availability of other lands for the purposes to be achieved,    and                       potentially affected resources, and in the context of,what would
              other alternatives which would reduce or eliminate the use,                               constitute a meaningful burden to t  .hose people.
              occupancy, or disposition of public lands needed.for subsistence
              purposes."                                                                                A hypothetical example may be useful in demonstrating the
                                                                                                        approach suggested above:
              In ANILCA-�802 Congress states its policy that the
              "...utilization of the public lands in Alaska is to.cause     the                         During an ETS study a proposed lease sale is determined
              least adverse impact possible on rural residents who depend upon                          potentially to affect local-salmon stocks.    The studies suggest
              subsistence uses of the resources of such lands...."     It is                            that the.activity will not  'have a major impact on regional salmon
              therefore important that �810 analyses fully   identify  and explore                      populations or regional harvest levels, but depending on    its:
              alternative areas and approaches which would.minimize    adverse                          timing and precise location, it could reduce a particular stock
              impacts on rural residents.                                                               or run. It is impossible, given uncertainty about where or when
                                                                                                        the activity will occur, to predict exactly which salmon    stock
                                                                                                        might be'affected. However, the EIS has identified 20
                                                                                                        communities and qroups.of people who make subsistence use of the

                                               3                                                                                         4

            Enclosure C                                                                              Enclosure C

            salmon runs which migrate through the general impact area and                            It is desirable for agencies to follow the S810 procedures for
            could be affected. The S810 evaluation therefore identifies                              public involvement in instances where a determination of
            these communities and the potential risks. it then examines what                         significance is not clear or where there may be significant
            effect a reduction in a local salmon run could have for                                  restriction even though certain data may not yet be availableto
            households within typical communities, perhaps dividing the                              support7the finding.
            communities into four or five categories, based on location,
            degree of reliance on subsistence resources, and so forth.                               Public notification of hearings following a determination of
                                                                                                     significant restriction should follow several avenues, including-
            In the hypothetical example, the FEIS concludes that the proposed
            action could substantially reduce local stocks of king salmon for                              1.   Notice published in local and regional newspapers;
            one or more seasons. As subsistence uses have been shown to
            occur on these stocks the S810 analysis would then identify this                               2.   Notice mailed to local fish and game advisory
            as a potential restriction and then go on to determine whether                                      committees, regional councils, local governments, and
            the action would "Significantly restrict" the subsistence use of                                    Native organizations;
            king salmon. In this analysis king salmon are one of the first
            fresh foods available to particular households in early summer,                                3.   Notice aired on local radio and/or television
            and the loss of king salmon for one or more seasons would be a                                      broadcasts;
            meaningful burden on families in the communities. The S810
            analysis, after weighing the risks to subsistence use of king                                  4.   Notice posted in community halls and other local
            salmon against the important role of king salmon to the people,                                     meeting places; and
            might conclude that the action could "significantly restrict"
            subsistence use of king salmon in several of the communities.                                  5.   Personal communications with individuals or groups
                                                                                                                known by the land manager to have an interest in the
            Meeting Notice and Hearing Requirements                                                             action.

            S810(a) requires the head of each federal agency to meet certain
            notice and hearing requirements before allowing an action which                          Minimizing unavoidable adverse impacts upon subsistence uses and
            would significantly restrict subsistence uses. The appropriate                           resources
            state agency and appropriate local committees and regional
            councils established under �805 must be notified, and a hearing                          S810(a)(3) requires three findings before an action which would
            must be held in the vicinity of the area involved.                                       significantly restrict subsistence uses can procede.
            In ANILCA 5801 Congress clearly stated its intent that rural                                   1.   That such a significant restriction of subsistence uses
            residents, who have knowledge of local conditions and subsistence                                   is necessary, consistent with sound.management
            requirements, should have a meaningful role in decisions                                            principles, for the utilization of public lands.
            affecting subsistence uses and needs. The specific requirements
            of S810 are intended to ensure that federal agencies have the                            This  finding of necessity should be specific   to the proposed
            best available information about thepotential effects of                                 action, and should be based upon an analysis    of the potential
            proposed actions on rural residents. They also seem, when taken                          impacts upon subsistence uses and the relative value of the
            in conjunction with 5810(a)(3), to be intended to ensure that                            proposed action in meeting the goals for the use of public lands.
            local knowledge and experience is brought to bear on the
            requirement that adverse impacts on subsistence be minimized.                                  2.   That the proposed activity will involve the minimal
                                                                                                                amount of public land necessary to accomplish its
            Again, a ommun tj      us in evaluating effects would * 1'f    I  the                               purposes.
                     c heplg      c                                     'I I
            notice and          1:quirements. Each 5810 evaluaiiors)IMuld
            include a map and list of the communities potentially affected,                          The finding of necessity should exclude all public lands that are
            and identify those where subsistence uses could be significantly                         not necessary to achieving the proposed purpose.
            restricted. In this way S810 assessment itself would indicate
            many of the groups which should be notified.                                                   3.   That reasonable steps will be taken to minimize
                                                                                                                adverse impacts upon subsistence uses and resources.

                                              5                                                                                        6

             Enclosure C                                                                               Enclosure  C

             identification and consideration of possible mitigation measures                                1.   Identify the people who make subsistence use of all
             are required to minimize the adverse impacts to subsistence uses                                     wild resources which would be affected by the proposed
             that could result from the proposal to use, occupy, or dispose                                       action;
             public lands. These can take many forms, and as noted above,
             public involvement can play a key role in developing suitable                                   2.   Identify the nature of their subsistence uses and needs
             mitigation measures.                                                                                 for these resources;
             The following categories represent a broad range of types of                                    3.   Describe the potential effects of the proposed action
             mitigation measures:                                                                                 on wild resources and upon community subsistence uses
                                                                                                                  and needs, and identify which of these effects could be
                        1.   Alternatives for deleting public lands from the                                      restrictions;
                             proposed action to reduce the risk of potential
                             subsistence resource restriction.                                               4.   Make a determination of whether potential restrictions
                                                                                                                  would be "significant" in the context of the meaning of
                        2.   Alternatives for reducing impact to seasonal                                         the affected resources to the people who use them, and
                             camps and other harvest and use locations;                                           the role the resources play in their lives;
                        3.   Alternatives for reducing habitat changes                                       5.   Identify alternatives that would minimize adverse
                             that may reduce species abundance and decrease                                       impacts on rural residents;
                             harvest opportunity;
                                                                                                             6.   If the proposed action could significantly restrict
                        4.   Alternatives for reducing numbers of people                                          particular subsistence uses:
                             living in, working in, or passing through area;
         L                                                                                                        a.    meet notice and hearing requirements;
       0                5.   Alternatives for reducing numbers of people
                             competing for resources;                                                             b.    make findings that;
                        6.1  Alternatives for reducing disturbance, roads,                                              1.   the necessity for the proposed action
                             noise, water quality degradation, etc., that may                                                outweighs the risks to subsistence;
                             affect distribution of species;
                                                                                                                        2.   the proposed action will involve the minimal
                        7.   Alternatives for reducing land classification                                                   amount of public lands needed to accomplish
                             and ownership changes;                                                                          its purpose;
                        a.   Alternatives for reducing changes in access                                                3.   reasonable steps will be taken to minimize
                             routes to use areas; or                                                                         adverse impacts upon subsistence uses and
                                                                                                                             needs.
                        9.   Alternatives for compensating people for
                             losses.                                                                         7.   Thoroughly document all data and findings so that
             Time and area restrictions on activity may frequently be useful                                      concerned parties have access to them.
             in mitigating effects on subsistence uses.

             Summary

             Federal agencies can satisfy the requirements of ANILCA �810 by
             following the systematic approach outlined above. An adequate
             S810 evaluation for an OCS oil and gas lease sale would clearly
             meet the following standards:

                                               7                                                                                          8

                                                                                                       and gas revenue from the Refuge. The Congress should require
                                                                                                       the protection of the environmental and subsistence resources
        REPRESCNTAnVE                                         PO, BOX 296. EAGLE RIVER. AK 99577       of the Refuge, including habitat, air, and water, in the event
        SAM COTTEN                                              PO. BOX' JUNEAU. AK99811               of oil and gas development on the coastal plain of the Refuge.
                                                                                                       in recognition of Alaska's economic situation and the need for
                              ALASKA STATE LEGISLATURE                                                 long-term economic development in the state, the Congress
                                    HovsE op RFPRESENTATTVFS                                           should require that exploration and development activity in
                                                                                                       the Refuge be conducted by Alaska work forces.
                                                                                                       The Congress also should amend the Export Administration Act
                                                                                                       to reduce America's trade problem and energy costs by allowing
               February 6, 1987                                                                        the export of new production from Alaska's North Slope.
               The Honorable Bill Horn                                                                 Thank you for considering these concerns. I hope that the
               Assistant Secretary for                                                                 Interior Department will work toward accomplishing these
                 Fish, Wildlife and Parks                                                              objectives during the Congressional debate on ANWR.
               U. S. Interior Department
               Washington, D. C.    20240                                                              Sincerely,

               Dear Secretary Horn:
               I am writing with regard to the draft 1002(h)   study which                             Representative Sam Cotten
               presents alternatives for management of the coastal plain   of                          co-Chairman, House Resources Committee
               the Arctic National Wildlife Refuge (ANwR).                                             (907) 465-3711/15/99
        0)     The interest shared by Alaskans in the decisions about ANWR                             SC:smc
               are fairly clear: we need to maintain a clean, healthy
               environment and provide jobs and revenue for Alaska's people.
               These are national interests as well.

               Toward achieving these goals, the U. S. Congress should.
               promptly open the coastal plain of the ANWR to oil and gas
               exploration, production, and transportation under conditions
               that are in the interest of the nation and the state;
               reserving the leasing of land in the core caribou calving
               grounds until &.later date. Although, at this time, there is
               some controversy about the location of the calving ground, we
               are hopeful that the research data can be put to good use in
               the near term to define it. Protection of the Porcupine herd
               is in the interest of American and Canadian citizens. other
               environmental issues such as air and water quality, waste
               management and disposal, and development coordination alsi
               need attention.

               The interior Department should desist from discussing land
               trades that would eliminate the State of Alaska's revenue.
               share from oil and gas activity in the Refuge and that could
               reduce the ownership influence of the state and federal
               governments.

               Unless the state concurs, the L:..S. Congress should not   allQw
               measures or actions that reduce the state's entitiement   to.oil

                                                        Arctic Village Council
                                                        Arctic Village, Alaska 99722
                                                                                                       Caribou has been our source of food for many generations
              February 6, 1987                                                                         before us. Skin is very valuable, too. Drilling.would keep
                                                                                                       caribou away from their calving ground (How would you like
              U.S. Fish and Wildlife Service                                                           it if you were in labor in a delivery room and someone was
              ATTN: Division of Refuge Management                                                      drilling in the same room?).
              2343 Main Interior Building
              18th and C Streets                                                                       Skin is a source of income for some--making linings, (dog)
              N.W. Washington, D.C.   20240                                                            whips, dogsleds, boots, strings, etc.

              Dear U.S. Fish & Wildlife Service:                                                       Don't do to the caribou what your ancestors did to the buffalo.

              Speaking for the majority of Arctic  Village people, we're                               ANWR stands for Arctic National Wildlife Refuge, doesn't it?
              opposed to the opening up of the ANWR land, However, if the                              Doesn't the name speak for itself? What is a Wildlife Refuge
              oil development will take place, we need to know what is                                 if you destroy the Wildlife's main calving grounds?
              going to happen to the Arctic Village and Venetie people,
              the ones that are going to be affected by the oil development                                                            sincerely,
              more than anybody in the U.S. The Fish & Wildlife Reports
              should say something about what will happen to Arctic Village
              and Venetie people, so that the Congress will have all of the                                                            Joseph J. Tritt@
              information to base their decision on for this important de-                                                             for the Arctic Village Council
              cision.
                                                                                                       JJT/mb
              The Fish & wildlife reported that on the ANWR or Coastal Plain
              lands, there are certain areas that will affect the herd, but
              from our standpoint,all the areas in ANWR and coastal plains
              are important to the herd. They (caribou) don't go to just
       ::@4   one Place, they're everywhere.
              Some reports say that the development can be compatible with
              the Porcupine herd; we don't think it is possible, due to
              encroachment without care to what the herd eats. The bulls
              won't mind, but the cows and calves will be affected by the
              impact of the development. After the caribou have their young,
              they migrate to the Arctic Village area and sometimes stay all
              winter. Since there's no trapping, the people of Arctic village
              depend more than anything on Porcupine herds. We don't have
              trapping which brings monies for our survivability; we have
              caribou to survive.

              To drill on the caribou's only calving ground would keep the
              cows from calving where the conditions are good for calving.
              It would also destroy our way of life and culture if we don't
              have the adequate amount of caribou around. We depend on the
              caribou for food and the skins to make our things--things like
              Caribou legskin boots, etc.

              My Village leaders asked me  to remind you that caribou is    our
              only source of meat. Meats   always consist of dry meat, meat
              stew, caribou head stew or soup, fry meat, caribou hamburger,
              roast and meat soup. In our coffee shop a hamburger costs $4.50.
              In the store it is $4.50/lb. and a checken fryer costs $9.00.
              Other store meat is very expensive due to distance from other
              places to our village.

      STATE OF CALIFORNIA-THE RESOURCES AGENCY                                  GEORGE DEUKMEJIAN. G*--

      DEPARTMENT OF FISH AND GAME
      1416 NINDI STREET
      SACRAMENTO, CA 93814
       (916) 445@3531

                                                                           February 2, 1987

              Mr. William P. Horn
              Assistant Secretary for Fish
                and Wildlife and Parks
              U.S. Fish and Wildlife Service
              Attn: Division of Refuge Management
              2343 Main Interior Bldg.
              18th and C Sts., N.W.
              Washington, D.C. 20240

              Dear Assistant Secretary Horn:

              We have reviewed your decision to allow for full leasing of Section 1002 land
              of the coastal plains of the Arctic National Wildlife Refuge and would
              respectfully request a reconsideration of your position because of Impacts on
              lesser snow geese.  As a major staging area for the Banks Island lesser snow
              goose colony, the lands of Section 1002 contain critical habitat as documented
              In both the March 1985 and November 1986 "Arctic National Wildlife Refuge
              Coastal Plain Resource Assessments".  We believe that full leasing activities
       OD     In areas used by up to 350,000 geese during fall staging could have long term
              adverse effects on a large component of the Pacific Flyways total population of
              lesser snow geese.

              As a further gesture of our concern over migratory waterfowl, we would also
              request that any land exchange programs associated with the 1002 project,
              receive the benefit of full public review.   Parcels available for exchange
              should be selected In such a manner as to provide maximum value for migratory
              birds.

              I would appreciate your consideration in this matter.

                                                          Sincerely,

                                                      ar Jack C. Parnell
                                                          Director

                                          of Kaktot,
                                                      ,t
                                                                                                         January 6. 1987
                                           P.0, Box 27                                                   Page 2
                                        Kakto0k, Alaska 99747
                                          (907) 640 (013
                                                                                                         Importance of offshore feeding In this area. The Alaska
               January 6, 1987                                                                           Eskimo Whaling Commission and the North Slope Borough may be
                                                                                                         doing whale studies that should be used to determine
                                                                                                         possible effects and In mitigating offshore activities. We
                                                                                                         would recommend using AEWC In formulating regulations to
               U.S, Fish and Wildlife Service                                                            cover all offshore activities.
               Attn: Division of Refuge Management
               2343 Main Interior Building                                                               The social problems that will develop in Kaktovik were not
               18th and C Ste.. N.W.                                                                     covered very well by the report, and with good reason. it
               Washington. D.C.    20240                                                                 is probably the hardest and most emotional aspect of
                                                                                                         development of the area to mitigate. The social problems
                                                                                                         that will develop must be addressed now. prior to
               The City Council  of Kaktovik has. after much deliberation,                               development. The North Slope Borough with Its CIP Program
               decided to support alternative B. limited leasing of the                                  Is an example of what can happen.    The North Slope Borough
               ANWR 1002 lands.                                                                          Is trying to address and correct after the fact. We wish to
                                                                                                         do this prior to development and In a way that utilizes the
               This support comes with the understanding that certain                                    unique lifestyle of the Kaktovik area.    We ask that funds be
               stipulations be met towards the protection of wildlife, It's                              made available for our use, as we believe necessary, to meet
               habitat, subsistence lifestyles, and the social economic                                  the needs of the community and develop programs to handle
               future of Kaktovik.                                                                       problems prior to any development or further exploration.
                                                                                                         Our primary objective would be to control alcohol and drug
               Option B was selected because It offers the most protection                               problems, and to enhance recreation and native arts.
               to wildlife but still allows private owners of land to                                    K
                                                                                                         .!@I!vj@.cloes.not,have the,economic base.nor the,time to
               develop and utill7_p thpir lancle     meet their economic                                           these Programs without legislative action to
               needs.                                                                                    create such a fund for our use. Again. prior to. instead of
                                                                                                         after, Is essential.
               The protection of habitat needed by the porcupine caribou
               herd and protection of the herd itself is of great concern.                               The primary difference between alternative A and B. as we
               This concern is felt not only by us but other communities                                 see it, Is A allows the Secretary to open areas for leasing
               that use the porcupine caribou herd to meet their                                         without further public'comment. If the Secretary would
               nutritional needs.    We realize negative impacts will occur.                             recommend, at the minimum, Involvement of all subsistence
               We feel conditions can be Implemented to control these                                    users of the Porcupine Caribou herd prior to     leasing of the
               impacts and ask that In the development of these controls                                 closed area, we would support Alternative A.     If he cannot
               the protection of wildlife be the priority and economics of                               do this, we do not and will not support Alternative A.      We
               the developers be secondary.                                                              ask Congress to consider this carefully. as    ,we are sure they
                                                                                                         will.
               Subsistence rights must be looked at In a manner that keeps
               areas open to hunting that are important to people's needs.                               If Congress so decides, we would support Alternative C or D
               We do not agree with the stipulation that no trapping or                                  but not E.
               discharging of firearms Witt-in 5 miles of any development is
               necessary. We ask that for local subsistence uses, a waver                                Sincerely,
               would be considered from the 5 mile no hunting and trapping
               zone.    On page 129, there Is mention of section 810 ot
               ANILCA and the requirement of the Secretary to determine the                              Al
               effects on subsistence.    This was only mentioned under                                  Loren Ahlers, Mayor
               alternative A.    It was also stated that Congress could                                  City of Kaktovik
               exempt the Secretary from the requirements of Section 810 of
               ANILCA.   We would strongly urge the Congress not to do this.                             LA:ms
               To circumvent the requirements of ANILCA Would not seem -n
               be in the best interest of all subsistence users.                                         cc2

               There was very little written about Possible impacts to ine
               Bowhead Whale. There are studies ongoing through t@%e
               Minerals Management Service on the effects of noise and the

    Commonwealth of Massachusetts

    Department of
    Fisheries, Wildlife &
    Environmental Law Enforcement

    Walter E. Rickford, Commissioner

    							January 21, 1987

    William P. Horn
    Assistant Secretary for Fish, Wildlife and Parks
    United States Fish and Wildlife Service
    2343 Main Interior Building
    18th and C Street, N.W.
    Washington, D.C. 20240

    Re:  Proposed Oil and Gas Development in the
         Arctic National Wildlife Refuge

    Dear Assistant Secretary Horn:

    The Massachusetts Department of Fisheries, Wildlife and
    Environmental Law Enforcement has carefully studied your Draft
    Report and Recommendation to the Congress of the United States
    on the above subject.  Because of the vital national importance
    of this issue, I am taking the liberty of submitting the
    Department's comments on your Recommendation to you directly as
    well as to the Division of Refuge Management.

    Please be advised that the Massachusetts Department of
    Fisheries, Wildlife and Environmental Law Enforcement vigorously
    opposes your Recommendation, as set forth on pages 169-70 of the
    Report, to open the entire 1.55 million-acre 1002 area of the
    Refuge to oil and gas leasing and development.  In contrast to
    your Recommendation, this Department very strongly supports
    Alternative E, under which the United States Congress would
    designate the 1002 area as wilderness within the meaning of the
    1964 Wilderness Act (Public Law 88-577).

    The Department's opposition to your Recommendation is based
    on the following reasons.

    100 Cambridge Street Room 1901 Boston, Massachusetts 02202   (617)727-1614
    An Agency of the Executive Office of Environmental Affairs

    	1.	As you are well aware, the Arctic National Wildlife
    Refuge is incredibly rich in native arctic wildlife and is of
    immeasurable importance as breeding and nesting habitat for
    migratory birds from all over the Western Hemisphere.  On these
    facts alone, the Department believes that the Refuge is eminently
    worthy of strict protection in its present pristine state.
    However, the Refuge is of far greater value than even this
    inherent inestimable worth suggests.  North America was once
    overflowing with wildlife resources of tremendous abundance and
    diversity.  However, our society has relentlessly plundered these
    resources in its ever more frantic search for energy and minerals
    to satiate its rapacious appetite for material goods.  As a
    result, we have suffered devastating losses of wildlife habitat
    throughout the North American continent, and these losses con-
    tinue.  The Arctic National Wildlife Refuge represents, in this
    Department's opinion, the last truly great wildlife resource area
    on the North American continent.  This imcomparable area must be
    preserved undamaged by human action.

    	2.	Your Recommendation is predicated almost entirely upon
    your assertion that this nation will continually need more and
    more oil and natural gas, and that as a result we must exploit
    every available domestic hydrocarbon resource.  Your Report
    clearly reflects this attitude by focusing exclusively on pro-
    jected increases in national demand for these energy resources
    and on how oil-and-gas development in the Refuge may help to par-
    tially satiate this ever increasing appetite for these energy
    fuels.  However, this assertion misconstrues the real issue here.

    	This Department believes that the decision about whether to
    open the Arctic National Wildlife Refuge to oil-and-gas develop-
    ment is really a decision about what is wise use and proper
    stewardship of the great natural resources with which this nation
    has been blessed.  The Department of Fisheries, Wildlife, and
    Environmental Law Enforcement agrees, as does practically
    everyone in the nation, that we need adequate reserves of oil and
    natural gas for economic well-being and national security pur-
    poses.  However, our economic health and national security depend
    on the wise use of these reserves, not on the full-scale
    exploitation of them just to satisfy demand for these resources.

    	As I am certain that you are aware, vast quantities of
    energy are still being wasted in this country.  Many studies have
    demonstrated that this nation's demand for energy can be substan-
    tially reduced through more efficient methods of production,
    heating, and transportation.  In addition, alternative energy
    sources such as solar power, the conversion of coal into natural
    gas, and geothermal heating can replace a great deal of the oil and
    gas currently being consumed.  Through the aggressive implemen-
    tation of these approaches for eliminating energy waste and
    encouraging the development of alternative energy sources, the
    demand for oil and natural gas can be dramatically lowered from
    what it is today.  As a result, not only would the alleged
    rationale for drilling in the refuge no longer be even remotely
    possible, but such a policy would in fact promote our economic

              health and national security by rPducin(j this nation's 6--Perldence
              on oil and natural gas as an energy source. I think that you
              will agree that it makes !ar more sense to more t)rudently iv@p
              what oil and gas supplies we have that are readily available than
              to give our energy-addicted society yet another oil-and-gas fix
              for a couple of years. By being wise in our use of these fuels,
              we can strengthen our economic well-being and national security
              while at the same time preserving for future generations the
              irreolacable national treasure that is the Arctic National
              Wildlife Refuge,

                   However, your Report totally falls to address this issue.
              Moreover, the Reoort fails to mention the role that the United
              States government has played In the last few years in inflating
              demand for oil and gas in this country by encouraging wasteful
              energy use via actions such as a) delaying deadlines for meeting
              automobile fuel mileage standards, and b) slashing funding and
              incentives for energy conservation and alternative energy source
              develoDment. The complete lack of any discussion of the impact
              on oil and gas demand from the implementation of already proven
              policies and methods for greatly reducing oil and gas use in this
              country vitiates the rationale underlying the Report And
              Recommendation.

                   3. Other national wildlife refuges and similar federal
              lands of special or unique value may also contain marginally com-
              mercial deposits of oil and/or natural gas. Although we believe
              that the rationale set forth in the Report and Recommendation is
              fatally flawed, the pressure to use it to force these other lands
              to be ODened to oil and gas development will rise dramatically if
              drilling is allowed to proceed in the Arctic National Wildlife
              Refuge.   The Department of Fisheries, Wildlife and Environmental
       w.a    Law Enforcement is adamantly opposed to any such activity In
              these protected areas, and recommends Instead that these special
              lands be permanently protected from commercial development of any
              kind.

                   For the above reasons, the Department vigorously opposes
              the  Recommendation contained in the ReDort and strongly supports
              Alternative E.   We face a critical decision for this nation.
              Through the choice we make here, we can set the stage for a
              country that either (a) has a clean, fuel efficient economy       and
              abundant wildlife resources, or (b) Is wasteful of and Addicted
              to oil-and-gas and essentially devoid of most of its once vast
              and splendid wildlife heritage. The choice is ours. The
              Massachusetts Departmentof Fisheries, Wildlife and Environmental
              Law Enforcement votes for Option No. I. We hope that you will
              join us by withdrawing the Recommendation and giving your full
              support to Alternative E. Thank you very much for this oppor-
              tunity to comment on this vital national Issue.

                                                         Sincerely yours,

                                                         Walter F. Bickford
                                                         Commissioner

              CC:  Division of Refuge Management
                   Honorable Senator Edward Kennedy
                   Senator John Kerry
                   All Congressional Representatives

                                                                                                                                     Director
        NORTH SLOPC BOROUGH                                                                                                          January 20. 1987
                                                                                                                                     Pn g-v 2
        OFFICE OF THE MAYOR

        P.O. Box 69 '
        Barrow, Alaska 99723

        Phone: 907-852-2611
                                       George N. Ahmaogak, $r., Mayor                                                                      2)   The cumulative effects that ANWR and other developments will
                                                                                                                                                have on fish and wildlife, on demprids for Borough services, and
                                                                                                                                                Oil lifestyles and subsistence opportunities;

                                                                                                                                           3)   There is no description of the specific procedures that you will
                                                                                         i   I'dIU147,                                          recommend to Congress to guarantee that local governments and
                                                                                                                                                residents will he involved in federal decision-making concerning
                                                                                                                                                exploration    and    development,     mitigation,    subsistence,     and
                                                          Jnnnory 20, 1987                                                                      transportation and utility systems,

                                                                                                                                           4)   You propose no mitigntion measures to avoid your projected loss
                                                                                                                                                of subsistence areas to (a)j developmeq, and (b) hunting
                  Director                                                                                                                      restrictions-, and
                  U.S. Fish and Wildlife Service                                                                                           5)   There is no indication of how-you propose to coordinate your
                  Division of Refuges                                                                                                           administrative    procedures      @Atg   decision-ainking    under the
                  18th and "C" Streets, N.W.                                                                                                    Borough's zoning jurisdiction.
                  Room 2343, Main Interior Building
                  Washington, D.C, 20240                                                                                                   Thank you for this opportunity to comment on the ANWR LEIS.
                                                                                                                                     Under separate cover, ve are providing certnin of the maps, previously
                                                       Re: ANWR LEIS                                                                 provided to your staff in Anchorage, that we feel are especially
                  Dear Sir:                                                                                                          Informative as to human uses (if ANWR.
                                                                                                                                                                              Sincerely,
                        These are the detailed comments of the North Slope Borough on your
                  "Draft Arctic National Wildlife Refuge, Alaska, Coastal Plain Resource
                  Assessment" and Legislative Environmental Impact Statement                    (LEIS).
                  Incorporated herein by reference are the statements presented on my                                                                                         George N. Ahmaogak Sr.
                  behalf by the Borough at the public hearings held in Kaktovik, Alaska and                                                                                   Mayor
                  Washington, D.C. on January 6 and 9, 1987.

                        1 believe that ANWR should be opened to oil and gas lensing. subject                                         cc:   Senator Ted Stevens
                  to stringent environmental,          subsistence,    local access,      and public                                       Senator Frank Murkowski
                  participation requirements.        I also believe that if Congress adopts                                                Loren Ahlers, Mayor of Kaktovik
                  Alternative A in the LEIS, as recommended by Assistant Secretary Ilorn,                                                  Kaktovik Inupiat Corporation
                  the "core" calving area of the porcupine caribou herd--located in the south                                              Jacob Adams, President, ASRC
                  end of the Jago River area of      ANWR--should be placed off limits to leasing                                          Robert Grogan, State of Alnska
                  for a period of time.                                                                                                    U ,S. Fish & Wildlife. Service, Anchorage
                                                                                                                                           North Slope Borough Assembly
                        My views on the larger      issues facing Congress, in deciding whether                                            NSF? Planning Commission
                  to open ANWR to leasing, were outlined in my statements at the hearings.                                                 William Garner
                  I have attached comments on the specific strengths and wenknesses in the                                                 Edwqrd Ittn, Director, NS13 Planning Department
                  draft LEIS.       I observe generally that the document is wenh in the                                                   Finrold Curran, NSR Attorney
                  following genernl areas:-___                                                                                             Warren Matumeak, NSB Land Management Administrator
                                                                                                                                           Ben Nrigenk, Director, NSB Wildlife Management
                        1)   The effects on coastal resources (especially whales            and fish)
                             from development and shipping at port and waterflood sites-,

                                                                                                                                     Kaktovik Inupiat Corporation (XIC) Is
                                                                                                                                                                                  nds, Native    inholdings now being
                                                                                                                                     acquired, and State lands--both submerged lands within and offshore of

                                                                                                                                     ANWR, and those to the West of ANWR.

                                                     COMMENTS OF THE                                                                 1.    ACCESS
                                                  NORTH SLOPE BOROUGH
                                                            ON THE
                                                     DRAFT ANWR LEIS
                                                       JANUARY, 1987                                                                       The LEIS addresses access on pages 127         -129. The LEIS does state

                                                                                                                                     that  subsistence bunting would be restricted in the vicinity of oil and          gas
                         Generally speaking, we think that the Draft LEIS            is concise, well                                facilities.  nitigation stipulation No. 21, Page 146, proposes a five- mile
                     written, and predicts well the impacts of potential oil and     gas development                                 restricted access area adjacent to oil and gas facilities, producing major
         q)          on terrestrial wildlife.    However, It discusses in far        less detail the                                 adverse effects by limiting access to resources and areas t radition ally
                     existing fishing, hunting, and whaling locatinna, and the needs of the                                          harvested.     As noted at p. 132, If there were to. be no hunting or
                     various Native groups that use ANWR         and the Porcupine Caribou Herd                                      trapping within five miles of development areas. full leasing (Alternative
                     (PCH).   It does not present alternative development scenarios for coastal                                      A) would result in the loss of over one half of the hunting area within the
                     and rJpp!1an_zones that might be dictated by the need to protect                                                1002 lands. This would be a major impact on subsistence activities (see p.
                     subsistence sites.                                                                                              9).

                         We also    el that since neither developments nor mitigation stipulations                                         The restrictions of this type imposed in various Units on the North
                     can be predicted with precision until concrete exploration or development                                       Slope, are inconsistent.      A restriction similar to No. 21 currently exists
                     plans are preqented, the LEIS should have devoted more attention to the                                         only in Prudhoe Bay, with no discharge of firearms allowed in the Prudhoe
                     procedures that the   Secretary will recommend to Congress for involving                                        Bay Unit at all. There are no sueh restrictions at kuptiruk. A five-ndlo.
                     the public in your Department's process for making zoning and mitigation                                        restriction currently exist   s on either side of the Trans-Alaska Pipeline
                     decisions for ANWR.     Those procedures should incorporate ANILCAA Titll                                       System, but only for the discharge of firearms.           However, enforcing this
                     fit and X1 procedures. They should emphasize coordination witli local                                           restriction is difficult at best due to lack of adequate personnel and
                     and State decision-making respecting similar or integral development of                                         vehiculnr- means to enforce the. prohibition. Uncertainty of local residents
                     r
                        -e
                     oe
                     the. V
               Cd

                                                                                                                                                                                 -2-

                   at Nuiqsut over what restrictions apply hRs itself tended to            discourage                              810 (a)(3) of ANILCA requires that. prior to lensing federal land tinder
                   subsistence activities.                                                                                         any provision of low, the responsible federal agency must determine, at a

                                                                                                                                   minimum-

                        Stipulation No. 21 is grossly overbroad.          Hunting   restrictions for
                   property protection should be deferred until specific developments are                                               1)   that any significant restriction of subsistence use is necessary,
                   proposed. Before leasing, we must enter Into agreements regarding such                                               2)   that the proposed action uses the minimal amount of land
                   questions as rifle calibers and types of development, etc.. that could be                                                 necessary to accomplish such use, and
                   used in the vicinity of oil and gas facilities.                                                                      3)   that reasonable steps will be taken to minimize adverse Impacts

                                                                                                                                             upon subsistence use.

                        Moreover, with traditional subsistence areas rendered unavailable, due
                   both to potential displacement of wildlife and to hunting restrictions. you                                          In addition to the foregoing recommendntions regarding hunting
                   should consider mitigation of subsistence effects, In the form of sport                                         restrictions, we suggest that At least the following be considered-

                   hunting restrictions. Subsistence use by local residents is a priority use
                   over other consumptive uses In ANWR. 50 C.F.R. 36.11(c) (1985). The                                                  A)   The LEIS should address and Congress shoold consider those
                   haul road experience suggests that "sport" hunting Is highly concentrated                                                 factors outlined in ANILCA Section 810.           This would require
                   along roadways, and is largely unpoliced.         This could well occur Along                                             considerable further recitation of sociocultural research to satisfy
                   roadways In ANWR, to the detriment of subsistence opportunity.                                                            Section 910 (a)(3).    (See Attachment A)

                                                                                                                                        B)   Since Kaktovik residents have stated that the biological studies

                        As proposed, industrial development (port construction) Is likely to                                                 associated    with the ANWR evaluation process have been
                   .have a major Impact on subsistence whaling if sea traffic is not controlled.                                             somewhat disruptive, measures must be taken to coordinate
                   (See Part III, below).    The noise and traffic associated with I or 2 ports                                              programs (such its the LGL bowhead feeding study) so as to not
                   near Kaktovik will be a far different matter from the oectisional disturbance                                             disrupt subsistence activities.

                   now produced by passing vessels.
                                                                                                                                        C)   There should be a full listing of the villages (U.S.          Canadian)

                        There is little mention of the ANILCA Section 810 process.            Section                                        that use the PCII.

                                                            -3-                                                                                                              -4-

                        D)   The LEIS must recommend to Secretary Hodel specific legislative                                              LEIS, that describe stream reaches and the inland subsistence
                             language providing fo    .r full local government and resident                                               sites used for fishing.    These should guide facility siting and
                             participation in    the federal processes for mitigating and                                                 water withdrawal decisions, just as caribou calving areas have,

                             approving     (1)   exploration    or   development     plans,     (2)                                       and more precise maps should be used in the Final LEIS.

                             transportation and utility systems, including roads, pipelines,

                             docks and ports,      (3) proposals to zone areas off-limits to                                   11.  COMPARING CENTRAL ARCTIC AND PORCUPINE CARIBOU HERDS

                             development, (4) restrictions on subsistence and non-subsistence

                             access.   The subsistence users must be fully apprised well                                            Any attempt to extrapolate to the PCH as it may be Impacted by
                             before development plans are decided.        Such briefings should                                ANWR leasing, the apparent success of the Central Arctic Herd (CAH)

                             clearly explain the significance of the development for continued                                 near Prudhoe Bay should note the following points.

                             subsistence hunting, and for possible socioeconomic and cultural

                             disruptions.                                                                                           JL)   The CAH   has not had a population decline. in part.      because a)

                                                                                                                                          the CAR   has only been displaced from a part of         its calving

                        E)   The document should state how. subsi stence- related mitigation                                              ground, b) there seems to be plenty of habitat for the CAH,
                             stipulations will be enforced and how the public can be involved                                             and c) the density of the CAH on their calving ground is low

                             In their enforcement.                                                                                        (p. 108).

                                                                                                                                    2)    The density of the PCH on the calving grounds is about 14 times

                        F)   The go@ernment should be authorized to control seasonal sea                                                  the density of the CAH calving grounds. (p. 108). This means

                             traffic to and from the ANWR docking facility,                                                               that the very large PCH is "packed     into" Its calving area. while

                                                                                                                                          the very  small CAH has "plenty of    room" on its calving grounds

                        G)   The port alternative east of Haktovik would be far more likely to

                             interfere with whale feeding and hunting than would the
                             alternative site near Camden Bay.                                                                      3)    Full ANWR development could potentially displace the PCH from

                                                                                                                                          32% of their most critical core calving area (p 108).

                        H)   The Borough provided your staff with maps, not used in the

                        4)   Because of the much greater density of PCH on their calving                                          If a pipeline and roads extend into ANWR, such "infrastructure" will make
                             grounds, the PCH will interact much more extensively with oil                                        development of nearby offshore prospects much more likely.                This is

                             development In ANWR than has the CAH near Prudhoe Bay (p                                             especially important since the nearshore area from Camden Bay to the

                                                                                                                                  Canadian border is already of great interest to the industry and the same

                                                                                                                                  waters appear to be Important feeding habitat for the bowhead.

                  111. IMPACTS ON WHALES AND FISH

                                                                                                                                        Disturbance studies have not shown conclusively that bowheads will

                        Kaktovik Whalers   have voiced serious concerns regarding the adverse                                     habituate to vessel traffic.      The statement on p. 119 that "long-term
                  effects of marine traffic on their hunting success.             The fundamental                                 behavioral effects from noise and vessel disturbance have not been
                  importance of subsistence activities to the proper functioning of the                                           demonstrated or measured" may be an overstatement.                Studies in the
                  Inupiat family and community is not clearly stated or well referenced. See                                      Canadian Beaufort have shown A steady decrease since 1980 in the use of
                  the Attachment A for a listing of pertinent    sources.                                                         the "industrial zone" during exploratory activities (Richardson, et al.

                                                                                                                                  1985).   Additionally, the effects of short term disturbances are not

                        The brief description at p. 119 of the    "Impacts" to bowhead whales Is                                  conclusive, as the authors point out on p. 119. A port facility may have
                  inadequate and does not mention that the marine waters off ANWR appear                                          considerable effects on whale distribution (avoidance of marine traffic) and
                  to be a major bowhead feeding area. (See attached Figure 1).                  This                              certainly on hunting success. particularly if a major sea lift was delayed
                  section must also be strengthened to recognize that noise disturbance from                                      Into late August or September because of bad ice conditions.

                  one or more port facilities is likely to be much more significant than

                  reactions of individual whales to noise sources reported in other studies.                                            The areas used In subsistence whaling activities extend beyond those

                  The conclusion (p. 119) that there would only be minor behavioral changes                                       outlined in the LETS. The region used extends west to 1441, east to 1431
                  is premature and not supported.                                                                                 30', and 25 nautical miles seaward.

                                                                                                                                        In addition to the effects of causeways, recited at p. 125, you should
                        Any discussion of potential ANWR impacts to bowhend whales must                                           note that several studies have documented causeway-induced (solid fill)
                  take Into consideration how ANWR activities are likely to influence further                                     changes to the nearshore temperature and salinity refrimes (Moulton et al.
                  development at Point Thomson and in the offshore Area adjacent to ANWR.                                         1985., Envirosphere 19F5). Such changes reduce suitable feeding habitat

                                                            -7-

                    (Nell. et al. 1983).    Numerous proposed or existing causeways used for                                        water usage for both exploration and development. As noted previously in
                    docking facilities and accessing nearsbore oil fields may have measurable                                       the discussion, these areas of access should be better documented. The
                    effects on anadromous fish populations (Craig 1984).          For instance, this                                NSB provided your staff' good maps for this purpose. Entire stream popu-
                    may prevent the recruitment of young arctic cisco to the Colville River                                         lations of arctic char or grnyling could be destroyed by dewatering such
                    (Callaway et al. 1983).                                                                                         areas, especially during winter months when many portions of a stream or

                                                                                                                                    river may be frozen completely to the stream bed.

                         The effects of leasing the Coastal Plain must be considered

                    cumulatively with the likely additional leasing of adjacent state, Native and                                         There must be established a "Technical Review Committee", modeled
                    federal lands.    The Coastal Plain borders on three offshore State Lease                                       after the Endicott T.R.C., to monitor local and cumulative impacts to fish,
                    Sales (50, 51, and 55), and Federal Lease Sale 97.           If developed. these                                and to recommend mitigation when needed.             Information from the most
                    will effectively "seal off" the Village of Kaktovik and potentially                                             recent studies of the Endicott Environmental Monitoring Project, the West
                    Industrialize the Eastern U.S. Beaufort coast.           Also. marginal fields,                                 Dock Causeway, and the Lisburne Project should                   be incorporated
                    (e.g., Point Thomson) may become economically viable once access is                                             continually into the design of mitigation measures outlined for this study.

                    established Into the Coastal Plain.

                                                                                                                                    IV. MITIGATION OF CONSTRUCTION ACTIVITIES

                         Accordingly, we recommend that the Final LEIS contain a more pointed

                    analysis of the effects that docks, wAterflood facilities, and related                                                Weiland Loss To Leachates -         Enforcement of wetland loss due to
                    shipping traffic, and industrial support facilities can have, in terms of                                       reserve pit contents leaching through or spilling over the pit (likes onto
                    obstruction and noise, on subsistence activities, fish, whales, the coastal                                     wetlands should be addressed in the      LEIS.

                    environment, and Inuplat lifestyles and culture.         There should be more
                    specifics, at p. 125, on the design of causeways, docks and wat            .ernood                                    Based on our    experiences in the Prudhoe Bay. Kuparuk River and
                    facilities to mitigate their cumulative effects.                                                                Milne Point oil an(] gas units, use and maintenance of reserve pits can and

                                                                                                                                    has caused concerns with respect to pit contents spilling onto the tundra.
                         Overwintering fish habitat deserves special attention.        Water Is very
                    limited on 1002 lands and serious conflict- will most likely arise regarding                                          For example, drill miids and cuttings placed into the pits as an

    allowed practice provided that they are not contaminated with
    hydrocarbons.  And yet not only hydrocarbons but crude oil has been
    discovered in the pits.  And when they are allowed to overtop or are
    breached, the contents, including the hydrocarbons and crude oil escape
    onto the tundra.

    Additionally, reserve pits are often used for the disposal of snow in
    the winter and if not managed so as to disperse the snow evenly in the
    pit, overtopping of the pit can occur in the spring when the snow melts
    and fills the pit.  If flowlines and other pipelines are constructed around
    the pit such that pipeline construction prevents the maintenance of the
    breach or be eroded out and spill their contents out onto the tundra.  This
    is an issue that should be addressed in ANWR and proposed regulations.

    -11-

                                               AXIACHMENT A                                                            REFERENCES

            Chance, Norman A. 1966. The Eskimos of north Alaska. Holt, Rinehart and
                  Winston, New York, NY. 107 pp.                                                                       Coffing, M., and Pedersen, S., 1985, Caribou hunting-Land use
                                                                                                                              dimensions, harvest level and selected aspects of the hunt
            Libbey, David. 1981. Kaktovik Cultural Resource Survey. North Slope Borough,
                  Barrow, Alaska 99723                                                                                        during    regulatory     year     1983-84    in    Kaktovik,      Alaska:
            Nielson, Jon M. 1977. Beaufort Sea Study-historic and   subsistence site                                          Fairbanks, Alaska Department of Fish and Game, Divisionof
                  inventory: a preliminary cultural resource assessment. North Slope Borough,                                 Subsistence, Technical Paper 120, 38 P.
                  Barrow, Alaska 113 pp.
            North Slope Borough 1979. Native livelihood and dependence, a study of land use                            Craig, P.C. 1984.         Fish Use of Coastal Waters of the Alaskan
                  values through time. U.S. Dept. of the Interior, Anchorage, Alaska                                          Beaufort Sea:      A Review.    Transactions of the American
                  National Petroleum Reserve in Alaska 105(c) Land Use Study, Field Study 1.
                  Report for National Petroleum Reservein Alaska 166.pp.                                                      Fisheries Society 113:265-282.
            .Patterson, Art. 1978. Native livelihood and dependence: National Petroleum                                Envirosphere        Co.    1985.         Preliminary       Draft,.     Endicott
                  Reserve in Alaska. National Petroleum Reserve in Alaska Work Group 1,
                  (Anchorage, AK). Task Force field report 187pp.                                                             Environmental      Monitoring      Program.      Prepared     for      the
            Spencer, Robert F. 1959. The North Alaskan Eskimo: a study in ecology and                                         Department of the Army, U.S. Army COE, Alaska District,
                  society. Smithsonian Institution, Washington, DC. Bulletin 171 (Reprinted                                   Anchorage, AK. and Standard Alaska Petroleum Company.
                  in 1976 by Dover Publications, Inc. New York, HY.@ 4913 pp.

            worl, Associates. 1978. Beaufort Sea Region Sociocultural Systems. U.S.                                    George, J.C. and Tarpley, R.J. 1986.              observations on the        1984
                  Bureau of Land Management, Anchorage, AK. Alaska OCS Socioeconomic Studies
                  Program. Technical Report 9. 168 pp.                                                                        and 1985 subsistence harvest of Bowhead Whales, Balaena
                                                                                                                              Mysticetus. with a note on the fall 1983 harvest.- Rep. Int.
            Worl, Robert, Rosita Worl, and Thomas Lormer. 1981. Beaufort Sea Sociocultural
                  SystenLs Update Analysis. U.S. Bureau of Land Management, Anchorage, AK.                                    Whal. Commn 36.
                  Alaska OCS Socioeconomic Studies Program. Technical Report 64. 238 pp.
            Worl, R. and Smythe, C.W. 1986. Barrow: A Decade of Mr-dernization Minerals                                Klein,     D.R.    1980.    Reactions     of   caribou     and   reindeer      to
                  Management Service, Anchorage Alaska. Technical Report 125. 455 pp.                                         obstructions-A reassessment,          p.519-527,     in Reimers,       E.,
                                                                                                                              Gare,. E. and Skjenneberg,S. editors, Proceedings of the 2nd
                                                                                                                              International Reindeer/Caribou Symposium, Roros, Norway:
                                                                                                                              Direktorate for vilt og ferskannsfisk, Trondheim, 799 p.

               Ljungblad, D.K., S.E.      Moore and D.R. Van Schoik.      1984. Aerial                       Neill, W.H., Fechhelm, R.G., Gallaway, D.J., Bryan, J.D.,              and
                     surveys of endangered whales in the northern Bering, eastern                                  Anderson,     S.W.    1983.    Modeling     movements      and
                     Chukchi and Alaskan Beaufort Seas, 1983:        with a five year                              distribution of arctic cisco (Coregonus autumnalis)
                     review, 1979-1983. NOSC Tech. Rep. 955, Naval Ocean Systems                                   relative    to   temperature-salinity     regimes    of    the
                     Center, San Diego, CA. 356 p.                                                                 Beaufort Sea near the waterflood causeway, Prudhoe Bay,
                                                                                                                   Alaska.   Biological Papers of the University of Alaska
               Ljungblad, D.K., Moore, S.E., Clarke, J.T., Van Schoik, D.R., and                                   21:4-23.
                     Bennett, J.C. 1985. Aerial surveys of endangered whales in
                     the northern Bering, eastern Chukchi, and Alaska Beaufort                               Richardson, W.J., Greene, C.R., and Wfirsig. 1985. Behavior,
                     Seas, 1984: with a six year review, 1979-1984. Technical                                      disturbance responses and distribution of bowhead
                     report 1046. Prepared for USDOI, MMS. San Diego, CA: Naval                                    whales Balaena mysticetus in the eastern Beaufort Sea, 1980-
                     Ocean Systems Center.                                                                         84: summary. Unpubl. Rep. from LGL Ecol. Res. Assoc., Inc.,
                                                                                                                   Bryan, TX, for U.S. Minerals Management Service, Reston, VA.

               Ljungblad, D.K., Moore, S.E., and Clarke, J.T. 1986. Assessment                               Richardson, W.J., Wursig, B., Miller, G. W., Silber, G. Bowhead
                     of bowhead whale (Balaena mysticetus) feeding patterns in                                     Distribution, Numbers and Activities.        rn* W.J. Richardson
                     the Alaskan Beaufort and northern Chukchi Seas via aerial                                     (ed.,) Importance of the Eastern Alaskan Beaufort Sea to
                     surveys Fall 1979-84@ Rept. Int. Whal. Comm. 36:265-272.                                      feeding bowhead whales, 1985.       Rep. from LGL.     Ecol. Res.
                                                                                                                   Assoc., Inc., Bryan, TX., for U.S. Minerals Management
               Lowry, L.F. and Burns, J.J. 1980.          Foods utilized by bowhead                                Service, Reston, UA. 315 p.
                     whales near Barter Island, Alaska, Autumn 1979. Mar. Fish.
                     Rev. 42 (9-10):88-91.                                                                   Shideler, R.T., M.N. Robus, J.F. Winters and M. Kuwada. 1986.
                                                                                                                   Impacts of human developments and land use on caribou: a
               Lowry, L.F. and Frost, K.J. 1984.       Foods and feeding of bowhead                                literature review. Volume 1: A worldwide Perspective. Alaska
                     whales in western and northern Alaska.           SCI.Rep. Whales                              Department of Fish and Game, Division of Habitat, P.O. Box
                     Res. Inst. 35:1-16.                                                                           3-2000, Juneau, Alaska 99802. 219 pp.

               Moulton, L.L., Fawcett M.H., and Carpenter, T.A. 1985. Lisburne                               Valkenburg, P., and J.L. Davis.       1985.   The reaction of caribou
                     Development Environmental Studies:         1984.     Fish, Final                              to aircraft:    a comparison of two herds.     Pages 7-9 j-n A.M.
                     Report, Chapter 5, Vol. 4. Prepared for ARCO Alaska, Inc.,                                    Martell and D.E. Russell, eds.        Proceedings of the first
                     Anchorage, AK, by Woodward-Clyde Consultants (Entrix, Inc.).                                  North American caribou workshop, Whitehorse, Y.T. , 1983.
                                                                                                                   Can. Wildl. Serv. Spec. Publ., Ottawa. 68 pp.

    NORTH SLOPE BOROUGH										U.S. Fish & Wildlife Services
    OFFICE OF THE MAYOR										January 23, 1987
    P.O. Box 09												Page 2
    Barrow, Alaska 99723

    Phone: 907-852-2611
    				George N. Ahmaogak, Sr., Mayor				Attachment

    													cc:	Senator Ted Stevens
    														Senator Frank Murkowski
    														Loren Ahlers, Mayor, Kaktovik
    														Kaktovik Inupiat Corporation
    							January 23, 1987					Jacob Adams, President, ASRC
    														Robert Grogan, State of Alaska
    														U.S. Fish & Wildlife Service, Anchorage
    Director													North Slope Borough Assembly
    U.S. Fish & Wildlife Services										NSB Planning Commission
    Division of Refuge											William Garner
    18th and C Streets, N.W.										Edward Itta, Director, NSB Planning Department
    Room 2343 Main Interior Building									Harold Curran, NSB Attorney
    Washington, D.C. 20240											Warren Matumeak, NSB Land Management Administrator
    														Ben Nageak, Director, NSB Wildlife Management
    Dear Sir:

    In addition to the comments we submitted on January 20, 1987, I
    would also like to submit the following comments regarding Native
    allotments of the Kaktovik residents.

    The main concern of the Kaktovik residents is to preserve the
    subsistence resources and availability of those resources.  Development of
    the 1002 area, as far as the residents of Kaktovik are concerned, is a
    secondary priority behind subsistence.

    Native allotments are an important factor in a subsistence way of life.
    There are approximately 43 Native allotments for which Kaktovik residents
    have applied.  Most of the applicants have not received title to these
    allotments from BLM and are still waiting approval.  Most of these
    applicants use their pending or approved allotment areas for subsistence
    campsites to allow them to harvest food for their winter supply.  We urge
    the Secretary of the Interior to resolve the pending Native allotment
    applications prior to the opening of ANWR for all exploration and
    development.  (Please see the attached Native allotment map).

    There are also a few subsistence campsites that have not been applied
    for that are currently used for harvesting fish and other animals.  These
    campsites are traditionally used by individual Kaktovik residents and
    should also be protected.

    						Sincerely,

    						George N. Ahmaogak, Sr.
    						Mayor

                               STATEMENT OF WARREN 0. MATUMEAK                                             WILDLIFE UPON WHICH OUR PEOPLE PRESENTLY DEPEND, AND WILL

                       REPRESENTING THE NORTH SLOPE BOROUGH, ALASKA,                                       CONTINUE TO DEPEND IN THE FUTURE.

                            BEFORE THE DEPARTMENT OF THE INTERIOR                                               FOR OVER A DECADE NOW, NATIVE SHAREHOLDERS IN THE KAKTOVIK

                               HEARINGS ON THE DRAFT ANWR LEIS                                             INUPIAT CORPORATION AND THE ARCTIC SLOPE REGIONAL CORPORATION

                                        JANUARY 9, 1987                                                    HAVE WATCHED FROM THE SIDELINES AS BILLIONS OF DOLLARS WORTH OF

                                                                                                           OIL HAS BEEN EXTRACTED FROM THEIR ANCESTRAL LAND IN THE PRUDHOE

                    ON BEHALF OF OUR NORTH SLOPE BOROUGH MAYOR, GEORGE M.                                  BAY AREA.   BOTH CORPORATIONS NOW HOLD TITLE TO LAND-HOLDINGS IN

               AHMAOGAK, SR., I WOULD LIKE TO THANK THE INTERIOR DEPARTMENT FOR                            SOME OF THE MOST PROMISING OIL AND GAS STRUCTURES IDENTIFIED BY

               GIVING US THE OPPORTUNITY TO TESTIFY HERE TODAY.         I AM WARREN                        THE LEIS.    A CONGRESSIONAL DECISION TO OPEN THE ANWR COASTAL

               MATUMEAK, DEPUTY DIRECTOR OF PERMITTING AND LAND MANAGEMENT                                 PLAIN WOULD, AT LONG. LAST, ALLOW THESE NATIVE SHAREHOLDERS TO

               ADMINISTRATOR FOR THE NORTH SLOPE BOROUGH.                                                  BENEFIT DIRECTLY FROM OIL EXPLORATION AND DEVELOPMENT ON THEIR

                    THE  QUESTION OF OIL AND GAS EXPLORATION AND DEVELOPMENT IN                            LANDS.   THIS OPPORTUNITY FOR NATIVE CORPORATIONS MUST NOT BE

               THE COASTAL PLAIN OF THE ARCTIC NATIONAL WILDLIFE REFUGE IS A                               DENIED.

               14ATTER OF CRITICAL IMPORTANCE TO THE CITIZENS OF THE NORTH SLOPE                                BEING A WHALING CAPTAINr AND THE HEAD OF A FAMILY WHICH

               BOROUGH, ESPECIALLY TO THOSE IN THE VILLAGE OF KAKTOVIK, AND                                CHERISHES THE SUBSISTENCE FOODS WHICH HAVE LONG NOURISHED THEIR
               OTHER VILLAGES, THAT WOULD FEEL MOST IMMEDIATELY THE IMPACTS OF                             HOUSEHOLD, MAYOR AHMAOGAK HOLDS STRONG FEELINGS ON THE QUESTION

               DEVELOPMENT.                                                                                OF CONGRESS OPENING THE ANWR COASTAL PLAIN TO OIL AND GAS

                    OIL AND GAS RESERVES THAT 14AY BE FOUND IN THE COASTAL PLAIN                           DEVELOPMENT.   IN NOVEMBER OF LAST YEAR, HE STATED HIS OPINION
               WOULD PLAY A CRITICAL ROLE IN THE FUTURE ENERGY SECURITY OF OUR                             THAT CONGRESS SHOULD OPEN THE ENTIRE COASTAL PLAIN OF ANWR TO OIL
               NATION, AND IN ITS BALANCE OF TRADE.        THEY WILL PROVE EQUALLY                         AND GAS EXPLORATION AND DEVELOPMENT, BUT THAT ALL DEVELOPMENTAL
               VITAL TO THE ECONOMIC STABILITY OF THE STATE OF ALASKA.                                     ACTIVITIES MUST BE SUBJECT TO STRICT ENVIRONMENTAL, SUBSISTENCE,

               RESIDENTS OF THE NORTH SLOPE BOROUGH HAVE ONLY RECENTLY BECOME                              CULTURAL AND LOCAL ACCESS REQUIREMENTS.

               ACCUSTOMED TO HAVING FINE SCHOOLS, MODERN HOUSING, POLICE AND                                    -- THE BOROUGH FAVORS ALTERNATIVE A IN THE LEIS. AS WE READ
               FIRE PROTECTION, AND OTHER SERVICES AND FACILITIES LONG TAKEN FOR                           THE   DESCRIPTION     OF   ALTERNATIVES     AND    THE     SECRETARY'S
               GRANTED BY MOST AMERICANS. RESPONSIBLE DEVELOPMENT OF ANWR WOULD                            RECOMMENDATION, PAGE 170, ALTERNATIVES A AND B DIFFER ONLY AS TO

               HELP ENABLE US TO CONTINUE PROVIDING THESE SERVICES FAR INTO THE                            WHETHER CONGRESS OF THE DEPARTMENT OF THE INTERIOR WOULD PLACE

               FUTURE.   WE 14UST ALSO CAREFULLY CONSIDER SUBSISTENCE, AND THE                             CERTAIN AREAS OF ANWR OFF LIMITS TO LEASING.

                                                                                                                                             2

                     WHILE WE AGREE WITH SECRETARY HORN THAT THE UPPER JAGO RIVER                       BELIEVE IT MUST BE IMPROVED BY A DISCUSSION OF OTHER NORTH SLOPE

                AREA SHOULD BE PLACED OFF LIMITS TO DEVELOPMENT WOFK  FOR A PERIOD                      DEVELOPMENTS, SUCH AS THE ENDICOTT CAUSEWAY AND OFFSHORE LEASING

                OF TIME, WE THINK IT WOULD BE TOO INFLEXIBLE AN       APPROACH FOR                      IN THE BEAUFOrT SEA, THAT WILL OCCUR BEFORE ANWR WOULD BE LEASED

                CONGRESS ITSELF TO DELINEATE ZONES  IN ANWR THAT MUST BE KEPT FREE                      AND THAT COULD HAVE CUMULATIVE EFFECTS ON FISH AND WILDLIFE,

                FROM ALL FORMS OF OIL AND GAS ACTIVITY.        IT IS  IMPORTANT TO                      NORTH SLOPE RESIDENTS, AND THE BOROUGH'S FINANCIAL RESOURCES.

                RECOGNIZE THAT EXPLORATORY WORK, INCLUDING DRILLING,  HAS BEEN AND                           WE HAVE SEEN AT NUIQSUT TRADITIONAL HUNTING.ACTIVITIES BEING
                CAN BE CONDUCTED DURING THE WINTER MONTHS ONLY, LEAVING NO                              GRADUALLY DISPLACED BY RESTRICTIONS IMPOSED AT THE PRUDHOE BAY

                APPRECIABLE EFFECT ON CARIBOU HABITAT. AND MI  TIGATION TECHNOLOGY                      AND KUPARUK UNITS. THIS TYPE OF PROBLEM SHOULD BE LOOKED AT MORE

                IS IMPROVING.                                                                           CAREFULLY IN THE LEIS FOR DEVELOPMENTS IN AND AROUND ANWR.
                    'WHEN KUPARUK AND PRUDHOE       WERE  INITIALLY PROPOSED, I                              FINALLY,.THE LEIS SHOULD C014TAIN A MORE DETAILED DISCUSSION

                PERSONALLY TOOK THE APPROACH THAT LARGE AREAS AROUND THESE FIELDS                       OF REGULATORY ALTERNATIVES FOR CONTROLLING USE OF ANWR BY NATIVE

                SHOULD BE ZONED OFF-LIMITS TO ANY          DEVELOPMENT.   BUT OUR                       AND FEDERAL LESSEES, FOR COORDINATING THE SAME WITH THE BOROUGH

                CASE-BY-CASE REVIEW OF OIL C014PANY PLANS, AND THE STIPULATIONS                         AND THE CITY OF KAKTOVIK, AND FOR INVOLVING LOCAL RESIDENTS IN

                THAT WE INSISTED UP    ON, HAVE SHOWN THAT WILDLIFE AND OIL                             REVIEW OF EXPLORATION AND DEVELOPMENT  PLANS.
                DEVELOPMENT CAN CO-EXIST IN THE ARCTIC. PROPERLY STIPULATED ON                               AGAIN, LET ME EXPRESS   MY APPRECIATION FOR THIS OPPOPTUNITY
                THE BASIS OF EXTENSIVE EXPERIENCE, WE.DON'T THINK THAT  IPI  PELINES                    TO TESTiry ON BEHALF OF OUR NORTH SLOPE BOROUGH MAYOR, GEORGE

                AND ROADS WILL RESTRICT CARIBOU MIGRATION ROUTES.                                       AHMAOGAK.

                     THE POTENTIAL IMPACTS TO OUR COMMUNITIES ARE ENORMOUS. OUR

                RESIDENTS, ESPECIALLY THOSE IN THE VILLAGE OF KAKTOVIK, MUST BE

                TREATED FAIRLY. THE BOROUGH AND ITS VILLAGES MUST HAVE ALL THE

                FINANCIAL, TECHNICAL, AND HUMAN RESOURCES POSSIBLE TO DEAL WITH

                THE IMPACTS OF DEVELOPMENT IN THEIR COMMUNITIES. THE FEDERAL LAW

                OPENING A14WR SHOULD ENSURE THAT FEDERAL REVENUE RECEIPTS ARE

                SHARED EOUITABLY WITH LOCAL GOVERNMENTS.

                     GENERALLY SPEAKING, WE FOUND THE LEIS TO BE WELL WRITTEN AND

                DOCUMENTED, CONCISE, AND HONEST IN ITS APPRAISAL OF THE EFFECTS

                THAT ANWR DEVELOPMENT WOULD HAVE ON WILDLIFE AND PEOPLE.          WE

                                                 3                                                                                       4

    NORTH SLOPE BOROUGH
    OFFICE OF THE MAYOR
    P.O. Box 69
    Barrow, Alaska 99723

    Phone: 907-852-2611
    				George N. Ahmaogak, Sr., Mayor

    						November 20, 1986

    Mr. Jacob Adams, President
    Arctic Slope Regional Corporation
    P.O. Box 129
    Barrow, Alaska 99723

    Dear Mr. President:

    Rest assured that as Mayor of the North Slope Borough.  I fully share
    your concern for the future of oil and gas development in the Coastal Plain
    of the Arctic National Wildlife Refuge.  I believe, as you do, that the
    proposed legislation would indeed work a grave injustice on the inupiat
    people.  We have long witnessed massive oil development in an extremely
    wealthy portion of the traditional inupiat homeland, now held under state
    title.  Any legislation which would prevent private corporations owned and
    controlled by Native shareholders from finally savoring the benefits of oil
    development on their own lands strikes me as terribly wrong.

    I also feel a strong sense of pride over the improvements our
    Borough government has brought to our communities.  When you and I
    were children, we had to travel far from our families and loved ones--and
    the life which we cherish--just to attend school.  Now we have fine schools
    in every village on the North Slope.  We have good roads where there
    were none.  we have modern, state-of-the-art fire houses which have
    resulted in the saving of many lives; we have water and plumbing piped
    into modern homes, we boast a first-rate Public Safety Department, and
    many other services which our people did not have in the past.

    I want to see these improvements maintained in the future.  I want to
    see them broadened, to fully benefit every citizen on the North Slope!
    This, of course, will require a solid tax base, even after Prudhoe Bay
    production drops off.  Responsible development in the ANWR Coastal Plan
    could prove vital in this regard.

    I too am concerned about out Nation's growing dependence on
    insecure sources of foreign oil.  As you have stated, the Coastal Plain
    offers the best hope of alleviating this dependence of any region in the
    United States.

    Therefore, as Mayor, I am throwing the full weight of my office into
    the effort to ensure that oil development becomes a reality on the Coastal
    Plain of the ANWR.  I will be right at your side as a leader in this fight.

    As a whaling captain, and a father who relies upon caribou, ducks,
    geese, seal, fish and other wildlife to feed his family.  I also share your
    strong concern for the well being of the wild creatures who live upon the
    Coastal Plain.  I am confident that with our Borough permitting powers,
    and the concern of corporate leaders such as yourself and Oliver Leavitt,
    we can ensure development that is ecologically sound, and which will
    protect our resources.

    Perhaps most importantly, I am concerned for our Borough citizens
    who actually live in the ANWR Coastal Plain, namely the people of
    Kaktovik.  They are the ones whose everyday lives will be most affected.
    They are the ones who will feel the direct impacts of development.  You,
    of course, are well aware of the difficulties we have had trying to secure
    a fair share of the NPR-A Impact funds for the North Slope villages hit
    hardest by exploration in the reserve.  Even after a successful lawsuit,
    we still must fight to get what is rightfully ours.

    With this in mind, I will be working to insure that an equitable
    method of revenue sharing from the federal mineral receipts for our local
    governments is enacted before any federal lease sales take place.  This
    might involve a lobbying effort to convince Congress to make
    appropriations directly to our local governments.  Any help you can give
    me here will be appreciated.  The people of Kaktovik must be treated
    fairly, and beneficially!  They must have all the financial, technical, and
    human resources possible to deal with the impacts of development in their
    community.

    I note with satisfaction the leadership you have shown in the
    organization of the Coalition for American Energy Security.  I am
    confident that this group will do much to educate Congress, and the
    public, of the importance development in the Coastal Plain of ANWR has for
    the entire nation.

    After seeking the advice of, among many others, U.S. Senator Ted
    Stevens, Kaktovik Mayor Loren Ahlers, and our attorneys in Washington, I
    feel that it would not be appropriate for me to join this group.  This will
    in no way diminish the effort I will give to make oil development on the
    ANWR Coastal Plain a reality.  I would note that one of our Washington
    attorneys, Ronald G. Birch, will be attending the coalition meetings.  He
    will keep us informed of coalition efforts, and he will inform the coalition

    of what we are doing.  This will insure that our efforts are mutual
    supportive.

    If you have any questions, or more information to pass on, please
    not hesitate to contact me.

    						Sincerely,

    						George N. Ahmaogak, Sr.
    						Mayor

    OFFICE OF THE MAYOR
    P.O. Box 69
    Barrow, Alaska 99723

    Phone: 907-852-2611
    					George N. Ahmaogak, Sr., Mayor

    Policy Statement From the North Slope Borough Mayor's Office
    On Oil Exploration and Development on the Coastal Plain
    of the Arctic National Wildlife Refuge

    Legislation currently in the U.S. Congress would designate the 1.5
    million acre Coastal Plain of the Arctic National Wildlife Refuge as
    wilderness.  All oil and gas exploration and development activities would
    be prohibited.  The Mayor of the North Slope Borough, George N.
    Ahmaogak, Sr., recognizes the potential economic and social benefits
    development in this region could bring to the North Slope Borough and its
    residents.

    Based primarily upon tax revenues on property in the Prudhoe Bay,
    Kuparuk River, and other oil fields, the Borough has in the past decade
    built a comprehensive network of schools, roads, housing and facilities and
    services of many kinds in all of its villages.  A strong, secure tax base is
    necessary to support these facilities in the future, including during that
    time when production at Prudhoe Bay begins to wind down.  Oil
    exploration and development within the ANWR Coastal Plain would provide a
    significant portion of that tax base.

    Many residents of the North Slope Borough are shareholders in Native
    regional and village corporations owning surface and subsurface rights
    within the ANWR Coastal Plain.   Oil development within the ANWR Coastal
    Plain would provide these corporations with their first opportunity to profit
    from oil development of their own lands.  The corporations and their
    individual shareholders stand to reap substantial benefits from such
    development, which would be positive for the Borough as a whole.  It is
    the feeling of the North Slope Borough Mayor that legislation preventing
    the Native shareholders from developing their own lands and resources
    would constitute a grave injustice.

    The State of Alaska has built an economy largely dependent upon oil,
    and stands to suffer when Prudhoe Bay goes into decline.  The Coastal
    Plain of ANWR holds the only real potential for another oil and gas
    discovery of reserves comparable to Prudhoe Bay.  The State and all of its
    citizens stand to benefit greatly from the finding and development of such
    reserves, and to suffer if these reserves are locked up.

                 'ANWR Policy Statement
                  Page 2

                       Oil production In   the United States has been decling even as oil
                  consumption has risen. The percentage of oil produced domestically drops
                  smaller and smaller, worsening the balance of trade, and placing the
                  energy security of the Nation ever more  * into the hands of other nations.
                  such as the member-states of OPEC.         The Coastal Plain of ANWR has
                  greater potential than does any other on-shore region in the United
                  States.   In fact. estimates of potential  reserves in ANWR Indicate they
                  could.exceed one third of all current U.S. reserves, and are likely greater
                  than were the reserves at Prudhoe Bay when first discovered.             The
                  development of oil and gas reserves In the Coastal Plain Is vital to U.S.
                  energy security.

                       In light of all of this, it is the policy of Mayor George N. Ahmaogak,
                  Sr., and his office. to fully support the future exploration and
                  development of the. Coastal Plain of ANWR.

                       The Mayor is deeply concerned that North Slope residents who will
                  feel the impacts of this development most strongly, namely the residents of
                  the village of Kaktovik on Barter Island, be fairly Included In revenue
                  sharing to offset these impacts and to enhance the quality of village life.
                  The Mayor and his office will strive to see that an equitable method of
                  sharing the pre-determined percentages of federal mineral receipts with
                  affected local governments, and of allocating these funds to them. is In
                  place prior to any federal lease sales. This will require close work with
                  both State and federal governments.
                       The Mayor Is also deeply concerned with the wildlife and naturAl
                  resources of the Coastal Plain.     The Borough will undertake whatever
                  steps are necessary to ensure that development takes place in an
                  ecologically sound manner. resulting in minimal effects upon the wild
                  resources of the ANWR Coastal Plain.

                                                                                                                       Geophysical hislitute, Unimsity of 4laska

                January 19, 1987                                                                                            Page 2

                                                                                                                                4.   Poker Flat Research Range, while owned and operated by the Geophysical
                                                                                                                                     institute, University of Alaska. Is totally funded by and operates
                                                                                                                                     under the aegis of a federal government contract. It is considered
                Division of'Refuge Hanagement                                                                                        a national asset as It is the only arctic/auroral zone research sounding
                U. S. Fish & Wildlife Service                                                                                        rocket launch range on U. S. soil.
                Department of the Interior                                                                                  There is enclosed, besides the map referred to above, a document describing the
                2343 Hain Interior Building                                                                                 range, its users and other data for your information.
                l8th and C Streets, NW
                Washington, DC 20240                                                                                        Very truly yours,
                Re: Arctic National Wildlife Refuge
                Dear Sir:                                                                                                   Neal B. Brown, Director
                Poker Flat Research  Range, Geophysical Institute, University of Alaska, submits                            Poker Flat Research Range
                the following comments with regard to the Department of Interior's recommendation
                that the Arctic National Wildlife Refuge (ANWR) be opened to oil and gas explore-                           Enclosures
                tion.

                Poker Flat is against opening the coastal plain of the ANWR to oil and gas explor-
                ation, as follows:

          -4         1.  This area is an integral part of Flight Zone 3 Arctic Extension, one
                         of the range's main flight zones for research sounding rockets (see
                         map attached). This flight zone van established and Is used under a
                         Certificate of Waiver and Authorization as issued by the Federal
                         Aviation Administration.

                     2.  The lands lying beneath and immediately adjacent to this flight zone
                         are used for the impact and recovery of research rocket motors and
                         payloads under a U. S. Department of the Interior, Fish and wildlife
                         Service, Special Use Permit.

                     3.  Safety is a prime concern of Poker Flat Research Range in the launching
                         and the recovery of the rocket motors and payloads/instrumentation.
                         Most of these research sounding rockets are for auroral research pur-
                         poses and are launched at night during the winter months; however,
                         launches are conducted during other times of the year for upper atmos-
                         pheric research, such as ozone. The research sounding rockets launched
                         from Poker Flat are unguided and do not carry destruct systems. Thus,
                         the opening of the lands within or immediately adjacent to this flight
                         zone to diverse groups for exploratory assessment, would effectively
                         close the zone, which is vital to the continued research being conducted
                         from Poker Flat.

                                         Geophysical Institute, University of Alaska
                                              Fairbanks, Alaska 99775MW
                                     PHONE, 907-474-7282 TELEX: 3S414 GEOPH INST F8K

                     Established by Act of Conglose,dedlIfitsJ to the mol,te-c. of geophvilcai r-ch conc-Ing the A,ct,C

                                       POKER FLAT RESEARCH RANGE
                                                                                                                                               PARTIAL LIST OF RANGE USERS
                 Poker Flat Research Range, primarily a sounding  rocket launch facility                                                               (1969 - 1986)
            dedicated to auroral and middle to upper atmospheric   research, to located north                                     United States:
            of Fairbanks, Alaska. at 30 Mile Steese Highway. Owned and operated by the                                                   Advanced Research Projects Agency
            Geophysical Institute. University of Alaska, It to the only university owned                                                 Aerospace Corporation
            launch range In the world. it to also the only high latitude and auroral zone                                                Air Force Geophysics Laboratory
            rocket launch facility located on United States soil.                                                                        Cornell University
                                                                                                                                         Defense Nuclear Agnecy
                 Self-supporting, Poker Flat to funded through contracts with the National                                               Florida Atlantic University
            Aeronautics and Space Administration (NASA), the Defense Nuclear Agency (DNA),                                               Geophysical Corporation of America
            the U.S. Air Force Geophysics Laboratory (AFCL), the National Science Foundation                                             Geophysical Institute, Univ. of Alaska
            (NSF) and the National Oceanic and Atmospheric Administration. Seven university                                              Lincoln Laboratory, MIT
            employees work year-round at the facility maintaining the physical plant and                                                 Los Alamos Scientific Laboratory
            the various waivers, approvals and agreements necessary to the operation.                                                    National Aeronautics and Space Administration
                                                                                                                                         National Oceanic and Atmospheric Administration
                 Scientists and technicians from many federal agencies and   from universities                                           National Science Foundation
            throughout the United States and abroad visit Poker Flat to conduct suroral,                                                 Pennsylvania State University
            ozone, solar proton, electric and magnetic field, ultraviolet and other atmos-                                               Sandia Corporation
            pheric research. Ten to fifteen major sounding rockets, plus a number of meteor-                                             Science Applications, Inc.
            ologleal tockets, are launched from the site each year. Other ongoing research                                               Space Data Corporation
            projects are: An automated Umkehr measurement station, one of six worldwide                                                  Rice University
            stations called the Automated Dobson Network (ADN), for ozone measuremets and                                                United States  Air Force, Space Division
            observations; and an air sampling/monitoring station operated for the University                                             United States  Air Force, HMO
            of Alaska. The range also cooperates with and helps support the USDA Institute                                               United States  Army, BMD
            of Northern Forestry's Carlbou-Poker Creeks watershed research project.                                                      University  of California at Berkeley
                                                                                                                                         University  of California at San Diego
                 Support facilities include the Poker Optical Observatory which houses                                                   University  of Colorado
            magnetometers, riometers, all-sky auroral cameras, scanning photometers and                                                  University  of Deaver
            other observing Instruments, and a low-light-level color television with video                                               University  of Michigan
            recorder for auroral research. The National Oceanic and Atmospheric Administra-                                              University  of Minnesota
            tion (NOAA) operates a Mesoapheric-Stratospheric-Tropospheric (MST) radar at                                                 University  of New Hampshire
            Poker Flat; this radar measures the direction and wind speeds at different                                                   University  of Rhode Island
            atmospheric levels.                                                                                                          University  of Texas at Houston
                                                                                                                                         University  of Washington
                 In addition to Its Importance to the scientific communityt Poker Flat                                                   University  of Wisconsin
            Research Range also contributes economically to Fairbanks and to Alaska: The                                                 Utah State  University
            annual budget for -the operation and maintenance of Poker Flat is over $1,000,000.
            with physical facilities valued at approximately $15,000,000; the per them paid                                        Foreign:
            annually to the user scientists and their support personnel amounts to approxi-w                                             Denmark
            mately $1,000,000, most of which in spent in. the Fairbanks area; and each mission                                           Japan
            spends $25,000 or more on air and truck freight.                                                                             Sweden
                                                                                                                                         United Kingdom
                 Throughout Its 17 year history, Poker Flat has enjoyed the support of a
            number of federal, state and military agencies. Permission to Impact rockets'
            and payloads on some nine million acres of land Is given by the Bureau of Land
            Management, the U. S. Fish and Wildlife Service, the State of Alaska Division of
            Lands and Doyon, Ltd. The land on which the site Itself Is located is owned by
            the University of Alaska. The U.S. Air Force provides aircraft and crews for
            payload recovery, some logistical support and, with the use of L-band transponders,
            can furnish radar tracking support. The Federal Aviation Administration approves
            requested rocket flight zones and coordinates air space during rocket launches,
            and the Alaska Department of Transportation gives the range permission to stop
            road traffic on the Steese Highway during launches.

            05/1986

                                           POKER FLAT RESEARCH RANGE                                                                  RESEARCH SOUNDING ROCKET VEHICLE SYSTEMS
                                                                                                                                                    LAUNCHED FROM
                                                                                                                                       POKER FLAT RESEARCH RANGE, 1969 - 1985
                                            PERFORMANCE 1969 - 1986

                                                                                                                               Vehicle				    Number of Launches

                                                                                                                               Astrobee D					8
                              o    217 major high-altitude rocket experiments:  								   Black Brant IVB				2
                                                 													   Black Brant VA					1
                                       GEOPHYSICAL INSTITUTE                    1                                              Black Brant VC					7
                                                                                                                               Black Brant IX					2
                                       NASA:                                                                                   Black Brant X					7
                                                                                                                               Bullpup-Apache					4
                                            University                        66                                               Castor						1
                                            														   Honest John-Hydac				3
                                            NASA Center                       44                                               Honest John-Javelin				1
                                                                                                                               Honest John-Nike-Hydac			2
                                       NATIONAL SCIENCE FOUNDATION             7                                               Honest John-Nike-Javelin			3
                                       															   Honest John-Tomahawk				5
              				     DEFENSE NUCLEAR AGENCY                 66                                               Nike-Apache					3
                                                                                                                               Nike-Hydac				     13
                                       AIR FORCE GEOPHYSICS LABORATORY         6                                               Nike-Javelin					4
                                                                                                                               Nike-Orion					8
                                       OTHER                                  27                                               Nike-Tomahawk				     61
                                                                                                                               Orion						4
                                                                                                                               Paiute-Apache					1
                               o   1700 Meteorological rocket launchings                                                       Paiute-Tomahawk				8
                                                                                                                               Sandhawk-Tomahawk				5
                                        (1971-1979 thrice-weekly data base to 65 km)                                           Sergeant                              11
                                                                                                                               Sergeant-Hydac                         6
                               o   Range Records:                                                                              Strypi                            	2
                                                                              						               Talos-Sergeant-Hydac				5
                                          Altitude - 1400 km                                                                   Talos-Castor					6
                                                                                                                               Taurus-Nike-Tomahawk				1
                                          Loft     - 5985 lbs. to 113 km                                                       Taurus-Orion					9
    																				   Taurus-Tomahawk				5
                                                                                                                               Terrier-Malemute			     10
                                                                                                                               Terrier-Sandhawk			     	4
                                                                                                                               Terrier-Tomahawk				1
    																				   Ute-Apache					1
    																				   Ute-Tomahawk					3

                                                                                       W@
                 121

                                                                                     A

                                                                                                                  ;lr

                                                                              UV

                                                                                         AA

                                         qu

                                                                                                    nN
                                                          Wy.

                                            L.A

                                            p

                         ONC C-9

                         sc@ mANAM   P;::@z

                                              GP&@17!OPIAL NAVIC,'%W@M CHART

                                                       Venetie Village Council
                                                       Venetie, Alaska .99781

              February 6, 1987

              U.S. Fish and Wildlife Service
              ATTN: Division of Refuge Management
              2343 Main Interior Building
              18th and C Streets
              N.W. Washington, D.C. 20240

              Dear U.S. Fish & Wildlife Service:

              We are writing our comments on the Draft Report about whether
              to allow oil and gas development in the Arctic National Wild-
              life Refuge. The people of the village of Venetie are opposed
              to allowing this development, because it will harm the Porcupine
              Caribou Herd.

              the Draft Report does not discuss the importance of caribou to
              Venetie or to Arctic Village. caribou are important here--to
              lose them would be to lose an important source of food and an
              important part of our culture. The Report should discuss these
              impacts on Venetie and Arctic Village to the same extent as it
              talks about effects on Kaktovik.

              The Report talks about the "core" calving area, which makes it
              sound like only that region is critical to the caribou. we
              @elieve that the entire coastal plain is critical and sould    be
               category I" habitat.

              We are opposed to any exploration and development. But if you
              are going to allow development, your standard of "unnecessary
              adverse effects" is wrong--development should be allowed only
              if it is compatible with the protection of subsistence and
              subsistence resources. And there should be no development
              until a11 Native allotments have been completely given to
              those who should have received them long ago.

              You should have held hearings here and in Arctic Village. If
              you had come here, you would have heard people tell you about
              how vital caribou are to our people here. They would have
              asked you whether 20 days worth of oil is worth the destruction
              of our culture.

              Thank you for your attention to the comments.

                                             sincerely,

                                             Venetie- Village Council
                                             Ist Chief -'MacArthur Tritt
                                             2nd Chief - Jim Christian
                                             Council Members:
                                             Eddie Frank
                                             Neil Sam
                                             Pete Peter
                                             John Titus
                                             Larry Williams

                                                                               Comments from Organizations (0)

                                                                                                                                                         Page

                                                           Akhiok-Kaguyak Inc         .......................................................................................... 0- 1
                                                           Alaska   Center for the Environment         ................................................................ 3
                                                           Alaska   Coafition for American Energy Society            ............................................. 5
                                                           Alaska   Friends of the Earth         ............................................................................  10
                                                           Alaska   Oil and Gas Association            ....................................................................  12
                                                           Alaska State District Council of Laborers            ..................................................... 130
                                                           Alaska   Support Industry Alliance          ................................................................... 151
                                                           Alaska Wildlife Alliance              .................................................................................... 134
                                                           American Petroleum Institute          ........................................................................... 135
                                                           American Wilderness Alliance          ......................................................................... 143

                                                           Anchorage Chapter - National Wildlife Refuge Association                  ........................ 162
                                                           Animal Protection Institute of America          ........................................................... 166
                                                           Arctic, Audubon Society               .................................................................................... 168
                                                             Testimony of Arctic Audubon Society              ........................................................ 179
                                                           Arctic Slope Regional Corporation           ....  ............................................................. 183
                                                           Audubon Society, Anchorage            .......................................................................... 186
                                                           Audubon Society, Alaska               ................................................................................. 188
                                                           Canadian Wildlife Federation          ............................................................................ 197
                                                           Council of Yukon Indians              ................................................................................. 200
                                                           Defenders of Wildlife      ......................................................................................... 206

                                                           Dunes Calumet Audubon Society               ................................................................... 212
                                                           Environmental Defense Fund            ........................................................................... 213
                                                           Friends of the Earth       .......................................................................................... 217
                                                           Greenpeace USA         ............................................................................................... 220
                                                           International Porcupine Caribou Commission, Alaska                  ................................. 222
                                                           International Association of Geophysical Contractors                ................................ 224
                                                           National Audubon Society              ...........................................I .................................... 228
                                                           National Audubon Society, Alaska            ................................................................. 250
                                                           National Park and Conservation Association                ............................................... 257
                                                           National Wildlife Federation          ............................................................................. 259

                                                           National Wildlife Refuge Association           .............................................................. 261
                                                           Natural Resources Defense Council              .............................................................. 265
                                                           New England Fuel Institute            ............................................................................. 292
                                                           Northern Alaska Environmental Center              .......................................................... 298
                                                           Pacific Legal Foundation              ................................................................................. 316
                                                           Renewable Resources Inc               . .............................................................................. 321
                                                           Resource Development Council for Alaska, Inc               . .......................................... 364
                                                           Rocky Mountain Institute              ................................................................................. 410
                                                           Rural Alaska Community Action Program                ..................................................... 415
                                                           Sierra Club     ..............        .......              ......- .................................... 417

                                                           Trustees for Alaska        .......................................................................................... 434
                                                           Washington Native Plant Society             ................................................................... 454
                                                           Wilderness Society         ...............................I ............................................................. 455
                                                           Wilderness Society, Alaska            .............................................................................. 472
                                                           Wildlife Federation of Alaska         ............................................................................ 474
                                                           Wildlife Management Institute         ...............................................4 ......................... 481

         JOHN ANTHONY ITONY) SMITH SMITH. GRUENING. BRECHT, EVANS & SIOITZFADEN JAMES R SZENDER
         CLARK 5 GRUFNING'                 ATTORNEYS AT LAW                     PATRICK RUMLEY
         AAWS J BRECHT           801 B STREET. - SUITE 300 - ANCHORAGE. ALASKA 9950 DANIEL PATRICK 0 TIERNEY U.S. Fish  wildlife Service
         CHARLES 0. EYANS           1907) 276 4691 - TELECOMER (9071277-4071  STEWENE GREER
         ROVIERT S SRTZFADEN'                                                                              February 6, 1987
         ROGERG CONNOR      217 SECOND STREET . SUITE 204 - JUNEAU. ALASKA 9919101 - f907) 566 8110 JUNEAU OFT'WE Page 2

                                                                                                           Water Act will serve to minimize water quality impacts from
                                         February 6, 1987                                                  operations in the area. The State of Alaska's Coastal Zone
                                                                                                           Management Program insures the involveuient of local communities
                                                                                                           affected by the operations as well as the input of interested
                                                                                                           state agencies such as the Department of Natural Resources, the
                                                                                                           Department of Fish & Game, and the Department of Environmental
                U.S. Fish III Wildlife Service                                                             Conservation. The North Slope Borough's local zoning ordinance
                Attn: Division of Refuge Management                                                        provides local authority for regulation of project activities.
                2343 Main Interior Building                                                                Added to this, the direct management authority of the Fish &
                18th & C Streets, N.W.                                                                     Wildlife Service over the area constitutes one more layer of
                Washington, D.C. 20240                                                                     insurance that impacts will be avoided or mitigated to the extent
                         Re: Comments   of Akhiok-Kaguyak, Inc.                                            possible.
                              on ANILCA Section 1002(h) Report                                                      Specific seasonal restrictions listed in the Summary of
                                                                                                           Recommended Mitigation for the 1OU2 Area should be only applied
                Dear Sir or Madam:                                                                         to the extent necessary to prevent significant Impact from
                                                                                                           occurring. Some seasonal stipulations may be impracticable from
                        on behalf  of Akhiok-Kaguyak, Inc., I provide the com-                             the standpoint of allowing continued operations, especially if
                ments set out below on the subject Arctic National Wildlife                                such restrictions were to apply during the development phase.
                Refuge ANILCA Section 1002(h) Report. Generally, Akhiok-Kaguyak,
                Inc. wishes to congratulate your Department on the preparation of                                   With regard to the disposal of drilling muds, cuttings,
                a thorouqh and well documented reDort and concurs in the                                   and other wastes, there Is a decided bias reflected In the Report
                Secretary's recommendation for full leasing of the ANILCA Section                          in favor of reinjection, without explanation as to why the use of
                1002(h) area.                                                                              reserve pits  is not appropriate.   Reserve pits have been used for
                                                                                                           many years without causing significant environmental impact at
                        The report provides a thorough evaluation of prospective                           Prudhoe Bay, Kuparak, and other areas throughout the State of
                impacts from oil and gas exploration and development.     However,                         Alaska.  Reinjection of drilling muds, cuttings, and other wastes
                in identifying these potential Impacts, the Report fails to                                should be economically feasible as well as geologically feasible.
                acknowledge the substantial mitigative effects of existing regu-
                latotV programs of the federal, state, and local governments with                                   With regard to site rehabilitation, Akhiok-Kaguyak, Inc.
                jurisdiction over the Report area. Federal agencies such as the                            recommends that applicable requirements be practicable, timely,
                United States Army Corps of Engineers, the Environmental                                   and non-redundant.   Reporting requirements should be kept to
                Protection Agency, National Marine Fishery Service, United States                          reasonable minimums so as not to burden both reviewing agency
                Coast Guard, in addition to the United States Fish & Wildlife                              staff and operators unnecessarily with unproductive respon-
                Service each have important roles to play in regulating the acti-                          sibilities in preparation and analysis of reports, proposals and
                vities which would occur in development. The Report points out                             other documents.
                that, for all intents and purposes, the entire area is classified
                as wetlands.  Wetlands are subject to the jurisdiction of the                                       Akhiok-Kaguyak, Inc. recognizes the strategic importance
                United States Army Corps of Engineers. The operation of the                                of finding significant oil reserves within the United States.       By
                Section 404 program of the Corps, byitself, involving direct                               the year 2000, when any production from the 1002 area might be
                participation by federal, state, and local agencies, will do much                          just beginning, the United States will be at least 50-60% depen-
                to minimize surface impacts directly and indirectly related to                             dent upon the import of foreign oil for its domestic use.      The
                the placement of gravel fill in the area. The Environmental                                present glut of oil in the international marketplace, with con-
                Protection Agency's authority under Section 402 of the Clean                               current low prices, should not be assumed to be a bellwether for
                                                                                                           the condition of the market 13 years hence. If large scale
                                                                                                           reserves are found in the 1002 area, this country simply must
                                                                                                           find ways to both develop it and minimize environmental harm
                                                                                                           while doing so. The alternatives are not pleasant to imagine.

             U.S. Fish & Wildlife Service
             February 6, 1987
             Page 3

             It is important to consider that if gross domestic shortages
             occur in the next ten years and petroleum prices have
             skyrocketed, the pressures for development of a highly perspec-
             tive geologic area might become so intense as to overshadow the
             attention which can now be given to avoiding or minimizing
             environmental harm.

                      Akhiok-Kaguyak, Inc. supports the recommendation of the
             Secretary of Interior and requests that the above considerations
             be addressed in the final.report to be prepared by the Depart-
             ment.

                                          sincerely yours,

                                          GRUENING1,B   HT, EVA   & SPITZFADEN
                                          By: Patr ickl/uM16-
             PR:afg

             cc: Ralph Eluska, Manager, Akhiok-Kaguyak, Inc.

                  Alaska Center too llu-
                  Suite IA
                  411 West 4th Ave.
                  Anchoraqe. Alaska 99501  :!74 If.                                                        ACE comments on Draft 1002 rpt--Arctic Coastal Plain (cont.)           p. 2

            January 15. 1987                                                                                      An issue that development interests have carefully side-
                                                                                                            stepped. however, is the impact of oil and gas exploration
                                                                                                            (alone. or with subsequent development) on the irreplaceable
                                                                                                            wilderness values or the Coastal Plain. We have not seen anyone
            U.S. Fish and Wildlife Service                                                                  from the development community willing to refute the assertion
            Division of Refuge Management                                                                   that leasing the Coastal Plain will destr6y the wilderness values
            2343 Main Interior Building                                                                     of the area. And to both Alaskan conservationists and millions
            18 and C Streets MW                                                                             of Americans in the lower 48. wilderness protection and wildlife
            Washington. D.C. 20240                                                                          conservation are co-equal goals in the drive to preserve the
                                                                                                            Coastal Plain for future generations.
                                        RE: Draft 1002 Report for the Arctic
                                             Coastal Plain                                                        The Arctic National Wildlife Range was established in 1960
                                                                                                            in large part because of its wilderness values. unlike most
            Dear Sirs/Madams:                                                                               national wildlife refuges where the primary goal is wildlife
                                                                                                            conservation. This is our last opportunity to preserve an arctic
                  The followinix comments or the Alaska Center for the Environ-                             area that includes a full spectrum of ecosystems in their natural
            ment are intended to supplement, amplify and/or reiterate the                                   states. largely unaltered by man. and until now almost completely
            oral testimony we provided at the January 5, 1987 hearing in                                    frea from the destructive impacts or our most modern technol-
            Anchorage on the Draft 1002 Report for the Coastal Plain of the                                 ogies.   Wilderness designation for the entire Arctic National
            Arctic National Wildlife Refuge.      Although the Center has a long                            Wildlife Refuge is also the last great spiritual gift of,its kind
            history of involvement in Alaska Lands Act questions, including                                 that we can leave to our descendants.        It would be a reaffirms-
            the Arctic Refuge. in recent years we have generally deferred to                                tion or our hope and belier that wevan learn from past mistakes,
            the several Alaskan conservation organizations whose primary                                    and that we are motivated by forces greater than greed.
            concern is federal lands so that we can focus on important haz-
            ardous waste, state land use. and local wetlands preservaLion                                         It is not as ir we need the Coastal Plain. where our chances
            issues which might otherwise be largely ignored.        The fact that                           of finding economically recoverable quantities or oil, even under
            the Center is nevertheless participating actively in the debate                                 the most optimistic--or unrealistic--assumptions, are less than
            over the rate of the Coastal Plain is a strong indication or the                                205.   Nowhere else has the Alaskan coastal plain been protected.
            tremendous interest in this issue on the part of the entire                                     Millions of acres of both onshore and offshore prospects are
            Alaskan conservation community, including our members.                                          available or potentially available for oil exploration and devel-
                                                                                                            opment. In fact, the present administration has already flooded
                  The exceptionally rich biological resources of the coastal                                the nation with oil lease sales and driven the economic return to
            Plain are or regional, statewide. national and international                                    the nation to levels that are approximately hair or what the
            a i g n i r i c a n c a. In a refuge blessed with biological treasures, the                     previous administration received for the public's resources.
            Coastal Plain is the reruge's most productive area. Lists of
            those valuable resources have been enumerated probably hundreds                                       But more importantly perhaps. any reasonable national energy
            of times.                                                                                       plan--should the federal government prepare one--could easily
                                                                                                            find ways or comfortably doing without any oil that might be
                  Contrary to what the oil industry so conclusively'states,                                 found under the AMUR Coastal Plain.       At the present time. how-
            Prudhoe Bay has not demonstrated that oil exploraLion and devel-                                ever, the federal government has virtually no credibility in
            CiPment are compa@ible with the conservation purposes of' the                                   regard to energy planning after the president's recent veto of
            Arctic Refuge.   Only minimal monitoring or the impact of those                                 national appliance energy standards. which if' enacted         would have
            activities has occurred.    We are just beginning to learn of                                   saved millions of barrels of oil, and its general policy of
            Possibly substantial air, water and toxics Pollution at Prudhoe.                                virtually ignoring even proven energy conservation measurers.
            The U.S. F.W.S. is only in  the process of, attempting to assess the                            The destruction of the nation's last great wilderness in these
            impacts of oil and gas activities on wetlands and waterf-owl.        In                         circumstances is unthinkable.
            Spite of the ract that some bull caribou do not avoid Cho oil
            pipeline, we are not aware of any scientific reports by disinter                                      Nor have several technical or logistical questions been
            sated observers that conclude that impacts of' Prudhoe Bay activ                                adequately addressed.     The 1002 Report admits that we do not know
            ities on caribou, especially on calving, are insi(inificarit..      I r.                        where we will find the enormous amounts or water and gravel
            any case, for the reasons that we will give beluw. we (to riot,                                 necessary for this project.      Similarly. oil and gas exploration
            bel i eve t hat there 1 s a need for any oi I I. hat aii qht: I i c ulider f. he
            Coastal Plain sufficient to justify the impacts it, wildlife that
            the draft 1002 Report Says are likely to occur..

           ACE comments on Draft 1002 rpt--Arctic Coastal Plain (cont.)    p. 3

            and development would create a host or potentially very substan-
            tial hazardous waste and pollution problems which we are only
            beginning to recognize, identify and attempt to deal with. To
            date we have not shown that we can deal with them adequately.

                  We recommend that the Interior Department recommend to
            Congress that Alternative E, which is wilderness designation for
            the entire Coastal Plain, be adopted. We recommend also that the
            secret negotiations which could lead to substantial public losses
            on the Coastal Plain. and which are seriously compromising this
            reporting process and could preclude Congress' ability to choose
            from a full range of options for the area, be suspended immedi-
            ately.

                  We are very happy to be able to provide comments to the
            Interior Department on this exceptionally important issue. We
            are deeply disturbed, however, that the department is grudgingly
            complying with the law and allowing public participation only
            after they were forced to by public interest groups who had to
            expend considerable amounts or time and money to secure this
            right. We are saddened by and ashamed of the Interior
            Department's actions in this regard.

                                                     Sincerely,

                                                     Cliff Eames
                                                     Issues Director
            CE:d9h

                                                                                                           Director
                                                                                                           U.S. Fish & Wildlife Service
                                                                                                           February 4, 1987
               Alaska Coalition for American Energy Security                                               Page 2

                  P.O. Box 10-1515 Anchorage. Alaska 99510-1515 (907)561-8641

                                                                                                                The positive    trends   of  1981-1985   towards  reduced U.S.
                                                                                                                dependency on imported oil, particularly from the Middle
                                                                                                                East, are being reversed.       Imports from the Middle East
               February 4, 1987                                                                                 more than doubled during the    first.seven months of 1986.

                                                                                                                The recent drop in oil prices has resulted in significant
                                                                                                                reductions in U.S. exploration, production, and drilling
               Director                                                                                         activity; these reductions cannot be quickly reversed.
               U.S. Fish & Wildlife Service
               Division of Refuges                                                                              Lower oil . prices are enco  .uraging growth in energy demand
               2343 Main Interior Building                                                                      while reducing U.S. oil and gas production.
               18th & C Streets, N.W.
               Washington, D.C.    20240                                                                   Finally, the Secretary concluded that, "Until oil prices in-
                                                                                                           crease appreciably, U.S. exploration will remain stagnant, our
               Gentlemen:                                                                                  dependence on imports will continue to increase, and our vulner-
                                                                                                           ability to oil price shocks and possible oil shortages or
               The Alaska  Coalition for American Energy Security is an umbrella                           stoppages will rise to an excessively dangerous level.         All of
               organization formed for the single purpose to encourage the                                 this could seriously affect our strategic and national security
               opening the Coastal Plain of the Arctic National Wildlife Refuge                            as well as our economic stability.* With the long lead time
               (ANWR) to oil and gas exploration, development and production.                              required to bring an Arctic oil field from discovery to full
               Coalition members include the Alaska Oil and Gas Association,                               production, typically 10 to 15 years, this study only reinforces
               Alaska State Chamber of Commerce,         Alaska Support      Industry                      the need to begin exploration activity in the Coastal Plain now.
       9       Alliance, Anchorage Chamber of Commerce, Arctic Slope Regional
               Cornoration. Assnriat-pil rpnprai rnnt-rArknrn, rnmmnn eanca F^r
                                                       --------                                            From a national security perspective the joint Chiefs of Staff
       (Yl     Alaska and Resource Development Council for Alaska.       The Alaska                        and the National Security Agency has long pointed out that the
               Coalition   appreciates   this   opportunity   to   provide written                         most important corner stone of our nation's security is a stable
               comments on the Draft Coastal Plain Resource Assessment.                                    and vital economy.      Without considering the implications of
                                                                                                           energy shortages to our defense forces, which were dramatically
               The Alaska  Coalition strongly supports the report's recommended                            illustrated in 1973   (the OPEC embargo), the exogenous shocks to
               Alternative A, full leasing of the Coastal Plain of ANWR.        There                      our domestic economy will clearly be devastating.
               are many compelling reasons why the Secretary of Interior must
               make that recommendation to the Congress of the United States.                              It is essential that Congress and the President move quickly to
                                                                                                           encourage domestic exploration and production of our energy
               NATIONAL INTEREST NEED                                                                      reserves.   As the Secretary of Energy has pointed out, the down
                                                                                                           turn in domestic production as a result of depressed prices is
               Exploration for and, hopefully, development of petroleum      on the                        not easily turned around.
               Coastal Plain of ANWR is clearly in the national interest                                   As U.S. production continues to decline at an accelerating rate,
               because of the dramatic and sustained drop in oil prices and the                            our ability to supply our own energy needs will be increasingly
               cumulative effect that it has had on domestic production, along                             impaired and our national dependence on imported oil will
               with a steady rise in domestic consumption of oil and gas                                   increase.   Higher prices at best, and shortages at worst will be
               products.   The United States is moving toward an ever increasing                           the inevitable outcome without the discovery and development of
               dependence on energy imports.        The present oil surplus is
               predicted to evaporate in three to five years.      Given the start                         additional domestic reserves.
               up or recovery time required to rebuild needed domestic pro-                                The single most Important decision our Congress will make in the
               duction,   it is imperative that the industry be allowed to                                 arear of domestic production and national energy security in the
               explore on highly prospective areas such as the Coastal Plain                               next eighteen months Is the opening of tho coastal plain of the
               without delay.                                                                              Arctic National Wildlife Refuge to leasing for energy explora-
               In a recent study requested by the Secretary of Energy on the                               tion and production.    This relatively small area at the north-
                                                                                                           oastern corner of Alaska holds the highest promise for signifi-
               future supply and demand for oil and gas, it was found that:                                cant domestic energy discoveries.        Even with an affirmative

               Director                                                                                     Director
               U.S. Fish & Wildlife Service                                                                 U.S. Fish & Wildlife Service
               February 4, 1987                                                                             February 4, 1981
               Page 3                                                                                       Page 4

               decision to open this critical energy reserve it will take ten                               The report estimates the chance for a commercially developable
               to fifteen years before a consumer product is available.         Alaska                      field at approximately 19 percent.         A 19 percent chance of
               has proven its capability in developing vital natural resources                              commercial success indicates a considerable improvement over the
               while being sensitive to fish, wildlife and habitat.                                         historical chance of success in Alaska petroleum exploration
               Currently, Alaskan oil and gas production represents about 20%                               which is typically a 2 percent chance of commercial success.
               of our total domestic production.       That production will be in                           A reserve potential of this magnitude cannot and must not be
               decline soon and will dramatically fall over the next ten years..                            ignored, and the Secretary is correct in recommending that the
               Without new discoveries and a dramatic change in domestic                                    entire Coastal Plain be opened for leasing.
               consumption there is little hope that we can avoid serious,
               national economic shocks.      The nation is more dependent, than                            It is estimated that the oil potential of the Coastal Plain
               ever, on oil products and it cannot afford to ignore areas rich                              could be as high as that of the Prudhoe Bay fields.        Prudhoe Bay
               with potential oil resources.                                                                and adjacent fields are presently providing approximately            20
                                                                                                            percent of the United State's domestic oil production.                 A
                                                                                                            conservative estimate of the oil that will have been supplied        by
               ECONOMICS                                                                                    the known North Slope fields upon their exhaustion is roughly        13
                                                                                                            billion barrels.      This represents hundreds of billions           of
               By allowing for exploration, development and production on the                               dollars for the cost of oil that would otherwise have been
               Coastal Plain,    the United States would receive a valuable                                 imported from foreign producers if those fields were not pro-
               resource which it would otherwise import from foreign producers                              duced.   Without this development, the U.S. economy would have
               at a tremendous cost to our national economy.      The trade deficit                         been even more vulnerable to the inflationary effects that were
               for 1116 alone was $170 billion.        It is estimated that about                           generated by the high oil prices from foreign suppliers.          North
               half of that imbalance is the direct result of foreign oil                                   Slope fields have helped strengthen the U.S. economy and have
               imports.    It  is interesting to note that Congress appears                                 contributed billions of dollars to the U.S. Treasury.         ANWR has
               willing to take extraordinary measures to protect U.S. manu-                                 the potential of being an equal contributor to the U.S. economy.
               facturers   from foreign trade competition, and yet the major
               problem is in the area of oil imports.          The trade imbalance
               translates directly into lost jobs for U.S. workers.          Assuming                       ENVIRONMENTAL CONSIDERATION
               an average value of oil of $35 per barrel, the 3.2 billion
               barrels of oil which is estimated to be the most probable                                    While the overall area of the Arctic National Wildlife Refuge is
               recoverable potential from the Coastal Plain, represents more                                quite large, that portion proposed for exploration and develop-
               than $100 billion in lost revenue to foreign producers.             Not                      ment represents only eight percent of the entire area.             The
               only would the loss of ANWR have an impact on U.S. workers, but                              actual surface impact to the resources of the Pefuge in this
               it would.impact the revenue deficit as well.       More oil develop-                         small area would be minimal.        The report's analysis and dis-
               ment by the domestic oil industry, means a greater return to the                             cussion of environmental impacts and effects on wildlife result-
               U.S.   treasury  from bonus payments,      rentals,   royalties,    and                      ing from exploration and production do not adequately reflect
               taxes. This will help reduce the federal deficit.                                            the experience of exploration and ongoing production in areas of
                                                                                                            the Coastal Plain adjacent to ANWR.        We see this as the most
                                                                                                            serious deficiency of the report, which may draw unwarranted
               RESOURCE POTENTIAL                                                                           opposition to the Department's proposal of full leasing.
               As recognized in the draft      report, the petroleum potential of                           The   'worst  case"   speculation   of   potential   impacts   on  the
               the Coastal Plain is the most outstanding oil and gas frontier                               Porcupine caribou Herd ignores much of what industry and the
               remaining in the United States.      However, the reserve estimates                          regulatory agencies have learned to date about the interaction
               for the 1002 area may be understated .         The report indicates                          between arctic oil development and caribou.        The report should
               that   only structural.   traps were considered      in  the    reserve                      take an approach which looks at impacts that are "most likely to
               estimate, yet many of the plays expected to contain hydrocarbons                             occur," based on North Slope experience. Such an approach would
               are stratigraphic in nature.      Were the potential stratigraphic                           significantly alter     the  results of     the analysis and yield
               traps considered, the reserve estimate for the Coastal Plain                                 realistic    conclusions    of   negligible    impacts    to    caribou
               would be even higher than what is quoted in the report.                                      populations.

                Director                                                                                    Director
                U.S. Fish & Wildlife Service                                                                U.S. Fish & Wildlife Service
                February 4, 1987                                                                            February 4, 1987
                Page 5                                                                                      Page 6

                The over-emphasis of the importance of a so-called -core calving                            caribou and other subsistence resources from impact at Prudhoe
                area" in the 1002 area leads the report to dismiss past ex-                                 Bay and Kuparuk is a further reason why subsistence resources
                perience and studies which show that caribou populations thrive                             will not be impacted in this area.
                in the midst of oil field activity on the North Slope.         Histor-
                ical data on the Porcupine Herd presented in the report clearly                             Third, the subsistence lifestyle requires access to cash, for
                show that the coastal plain from the Babbage River in Canada                                purposes of obtaining three-wheelers, guns, ammunition, and
                across the 1002 area to the Canning River has been successfully                             related supplies.    The villagers in the local area will be able
                used for caribou calving.     The Porcupine Herd has been observed                          to utilize job opportunities offered by oil development to
                in some years not to use the so-called core area at all.            In                      enhance their subsistence activities.
                some years, the herd has been observed to calve entirely outside
                the 1002 area.   Thus, rather than a specific core area, calving                            Fourth, natives in the area, who are well experienced with the
                habitat is a continuum across.the Arctic coast from the Canning                             interactions between oil and gas development and subsistence,
                River to the Babbage River in Canada.         Recognizing the wide                          favor oil and gas development in ANWR.        In fact, Jacob Adams,
                year-to-year variation in calving distributions,         it becomes                         President of the Arctic Slope Regional Corporation, himself a
                increasingly clear that activities such as oil exploration and                              whaling captain, has stated as follows:
                production   which use only small portions of abundant habitat
                will not affect the calving success of caribou in ANWR.       Caribou                                We are convinced that experience gained by the
                continue to use the area in and around the Kuparuk River oil-                                     exploration and development of energy sources within
                field for calving and that herd continues to increase at rates                                    the last 20 years will lead to the development of new
                similar to other North Slope herds.          The Department should                                energy production facilities that can be operated very
                re-evaluate the core calving area concept and de-emphasize the                                    compatibly with the caribou and other living resources
                importance it plays in the conclusions in the report related to                                   of the Coastal Plain.     we know that it wi    11 require
                potential impacts from petroleum development.                                                     careful requlation and will increase Project costs,
                                                                                                                  but we believe a productive balance can be achieved."
                SUBSISTENCE                                                                                       "Our own local governments and companies have brought
                                                                                                                  @heir experience and knowledge to bear on the energy
                Preservation of the subsistence resource is one 'of the most                                      development   process,    resulting   in   sensitive     and
                difficult and.important issues relating to opening ANWR to oil                                    effective decisions.     The lands we own within ANWR
                and gas development.    In evaluating this issue, it is important                                 were cooperatively placed under a regulatory scheme
                to keep in mind the following points:                                                             and set of stipulations that has demonstrated the
                                                                                                                  compatibility    of    living   resources     and    energy
                First, the oil and gas industry has a strong commitment to                                        development.'
                preserving subsistence resources, and an excellent track record
                in having done so.    The oil and gas industry has worked on the                                  'As a people reliant on our land its resources, we are
                North Slope and in western Alaska in close contact with Native                                    sensitive to the long-term significance that develop-
                communities and regulatory agencies seeking to preserve the                                       ment of the ANWR Coastal Plain may represent.            We
                subsistence resources which otherwise might be affected by oil                                    think that sound environmental studies and mitigation
                and gas exploration and development.      As a result, no signifi-                                measures have been and will be successful in limiting
                cant impact upon any subsistence resource has ever been substan-                                  the adverse effects of development.          We are also
                tiated as a result of oil exploration and development in Alaska                                   confident that the existing and improving technologies
                -- and it is our strong belief that this excellent track record                                   can ensure the integrity of the environment during oil
                will continue in ANWR.     The industry is strongly committed to                                  and gas operations.'
                this concern and will closely cooperate with Native subsistence
                users.

                                                                                                            WATER AND GRAVEL RESOURCES
                Second,  it is also important to take note that subsistence
                impacts can only occur if there are significant impacts upon the                            The 1002(h) report indicates that water and gravel resources
                wildlife  resources   of    the area.     The  primary    subsistence                       could be problematic      with respect to their availability to
                resource in this area is the Porcupine Caribou Herd, along with.                            support petroleum exploration and development in the Coastal
                waterfowl.   The    industry's   excellent  record   in    protecting

                Director                                                                                   Director
                U.S. Fish & wildlife Service                                                               U.S. Fish & Wildlife Service
                February 4, 1987                                                                           February 4, 1987
                Page 7                                                                                     Page 8

                Plain.  The Alaska Coalition offers the following comments and                             drilling thousands of shot-holes to depths of 75' the 1984 and
                observations.                                                                              1985 seismic programs.

                Water                                                                                      in fact, not only do abundant sources of gravel seem to be
                                                                                                           available in the 1002 area along the major stream valleys, but
                There are many means to provide water for oil and gas opera-                               pages 99-100 indicate that the taking of gravel from areas such
                tions.  Snow melt by using snow collected by use of snow fences,                           as river bars, river terraces, and cutbanks can be done with
                temporary roads to deep lakes, desalinization can furnish water                            minimal adverse impacts.    Furthermore, water reservoirs would be
                for early exploration.    Water supply wells could and would, be                           created, thus supplementing other water supplies.
                established fairly early if surface supplies are insufficient.
                Water from these wells would be in the form of treated formation                           One last point to be made with respect to both water and gravel
                water from deeper horizons below the permafrost.      These methods                        resources pertains to the ability of the petroleum industry to
                are routinely used in the Prudhoe Bay development area to insure                           overcome technical problems.      The opening of the coastal Plain
                adequate water supplies.                                                                   should not be precluded solely on the basis of the potential
                                                                                                           technical obstacles. Historically, these kinds of problems have
                Although as much as 15 million gallons of water may indeed         be                      been overcome.
                necessary for initial exploratory wells, the bulk of this water
                volume is needed not for the direct drilling of the well, but
                for the associated ice pad, ice road, and/or ice airstrip.                                 LEASING METHODS
                Hence, much of the required water volume will decrease as                                     I
                permanent infrastructure replaces temporary annual ice struc-                              The most basic action contemplated by Congress       with respect to
                tures.                                                                                     ANWR is leasing.     However, a full discussion of the merits of
                                                                                                           this basic action is obscured by the debate about the environ-
                For development and production, water supplies can be supple-                              mental consequences of oil development. There are significant
                mented by artificial water reservoirs at gravel barrow sites.                              aspects with respect to the leasing program which should be
                                                                                                           developed with care.
                Gravel
                                                                                                           The draft Environmental Impact Statement states, with respect to
                The report contains conflicting discussions on the ava1lability                            leasing systems, as follows as page 89, in its discussion of
                of gravel resources within the 1002 area. The Executive Summary                            'Alternative A*:
                (page 6, column 1, paragraph 5) states that "...the water and
                gravel necessary for construction and development are in very                                    Under the alternative of full leasing, it is assumed
                limited supply on the 1002 area.' Further, page 75. (column 2,                                   that Congressional action would allow all Federal
                paragraph 1) states that 'Specific locations and sources of                                      subsurface ownerships of the S 1002 area to be avail-
                water and gravel for exploration and development activities have                                 able for development through a leasing program admin-
                not been identified, and it is understood that these resources,                                  istered by the Department of the Interior.             This
                especially water, are not readily available on the 1002 area.*                                   action would also open to oil and gas development in
                Page 84 (column 1, paragraph 1) states that "the availability of                                 production the private lands within the refuge.         The
                adequate gravel supplies on the 1002 areas is uncertain.                                         exact terms of the leasing program would be developed
                                                                                                                 in response to specific legislation passed by the
                However, the description of the physical environment on      page 20                             Congress.    If   the  Congress   chooses   to    authorize
                (column  2, paragraph 4) states that "The valleys of           larger                            leasing in   the entire S 1002 area, the legislation
                streams are underlain by large quantities of course sand and                                     would probably contain the important elements of the
                gravel.' Figure 11-2 on page 16 indicates abundant surficial                                     Minerals Leasing Act and the NPRA legislations, with
                deposits of sand and gravel.      Although Figure 11-2 indicates                                 special provisions to meet the unique needs of the
                surface  materials only, it is unlikely that these gravel                                        Arctic Refuge.
                deposits are strictly surficial in nature, particularly since
                similar deposits are widespread and abundant across the entire                             It is crucial that no element of the NPRA 14,.qislation be used.
                North Slope Coastal Plain.    Abundant gravel beneath the Coastal                          The NPRA leasing program did not, for instance, contain normal
                Plain was observed and reported by the seismic crews when                                  provisions regarding unitization, for the maintenance of the

              Director                                                                                 Director
              U.S. Fish & Wildlife Service                                                             U.S. Fish & Wildlife Service
              February 4, 1987                                                                         February 4, 1987
              Page 9                                                                                   Page 10

                                                                                                       We are confident that the oil industry can operate in an envi-
                                                                                                       ronmentally safe manner and we urge the Secretary to recommend
              lease and the extention of the primary period by shut-in produc-                         to the Congress that the 1002 study area be opened to leasing,
              tion, etc.                                                                               development and production.

              The Secretary should recommend to Congress that it adopt, with                                                                Sincerely,
              respect to ANWR, the ANILCA SS 1008 (16 U.S.C. 53148) and 1009
              (16 U.S.C. S 3149) onshore leasing program.       The SS 1008 and
              1009 program is the competitive onshore leasing program uti-
              lizing the statutory authority and well developed procedures of
              the Mineral Leasing Act, as applied by ANILCA to the unique                                                                  BOYD BROW  FIELD, C@Lrman
              circumstances in Alaska. The important features of this program                                                              Alaska Co  lition for American
              include procedures to provide significant environmental pro-                                                                   Energy S curity
              tection, and are intended to apply to game refuges in Alaska.
                                                                                                       BB:.tp:NS4:467
              The procedures provided in S 1008 are similar to those contained
              in the Outer Continental Shelf Leasing Act (OCSLA, 43 U.S.C. S
              1401 et seq. ) including the preparation, pursuant to 5 1008(f)
              of an exploration plan, and, pursuant to S 1008(g) preparation
              of a development and production plan. The Secretary retains the
              authority to monitor and modify the terms of such plans pursuant
              to 5 1008(h), and if the Secretary determines that *immediate
              and irreparable damage will result from a continuation enforce
              of a lea--e,' then the lease may be suspended -
              pursuant to S 1008(1). @                             or cancelled

              Congress need not attempt to *reinvent the wheel." The-prepara-
              tion of an environmentally sensitive leasing ptogram which
              applies to game refuges in Alaska has   already been accomplished
              by Congress and all Congress need do is to implement it.         In
              other words, the simplest action for    Congress to take in this
              instance would simply be to revoke      SS 1002(1) (16 U.S.C. S
              3142(i)) and 1003 (16 U.S.C. S 3143),   and the 55 1008 and 1009
              program will automatically apply                     %

              INDUSTRY TRACK RECORD

              The petroleum industry has a long and   well demonstrated history
              on the North Slope of working closely in consonance with the
              physical and biological environment.      A tremendous amount of
              funding and effort has gone into studying the environment and
              seeking ways.to minimize adverse impacts.    The lack af signifi-
              cant impact serves as a testimony to the ability of industry to
              operate in an environmentally safe and sound manner. Meanwhile,
              Arctic technology continues to be developed,        assuring that
              future projects and developments are "state of the art.*
                                                                                                                                                     I@IF
                                                                                                                                                      1
                                                                                                                                                     S

             Alaska Friends of the Earth
             Box 3847         Anchorage, AK 99510                                                                         k=rding to the 1002 RaLport, oil development in the Arctic Refuge would
                                                                                                                     include the construction of ports,@        pipelines, and airfields as well
                                                                                                                     as thousands of people moving in. Elevated pipelines would Zza; caribou
                                                                                                                     access to coa tal insect relief areas. All of this development and the
                                     Testimony on the Draft                                                          associated air and road traffic would add unacceptable stresses and
                           Arctic National Wildlife Refuge, Alaska                                                   to the Pm-cupine caribou herd.
                              Coastal Plain Resource Assessment                                                           in village meetings in Alaska and Canada in the spring of 1978 e  Iders
                                 - - - - - - - - - - - - -- - -                                                      agreed that development of oil. within the coastal plain of the Arctic Refuge
                                     Kaktovik Public Hearing                                                         would be very harmful to the continued hmalth of the Porcupine caribou hard,
                                          January 6. 1987                                                            and thus bring herd times to those people who haw lived in close relation to
                                                                                                                     the caribou for tam of thousands of years.
                                                                                                                          Unlike Prudhoe Bay, water is scarce in the 1002 area. Here the coastal
                                                                                                                     plain is narrow and sloped, not flat with lakes like Prudhoe. A lot of
                My nano is Mike Holloway and I represent Alaska Friends of the Earth.                                disturbance of the ground and river beds would be done to provide enough water
            Friends of the Earth is a international citizen-based environmental grCYuP- We                           and gravel for oil field development. Ckil activities will certainly have an
            believe continuation of traditional subsistence cultures is as vital to the
            diversity and richness of the earth as is the protection of plants and animals.                          inpact on -ter quality, espec:ially considering the         problems of
      9     W believe oil exploration and development of the coastal plain of the Arctic                             unavoidable oil spills and the staring of toxic drilling muds in reserve pits.
       a                                                                                                                  of course, there Are efforts to develop oil offshore of this area also.
            Refuge is a threat not only to international wildlife resources, but also to                             Mter traffic and activity from all this development would effect marine
            the subsistence way of life.
                Every spring for thousands of years caribou have collected at the foot of                            memmals, especially noise-sensitive bow!xW whales.
            the Richardson @buntains and traveled north to the coastal plain of Canada and                                njere are also the noted effects of loss of polar bea dam    ing, musk
            Alaska to give birth to their young. The 1002 Report does not show the entire                            ox habitat, and restrictions on subsistence hunting with the 1002 area.
            calving grounds of the Porcupine caribou herd, which includes the whole 1002                             Page 129 of the report reads as follows: "Most important will be the likely
                                                                                                                     der-line or change in distribution of the PCH and the CAH and the harvest
                  However, the select portion of the calving@ areas shown in the report                              prohibitions ne-ir developed areas. These effects, in coMbinatJon with adverse
            ent*asizes U-ie high use of the aim betv;een the 1hilahula and Aichilik rivers,                          effects an other subsistence use species, disruption of traditional use sites,
            in direct conflict with proposed oil actvities.                                                          and likely psychological effects on a people accustomed to isolation, will
                After the long migration, giving birth, and nursing a calf, caribou cows                             result in a major adverse effect on subsistence uses within the 1002 area.
            are at their weakest. At a tine when they can poorly tolerate more stress,                               03rpetition for resources and the potential for increasing restrictive hunting
            mosquitoes hatch out to agitate and drive herds of animals into a frenzy. When                           regulations may add to the severity of impacts an subsistence uses."
            the insects are at their worst, caribou are almost continually on the mow.                                    The 1002 report and the oil industry would have us all belieWthat We
            They are easily stampeded. Insect season contributes to the high death rate                              need to get the oil and gas out of do coastal plain as soon as Possible,
            for calves. Access to forage and insect relief habitat is crucial at this time.                          that pumping this area dry of oil and gas reserves is in the beat interests of
            Any oil exploration and development activities would likely add to already high                          national economy and security. But at current rates of U.S. use, there Would
            levels of stress and likely increase calf mortality. This could have a drastic
            effect on the continued health of the Porcupine caribou herd and should                                  only be enough oil for several months. Energy conservation efforts could
            therefore be opposed by any agency concerned about the protection of wildlife.

              Kaktovik Testimony
              Page 3

              easily save this anowt.
                  7he Arctic National wildlife Refuge was established in 1960 tD, in part,
              -conserve fish and wildlife populatiom and habitats in their natural diversity,
              to provide for continued subsistence uses by local residents and to ensure, to
              the maximum extent practicable, water quality and necessary water quantity
              within the refuge.- In 1978 and 1980 the U.S. House of Representatives voted
              twice to make the coastal plain of the Arctic Refuge Wilderness, but the
              Senate ruxessitated this 1002 study and report.
                   The coastal plain is do most biologically productive part of the Arctic
              National Wildlife Refuge. it is the center of the cycle of life for caribou,
              birds, fish, and other animals. It oust not be disturbed for the possibility
              of a few months oil supply.
                   Ib develop this area now for short term gain will destroy forever the
              wilderness characteristics of one of the most important biological areas in the
              entire Arctic. This is the only area of our Arctic slope now protecte d. Let
        tl    it r-min protected. we recommend the 1002 area be put into Wilderness with
              continued subsistence 1- as protected in the Alaska National interest Lands

              Oonservation Act.

                   7hank

                                                                                                          Director
                                     Alaska Oil and Gas Association                                       U.S. Fish & Wildlife Service
                                                                                                          February 4,*1987
                                                                                                          Page 2

                                     121 W. Firewood Lane, Suite 207
                                     Anchorage, Alaska 99503-2035
                                     (907) 272-1481                                                       significant new discoveriese out      nation could be dependent upon
                                                                                                          foreign sources for 60-75% of         its demand, almost double the
                                                                                                          present level of dependency, within the next 10-15 years. Because
             February 4, 1987                                                                             it takes 10-15 years to explore, develop, and bring Arctic oil and
                                                                                                          gas resources into production, the opening of the ANWR 1002 area
                                                                                                          for development is now of timely and critical importance.
             Director                                                                                     All the geologic factors favorable for significant oil and gas
             U.S. Fish and Wildlife Service                                                               discoveries exist in the 1002 area, including source rocks th           at
             Division of Refuges                                                                          generate oil and gas, thick sequences of reservoir rocks, large
             United States Department of interior                                                         structures to trap petroleum and a favorable geologic history.
             Room 2343, Main Interior Building                                                            The 1002 area is one of the most promising areas for major dis-
             18th and C Streets                                                                           coveries of oil and gas of all untested onshore areas of the
             Washington, D.C. 20240                                                                       United States.
                                                   Arctic      National       Wildlife                    Exploration, development, and production can proceed on the
                                                      F_                                                  coastal plain with minimal environmental effects through reason-
                                                   Re uge,   Alaska Coastal Plain
                                                   Resource  Assessment                                   ably applied mitigation measures.         Clearly, the 18 years of
                                                                                                          exploration and development of Prudhoe Bay and other North Slope
             Dear Sir:                                                                                    oilfields and construction of the Trans-Alaska Pipeline System
                                                                                                          (TAPS) has shown that proven and current industry practices can
             The Alaska Oil and Gas Association (AOGA)       is a trade association                       ensure that development can proceed in. a manner compatible with
             whose member companies account for the majority of oil and gas                               wildlife resources and ensure that no unnecessary adverse environ-
             exploration, production and transportation activities in Alaska.
                                                                                                          mental impacts occur.
             AOGA appreciates this opportunity to comment on the draft Coastal
             Plain Resource Assessment.                                                                   AOGA strongly endorses Alternative A, full leasing of the '1002"
                                                                                                          study area, as the most acceptable alternative consistent with the
             AOGA commends the Department of Interior on the overall complete-                            national interest.    Alternative R, partial leasing, is based on a
             ness and adequacy of the report in the assessment of the resources                           speculative premise that a traditional core calving area exists
             of the A14WR Coastal Plain.    AOGA strongly supports the Department                         and is necessary for the maintenance of a healthy caribou herd.
             of the Interior's proposed recommendation that the entire '10021                             This has not been demonstrated in the scientific literature and
             study area be authorized for oil and gas exploration, development                            there is a large body of dAta which indicates otherwise.         Alterna-
             and production.                                                                              tive C makes no positive contribution.           Surface and regional
                                                                                                          geologic information already confirm that the area has oil poten-
             As demonstrated since     1973, the United States is vulnerable to                           tial.   The amount can only be verified by on-structure drilling.
             serious supply disruptions and price escalation because of its                               Stratigraphic type drilling is an unnecessary duplication and its
             dependence on foreign sources of oil.      The Free World's sources of                       surface impact would be in addition to that eventually required
             petroleum are heavily concentrated in the Middle East where                                  for on-structure wells.     Also, Alternative C will only delay any
             two-thirds of the proven reserves are located.       Saudi Arabia alone                      eventual production from the area.        Neither Alternative$ D, no
             possesses one-fourth of the world's reserves.         increased future                       action, nor E, wilderness designation, would determine whether or
             dependency on politically unstable Middle East nations is highly                             not,:ubstantial petroleum reserves exist in the "1002" study area.
             undesirable from a national interest standpoint.                                             Alt natives D and E preclude reasoned planning and would deny the
                                                                                                          nation the positive benefits that could come from oil and gas
             Domestic crude oil production from existing fields is forecast to                            production on the coastal plain.
             decline from the 8.9 million barrels per day average of 1985 to
             6.2 million barrels per day by 1991, if oil prices prevail at                                Our more detailed written comments on the draft Coastal Plain
             about $15 per barrel.     Current domestic crude oil production has                          Resource Assessment report are attached for your consideration
             already fallen to about 8.5 million barrels per day as marginal                              (Attachment A).     We have also attached copies of independent
             fields are being abandoned.      Domestic production may decline as                          analyses on the report's biological portions, prepared by R. J.
             low as 4 million barrels per day by the year 2000 unless signifi-                            Jakimchuk (Attachment B), J. Curatolo (Attachment C) and A. T.
             cant new domestic reserves are found and developed.               without                    Bergerud (Attachment D) at the request of AOGA.       Also, attached is

    Director
    U.S. Fish & Wildlife Service
    February 4, 1987
    Page 3

    AOGA's testimony presented at herings held in Anchorage and
    Washington, D.C. (Attachment E). We submit our written comments as
    constructive input and urge the Service to consider them in
    preparing the final report for submittal to the Congress. Thank
    you for this opportunity to comment.

    Sincerely,

    WILLIAM W. HOPKINS
    Executive Director

    WWH:TP:NS4:477

    Attachments (5)

    ATTACHMENT A

    COMMENTS OF THE
    ALASKA OIL AND GAS ASSOCIATION ON THE
    U.S. DEPARTMENT OF INTERIOR (DOI) - 1002(h) REPORT

    EXECUTIVE SUMMARY

    Page 2, paragraph 1;  The point from this paragraph is the bottom
    line conclusion of the entire 1002 study.  We would like to
    re-emphaize our support for this position.  We concur that
    adverse effects resulting from development can be minimized or
    entirely eliminated through proven mitigation measures, lessons
    learned and technology acquired from the Prudhoe Bay development
    and from construction of the Trans-Alaska Pipleline System (TAPS).

    Page 6 paragrah 2:  "The Department did not include gas in its
    recoverable calculations as it was determined that the gas
    resources were unlikely to be economic at any point in the 30-year
    peroid considered."

    Given the quantities of gas estimated to exist in the area, we
    question the statement that the gas resources are unlikely to be
    economic during the next 30 years.

    Page 6, column 2, paragraph 4:  "Oil and gas discovery will lead
    to industrial development..."

    There may indeed be development pressure, but adverse effects can
    be controlled or mitigated.

    Page 6, column 2, paragraph 5:  This paragraph states that
    "changes in wildlife habitat and wilderness environment could
    include displacement and reduction in the size of the Porcupine
    Caribou Herd (PCH).  The amont of reduction and its long-term
    significance for herd viability is highly speculative."  (Emphasis
    added)

    We strongly agree that many of the subsequent environmental
    consequences are overstated and highly speculative.  As currently
    written, many of the conclusions of severe impacts and concerns
    for caribou populations are stated as fact, when in actuality,
    they are speculations not supportable by the experience at Prudhoe
    Bay or elsewhere in the Alaska arctic.

    Thus, we ask that the authors of the report reconsider these
    speculative, "worst-case" statements.  At a minimum we ask that
    the authors emphasize the highly speculative nature of the conclusions
    in the environmental consequences section by including
    appropriate caveats and cautionary statements to avoid further
    proliferation of these consequences as statements of fact.

    NS4:481/AOGA/02-04-87

                               CHAPTER II - Existing Environment and                                       coastal plain will be inconsequential to growth and productivity
                             CHAPTER VI - Environmental Consequences                                       of the herd.

                                                                                                           In the management of wildlife populations, the concept of habitat
              Comment I - Often the NEPA-mandated EIS process is forced to                                 carrying capacity is the key to defining management goals for a
              predict environmental consequences of new developments with little                           herd.   It is an established fact that neither the Central Arctic
              or no previous field experience to guide the predictions.         Clear-                     Herd (CAH) nor the Porcupine herd approach the carrying capacity
              ly, for the ANWR coastal plain, the test case has already been run                           of their ranges.    indeed, Skoog (1968) stated the "It seems likely
              at Prudhoe Bay.    Collectively, the experience of the regulatory                            that the Alaskan caribou population has remained far below range
              agencies and industry is captured in the DEIS on page 2:             "The                    carrying capacity and that the total habitat has never been fully
              evidence generated during the 18 years of exploration and develop-                           occupied.    In reality caribou populations seem to--tCa-ve maintained
              ment  at   Prudhoe   Bay   indicates   minimal   impact   on    wildlife                     densities much lower than the maximum dictated by food alone, and
              resources. Hence, it is reasonable to assume that development can                            hence the reduction in total range becomes less meaningful." Thus,
              proceed on -the coastal      plain   and generate     similar minimal                        we agree with Skoog's conclusion that habitat is not currently
              effects.' Jointly, the industry and regulatory agencies have                                 limiting the growth of the (PCH) and that the loss of habitat
              expended literally millions of dollars and hundreds of man-years                             represented by likely-development in the 1002 area will not impact
              effort to characterize the interaction of fish and wildlife with                             growth or productivity of resident caribou.
              the oil field development     in and around the Prudhoe Bay area.
              Undoubtedly this is one of the most-studied ecosystems in North                              Comment 3 - The 'core calving area" is assumed to be critical to
              America.   This effort has    led to the development of tried and                            (PCH) herd demographics and therefore any displacement from this
              proven mitigation techniques to ensure the compatibility of                                  area would necessarily impact productivity.
              wildlife and oil field interests.
                                                                                                           The report places undue emphasis on a core-calving concept when,
              Furthermore, we support the statement, also on page 2 of the DEIS,                           in fact, the historical data for calving use do not support
              that  "Most adverse effects would be minimized or eliminated                                 fidelity to a 'core calving area.' Historical data for calving
              through carefully applied mitigation, using the lessons learned                              distribution cl3arly show that the coastal plain from the Babbage
              and technology acquired from development at Prudhoe Bay and from                             River in Canada, across the 1002 area to the Canning River has
              construction of the Trans-Alaska Pipeline System (TAPS)."                                    been used for calving.      Thus, calving habitat is more correctly
                                                                                                           referred to as a continuum across the coastal plain rather than a
              Indeed, we would like to point out that all of the environmental                             specific core area.
              activists' unwarranted predictions of 15 years ago, prior to the
              construction of TAPS, have subsequently been proven false.            The                    Chapter II, page 28 correctly points out that wide year-to-year
              demise of major caribou herds, alterations in water quality           and                    variations in calving distribution can occur due to weather
              major losses of habitat simply have not occurred.      Conversely,    the                    influences and the arrival of spring snow-melt.        This acknowledged
              development of Prudhoe Bay and TAPS have allowed Alaskans to enjoy                           effect of weather further erodes the core-calving area concept and
              a period of economic prosperity in harmony with a high quality                               points out the wide annual variability and adaptability of
              environment and thriving wildlife populations.                                               caribou.   During 1983, 1984, and 1985, calving estimates were 74%
                                                                                                           to 35% and 82% respectively in the 1002 area. These data clearly
              Comment 2 - Numerous sections of Chapter II and VI are devoted to                            show the adaptability of the PCH to yearly variations in weather
              discussions of research on the behavior and movements of caribou                             conditions and point out that calving distributions do vary
              in and around oil field development.          The main problem this                          widely.
              discussion and the conclusions drawn is that habitat is not a
              limiting factor for any of the stages of      the caribou life cycle.                        The 'core calving area' for the PCH has been arbitrarily defined
              Therefore, conclusions regarding displacement of maternal cows or                            as an area where high density (       50 caribou sq. mi.) calving has
              bulls carry little if any significance for the continued growth                              occurred for at least 5 of the       last 14 years.    For much of this
              and survival of the herd.    Since habitat is not limiting, loss of                          area, high density calving has occurred in 9           of the 14 years,
              access to small portions of available habitat due to oil field                               which still leads to the obvioui conclusion            that calving has
              development is not biologically significant.                                                 occurred outside the 'core calving area" during        5 to 9 years.     An
              We readily agree that some degree of modified behavior and dis-                              important aspect of the "core calving area" to consider is what
                                                                                                           percentage of the overall calving habitat it           represents.     From
              placement has occurred in response to habitat alterations in the                             Table VI-5, the total "core calving area" is 311,000 acres, while
              Prudhoe field.    However, habitat is not limiting caribou popu-                             total concentrated calving occurs over 2,117,000 acres.              Thus,
              lation growth for any Alaskan herds at the present time.          There-                     -core calving represents 15% of all concentrated calving areas, and
              fore, a degree of habitat loss as a result of development on the                             would represent an even lower percentage if peripheral calving

              NS4:481/AOGA/02-04-87              -2-                                                       NS4:481/AOGA/02-04-87                -3-

               areas were considered.     The conclusion is that the PCH has success-                           by USFWS for its scientific validity in the arctic.            The founda-
               fully calved over a very large area in the past and while the core                               tion of the USFWS Mitigation Policy is the management of habitat
               area is obviously important to the herd, it           is not necessarily                         as a means of managing the productivity of fish and wildlife
               critical.                                                                                        populations. It is inappropriate, however, to use a habitat-based
                                                                                                                system to manage a population when habitat availability has not
               The assumption is made that areas outside the        "core calving area'                         been shown to be a mechanism by which that population is regu-
               have  less important habitat values or higher         exposure to preda-                         lated.    The policy is particularly inappropriate In the arctic
               tors.   If this were so then reduced productivity should be appa-                                where habitat has not been shown to be a limiting factor for most
               rent  from the years that the herd used these alternative areas.                                 species, and is particularly meaningless with respect to caribou.
               This  has not been demonstrated and it is known that the herd has                                The published literature on caribou clearly supports the finding
               grown steadily since the early 701s.                                                             that herd productivity (arid therefore size) is regulated by direct
                                                                                                                mortality due to predation and hunting. Continental caribou herds
               In considering the effects of displacement              from traditional                         have not been shown to be limit         y.habitat availability.
               calving grounds, examples can be drawn from the literature. Davis
               et al., (1983) report that 'in 1982, the Delta Caribou Herd was                                  Since habitat is not a limiting         factor for many of the Arctic
               apparently precluded from calving in its traditional core areas                                  species, it is more biologically meaningful to focus on impact
               because of persistent snow cover and instead used an alternate                                   mitigation.    The most biologically    effective approach to assessing
               calving area roughly within the area burned in 1979, even though                                 and mitigating effects of development on wildlife is first to
               snow conditions were as favorable in unburned areas northeast,                                   determine systematically how project activities and structures
               northwest, and west of the 1979 burn, where some calving occurs in                               will adversely affect a population and then to apply mitigative
               most years.    Calving in 1982 was quite successful, which suggests                              measures that will avoid or minimize the mechanism by which those
               that caribou may have considerable flexibility in their habitat                                  activities and structures disturb the population.
               requirements.' The CAB and Taimyr Herd in Russia also provide
               examples where industrial activity has had no measurable effect on                               The USFWS Mitigation Policy should not be the basis for either
               herd productivity.                                                                               impact analysis or mitigation requirements in the arctic.
               Skoog (1968) and Bergerud et al. (1984) believe that caribou are                                 Comment 5 - The 1002.Report states on page 98 that 'the mitigation
         9     not limited by available habitat . Shank (1979) states that:                                     -po-lf-cy-recommends that legally designated or set-aside areas, such
          &                                                                                                     as National Wildlife Refuges, be given special con-sideratlon as
         U1          'Stating  that animals have no adequate habitat into which                                 either Resource Category I or 2."
                     they can  disperse is tantamount to saying that the populati       'on
                     is being  density controlled.     In fact, northern large mammals                          The designation of USFWS Resource Category I for a portion of the
                     (excepting sheep) are most likely not often resource limited                               caribou calving habitat is inappropriate.        The habitat in question
                     suggesting that at       least some degree of distributional                               is not ,      ue or  1rjepl:cc1;1bje:@  It has not even been establish-
                                                                              demographic                                UnVP            sp
                     alteration could be accommodated without drastic                                           ed that th     CH ha                  ore* calvinq area.     The Porcupine
                     consequences.'                                                                             herd's cWl-ving concentrations vary annually in number and loca-
                                                                                                                tion, in some years falling within the same general area, in other
               Therefore, conclusions     regarding the relative importance of the                              years separated by hundreds of miles.        Calving occurs primarily in
               Jago highlands as a core-calving should be de-emphasized through-                                the uplands along the northern sides of the Sadlerochit, British,
               out the report.                                                                                  and Richardson mountains, a region extending approximately from
                                                                                                                the western boundary of ANWR at the Canning river to the western
               Comment 4 - In assessing the environmental          consequences of pos-                         Mackenzie Bay area in Yukon Territory.           This principal calving
               sible oil and    gas development in the 1002 area, the USFWS has                                 range encompasses an east-west distance of over 200 miles and an
               chosen to apply its USFWS policy (46 Federal Register, p. 7644 -                                 area exceeding 6,500 square miles, larger than Connecticut.                In
               7663, January 23, 1981) (1002 Report, p. 12).            In so choosing,                         1982, for example, the majority Of the Porcupine herd calved east
               USFWS has focused their impact analyses on losses of habitat value                               of the United States - Canada border in Yukon Territory, com-
               and has quantified their impact conclusions in terms of acres                                    pletely outside ANWR.     Also, 1986, the herd calved almost entirely
               lost. -Then, assuming a direct correlation between acres of                                      outside the 1002 area.       in any given spring, there are usually
               habitat available and the population sizes of resident species,                                  several areas where densities of calving caribou cows are higher
               USFWS has translated their projections of acres lost to population                               than elsewhere in the calving range.         These concentrations may be
               reductions.                                                                                      several hundred miles apart, some in Alaska, some in Yukon Terri-
                                                                                                                tory, and may vary greatly in location and number from one year to
               This approach to resource management is justified primarily on the                               the next, - while remaining inside the herd's' principal calving
               basis of the USFWS Mitigation Policy and has never been examined                                 range.   The idea of a "core* calving area consisting of a specific
                                                                                                                tract of land with fixed boundaries, used consistently and pre-
                                                                                                                dictably from year to year, is a misconception.            Calving habitat

               NS4:481/AOGA/02-04-87                -4-                                                         IIS4:481/AOGA/02-04-87                -5-

              is more  appropriately represented as a true continuum across the                                 3.   No consideration is given to the fact that the high
              coastal plain.     Thus,   the 'unique and irreplaceable*         nature                               numbers of the PCH relative to the low numbers indicates
              required for designation as Resource Category I does not pertain.                                      that the predator - prey system is not in a stage of
                                                                                                                     dynamic equilibrium where a small change in one popu-
              Comment  6 - The report confuses behavioral responses with demo-                                       lation leads immediately to a change in the other.
              graphic  responses.   That Is, the report proposes that if a be-
              havioral response is observed or predicted in an individual or                               As an example of the problems with the assumption that PCH numbers
              group, then the species productivity has been or will be nega-                               are now limiting the 4 predators discussed, wolves will be examin-
              tively impacted.                                                                             ed in detail below because wolf-caribou systems have been studied
                                                                                                           more extensively.   The logic behind the argument applies to the
              Shank (1979) discusses this confusion directly.          He defines a                        other predators as well.
              behavioral disturbance "as any behavioral response to human-caused
              stimulus which results in actually or potentially reduced repro-                             Population estimates for the PCH ranged from 100,000-106,000 for
              ductive fitness.    If human action results In an animal acting in a                         most of the 701s, which represents a decline slightly greater than
              manner in which it would not otherwise have acted and if this                                the maximum 40% predicted by the 1002 report.     Yet wolf numbers in
              alteration is thought to cause a reduction In that individual's                              the 1002 area are not estimated to have been significantly lower
              capacity to produce a viable offspring, then behavioral distur-                              than the report's estimate of 5-10 wolves, and in fact may have
              bance has occurred.      The issue is confused by the occasional                             been higher.   'Wolf predation on caribou in the ANWR study area
              unavoidable use of the term 'disturbance' to describe the human-                             during calving and post-calving is probably low." (USFWS 1982) It
              caused stimulus itself.'                                                                     is fairly safe to assume that wolf populations on the 1002 area
                                                                                                           have been held artificially low through rabies and legal and
              Shanks further states 'Behavioral disturbance becomes manifested                             Illegal hunting and that PCH population size is not         a dominant
              in animals In three distinct analyzable modes:        overt behavioral                       factor.
              response, physiological response, and demographic responses.*
                                                                                                           Keith (1981) shows a direct relation between wolf            population
              There is   a consistently blurred distinction In      the 1002 report                        density and ungulate population biomass.         However,  the theory
              regarding  what Is a behavioral response and what     is a demographic                       behind this relation cannot be applied to the 1002 area because:
              response.   The discussion of effects an caribou and muskox are
              excellent examples of this confusion.        In both cases observed                               1.   Wolf densities are quite low relative to the available
              behavioral responses (flight reactions or displacement) are used                                       biomass of the PCH, such that Keith's relation does not
              to estimate areas of affected habitat.     Although habitat Is not a                                   hold.   This suggests other factors control wolf popu-
              limiting factor for either species, these avoidance behaviors are                                      lations In the 1002 area.
              then equated to demographic responses. As Shank (1979) states:
                                                                                                                2.   The PCH are only seasonally available to resident
                   'What is commonly forgotten or Ignored... Is that disruption                                      wolves, and then at a time when wolves are tied to
                   of normal behavior is not necessarily bad in itself.            For                               denning sites to the south of the 1002 area.
                   behavioral disturbance to be of practical concern, it must be
                   demonstrated that it does or does not, have demographic                                      3.   The availability of the PCH occurs in summer, not during
                   consequences.    Failure to provide this link is, without                                         the more critical winter period, when resources are more
                   question, the major failing of current research."                                                 scarce and wolves have fewer prey alternatives.
              Comment 7 - Declines in all major predators are assumed to occur                             For the reasons *discussed above it is not reasonable to assume
              due to the hypothesized decline in caribou population.                                       that declines of 20-40% of the PCH population will have any effect
                                                                                                           on wolf numbers.    Negligible to minor impact on other predator
              The discussions of wolves, brown bears, wolverines         -and golden                       species would also be expected from the hypothetical worse case of
              eagles all predict a "moderate" impact, largely due        to a hypo-                        a 20-40% decline.
              thesized 20-40% decline in the PCH.     This reasoning is flawed for
              several reasons:                                                                             Comment 8 - The standard for judging environmental effects is not
                                                                                                           discussed.  Based on numerous examples documented in the specific
                   1.    No alternative prey species are considered.                                       comments section, it is apparent that the standard used in the
                                                                                                           1002 report is 'worst case'.        NEPA as now amended currently
                   2.    The 6-8 weeks of PCH availability to predators on the                             requires that a 'reasonably foreseeable' standard be used.
                         coastal plain would have to be a critical period for all
                         species where the predators relied almost entirely on                             Although the current 1002 report is a legislative EIS and not one
                         caribou.                                                                          occurring directly as a result of NEPA, most CEO guidelines apply

              NS4:481/AOGA/02-04-87              -6-                                                       NS4:481/AOGA/02-04-87              -7-

              to a LEIS as well.    As stated above, the requirement to prepare a                                                             is
              "worst case analysis* when faced with incomplete or unavailable                                low use for calving represents an hi   storical distribution
              information was rescinded in April, 1986.         Since most of the
              environmental consequences result from worst case analysis, this
              approach requires modification.      The large amount of study and                             rather than a displacement of calving to other areas.
              experience on the North Slope allows for an analysis of 'reason-
              ably foreseeable' effects.
                                         paragraph (also page 104):    We feel that                                     I do not disagree that   cows with neonates are
              Page 23'   o'"WL           0, the PI
              undue mp@a-,@,     pllacetd         ant, Thlaspi arcticum. Although                            sensitive to disturbance.    There  is ample evidence to support
              the plant is known to occur in the 1002 area, its status and
              distributional ecology are not well understood.        Currently, the                          this sensitivity not only for caribou but for other cervids and'
              plant has no status either as threatened or endangered, and yet it
              is-treated as endangered status throughout the report.             More
              information must be developed on the occurrence and distribution                               bovids as well.   This sensitivity appears to be strongly
              of this species before stipulations and set-back requirements can
              be promulgated.                                                                                associated with a behavioral repertoire in response to
                                                                                                             predation. I do not disagree, either, that developments such
              .Page 211, paragraph 1:   'The long-term maximum and minimum popu-
              latio, of th  e PCH and the carryin  g capacity of the PCH are un-                             as roads with traffic and human activity, are disturbing to
              known.'
                                                                                                             cows with calves, or that some types of barriers can physically
              This is a key point not mentioned again in the entire report. We
              agree that the habitat and range carrying capacity for the PCH are                             exclude caribou from their ranges.     I do, however, distinguish
              indeed unknown. However, it is an accepted fact that the PCH and
              most circum-polar caribou herds do not approach the carrying                                   between the-sensory disturbances associated with the Dalton
              capacity of their ranges based on food, calving habitat, insect
              relief or any other habitat basis.                                                             Highway which have been documented, and the notion. of avoidance
        -4    Since habitat is not limiting growth, ample room exists to accom-                              or displacement along the TAPS corridor which implies a
              ,modate development interests in the .1002 area without potential
              for impacts on the size or growth of the PCH.              This is a                           pprmanency that is not justified by the evidence.      I feel that
              fundamental tenet of caribou biology and we would. like this
              relationship to be much more strongly emphasized in the net                                    the pipeline itself is not a source of disturbance - most of it
              conclusions of the 1002 report.
              Page 28, paragraph 3:     "The core calving area is a location to                              is buri.ed in the Sag. River floodplain.    Most of the existing
              which pregnant cows have shown a strong fidelity as traditionally                              disturbance comes from the traffic and hunting along the Dalton
              favored calving habitat. Those concentrated calving areas used in
              at least 5 years during    the 14-year study were identified as the                            Highway.  But even here, except for hunting mortality, I feel
              core calving area.'
              We disagree that use in    5 of 14 years illustrates *strong fide-                             that the disturbances are temporary and are not instrumental in
              lity".   Instead, we believe that a minimum of 1/2 of the histor-                              altering either the behavior or distribution of caribou along
              ical record is necessary to suggest any fidelity at all.
              Page 28, column 2, paragraphs 2 and 3: We are concerned that the                               that corridor in any fundamental or permanent way. In short, I
              report places undue emphasis    on  a core-calving concept when, in                            think that caribou are frequently disturbed by activity within
              fact, the historical data for calving use do not support fidelity
              to a "core calving area." Historical data for calving distribution                             the corridor but they do'not avoid it for this reason.
              clearly show that the coastal plain from the Babbage River in
              Canada, across the 1002 area to the Canning River has been used
              for calving. Thus, calving habitat is more correctly referred to
              as a continuum across the coastal plain rather than a specific
              .core area.

              NS4:481/AOGA/02-04-87              -8-

                                                    19                                                                                           20
                              Evidence suggesting that disturba   nces to date are                              exists between a viable caribou population and development, to
                  temporary and sensory in nature is available from a broader                                   document where development activities Are incompatible, to
                  review of the'g,t,wth, distribution and movements of the Central                              identify the nature of the problem, and to develop means of
                  Arctic herd (previous papers). There is no indication that                                    effective mitigation.

                  there has been any change in distribution, life cycle patterns

                  or the fundamental ecology of caribou resulting from the

                  interaction with existing oil development. On the contrary.

                  the herd has grown in size and has continued to use and occupy

                  habitats in the region in a manner consistent w1th

                  pre-development use. The best evidence for this is where pre-

                  development baseline data exist, such as the Kuparuk and Milne

                  Point developments. There are no overall effects on seasonal

                  distribution, habitat use or numbers which can currently be

                  attributed to petroleum development.     The seasonal cycles of
        00
                  caribou in  the Central Arctic region continue despite the

                  d,evelopment which only recently includes their major pre-

                  development  calving ranges.

                             As development continues and expands, it is important

                  to monitor and document interactions with caribou and to assess

                  their significance. If decisions are taken that any habitat

                  alteration is deleterious and this forms the basis for

                  permitting, it will be difficult to justify management oriented

                  research because of the a priori conclusion that all changes

                  are equally deletrious. The most important requirement for

                  future research, in my view, is to identify where compatibility

                                                 21                                                                                         22
                 LITERATURE CITED                                                                          Child.  K.N.,  1973. The reactions of barren-ground caribou
                                                                                                                 (Rangifer tarandus           to simulated pipeline and pipe-
                 Cameron, R.D. and K.R. Whitten. 1979a. Seasonal movements and                                   Iffie crossTn-g -atrudurMialt Prudhoe Bay, Alaska. Alaska
                      sexual segregation of caribou determined by aerial survey.                                 Coop. Wildl. Res. Unit, Univ. of Alaska, Fairbanks.
                      J. Wildl. Manage. 43t624-633.                                                              45 pp.
                 Ca meron. R.D. and K.R. Whitten 1979b. Distribution and move-                             Curatolo, T.A. 198S. Sexual segregation and haitat use by the
                      ments of caribou in relation to the Kuparuk Development                                    Central Arctic caribou herd during summer. Pp. 193-198 in
                      Area. First Interim Rep., Alaska Dep. Fish & Game,                                         T.C. Meredith and A.M. Martell  ' eds. Caribou Management,
                      Fairbanks. 32 pp.                                                                          Census Techniques, Status in Eastern Canada. Proceedings
                                                                                                                 Second N.. Am. Caribou Workshop, Val Morin. Quebec. 17-20
                                                                                                                 October 1984. McGill Subarctic Research Paper No. 40.
                 Cameron. R.D. and K.R. Whitten. 1960a. Influence of the
                      Trans-Alaska Pipeline corridor on the local distribution                             Gavin, A. 1977. Caribou migrations and patterns, Prudhoe Bay
                      of caribou. Pp. 475-484 in E. Reimers. Z. Gaare and S.                                     Region, Alaska's North Slope, 1969-1977. Prep. for
                      Skjenneberg, eds. ProceeUrngs of the Second International                                  Atlantic Richfield Company. 57 pp.
                      Reindeor/Caribou Symposiu, Rj4ros, Norway. Direktoratet
                      for vilt og ferskvannsfisk. Trondheim. 79.9 pp.                                      Gavin, A. and D.W. Chamberlain. 1979. Caribou migration and
                 Cameron, R.D. and K.R. Whitten. 1980b. Distribution and                                         population patterns in the Prudhoe Bay region of Alaska's
                                                                                                                 North Slope. 1969-1978. Unpubl. Rep. prep. for ARCO
                      movements of.caribou in relation to the Kuparuk Develop-                                   Alaska, Inc. 45 pp.
                      ment Area. Second Interim Rep.. Alaska Dep. Fish        Game_
                      Fairbanks. 35 pp.                                                                    Jakimchuk, R.D., S.H. Ferguson and L.G. Sopuck. In press.
                 Cameron, R.D., K.R. Whit  .ten and W.T.ISmith. 1981. Distri-                                    Differential habitat use and sexual segregation in the
                      bution and movements of caribou in relation to the Kuparuk                                 Central Arctic caribou herd. Accepted by Can. J. Zool.,
                                                                                                                 Sept. 1968.
                      Development Area.. Third Interim Rep.. Alaska Dep. Fish L
                                                                                                           Sopuck, L.G.. and R.D. jakimchuk. 1986.. Caribou monitoring
                                                                                                                 studies in the Central Arctic Region of Alaska, Final
                 Cameron, R.D., K.R. Whitten and N.T. Smith. 1983. Responses                                     Report. Prepared by Renewable Resources Consulting
                      of caribou to petroleum-related development on Alaska's                                    Services Ltd. for Alyeska Pipeline service Company, ARCO
                      Arctic Slope. Alaska Dep. Fish & Game, red. Aid in wildl.                                  Alaska. Inc., Exxon Company, U.S.A., Standard Alaska
                      Restor.. Progr. Rep.. Proj. W-21-2. Job 3.18R. 74 pp.                                      Production Company, and BP Alaska Exploration, Inc.

                 Cameron, R.D., K.R. Whitten and W.T. Smith. 1985. Effects        of                       Smith, W.T. and R.D. Cameron. 1983. Responses of caribou to
                      the Trans-Alaska Pipeline on the distribution and move-                                    industrial development on Alaska's Arctic Slope. Acts
                      ments of caribou. Alaska D4p. Fish & Game, Fed. Aid in                                     Zool. Fennica 175s43-45.
                      Wildl. Restor.. Final Rep.. Proj. W-17-7 through 11.
                      W-21-1 thcough 12. W22-1-4. Job. 3.18R. 24 pp.                                       Smith, W.T., R.D. Cameron and K.R. Whitten. 1984. Distri-
                 Cameron. R.D., K.R. Whitten. W   T. Smith and D.D. Roby. 1979.                                  bution and movements of caribou in relation to the Kuparuk
                      Caribou distribution and group composition associated with                                 Development Area. Alaska Dep. Fish & Game, Juneau. Prog.
                                                                                                                 Rep., Fed. Aid in Wildl. Restor., Proj. W-22-2, Job 3.30R.
                      construction of the Trans-Alaska Pipeline.. Can. Field-                                    17 pp.
                      Nat. 93(2)sl55-162..
                                                                         -                                 White, R.G.. B.R. Thomson. T. Skagland. S.J. Pearson. D.E.
                 Carruthers, D.R.. R.D. Jakimcbuk and S. Ferguson. 1984. The                                     Russell, D.F. Holleman and J.R. Luick. 1975. Ecology of
                      relationship between the Central Arctic caribou herd and                                   caribou at Prudhoe Say, Alaska. Pp. 151-212 in J. Brown,
                      the Trans-Alaska Pipeline. Prep. by Renewable Resources                                    ed. Ecological Investigations of the Tundra Brome in the
                      Consulting Services Ltd. for Alyeska Pipeline Service                                      Prudhoe Bay Region, Alaska. Biol. Paper, Univ. of Alaska.
                      Company, Anchorage. 207 pp.                                                                Spec. Rep. No. 2.

    23
    Whiteen, K.R. and R.D. cameron, 1983.  Population dynamics of
    the Central Arctic herd, 1975-1981.  Acta Zool, Fennica
    175:159-161.

    Whitten, K.R. and R.D. Cameron. 1985.  Distribution of caribou
    calving in relation to the Prudhoe Bay oil field.  Pp. 35-39
    in A. Martell and D. Russell, eds.  Proceedings First
    N. Amer. caribou Workshop, Whitehorse, 1983.  Can. Wildl.
    Serv. Spec. Publ., Ottawa. 68 pp

    ATTACHMENT C

    Southern Tier Services
    P.O. Box 29
    Beaver Dams, New York 14812
    (607)936-3324

    Mr. William Hopkins
    Alaska Oil and Gas Association
    121 W. Fireweed Lane, Suite 207
    Anchorage, Alaska 99503-2035
    17 January 1987

    Dear Mr. Hopkins:

    Enclosed is a copy of my review of the ANWR report. I apologize for it being
    late; the Post Office lost my Express Mail package. Please feel free to contact
    me if you have any questions or comments. You can contact me at the above
    address if I can be of further assistance.

    Sincerely.

    James Curatolo
    President

    Enclosure

    A REVIEW OF THE DRAFT REPORT

    ARCTIC NATIONAL WILDLIFE REFUGE ALASKA

    COASTAL PLAIN RESOURCE ASSESSMENT

    WITH RESPECT TO CARIBOU

    Prepared by:

    James Curatolo
    Southern Tier Services
    P.O. Box 29
    Beaver Dams, NY 14812

    Prepared for:

    Alaska Oil and Gas Association
    Suite 207
    121 W. Fireweed Lane
    Anchorage, AK 99503-2035

    I have reviewed the Draft Report Arctic National Wildlife Refuge
    Alaska Coastal Plain Resource Assessment Solely for its content as it refers
    to the effects of oil development on caribou. All of my comments reflect my
    own opinion on this subject.
    Overall, I thought the report provided a thorough examination of the
    various aspects of caribou biology as it related to oil development in the
    Arctic National Wildlife Refuge (ANWR). The report's final conclusion that a
    substantial decline in caribou populations would occur under a full leasing
    program, however, do appear to be extreme. In general, I believe oil
    development in the 1002 area would result in localized displacement of the
    PCH caribou during calving and localized changes in movement patterns
    during insect season. These changes would have a negligible effect on
    caribou productivity, however, because caribou would still have adequate
    habitat for calving and would still be able to access most of the insect relief
    habitat. The "core" calving area concept in the report probably
    overemphasizes the importance of a portion of the Porcupine Caribou Herd's
    (PCH)calving ground. It should be noted that the PCH's calving ground
    extends from the Canning River in Alaska to the Babbage River in the Yukon
    Territory. The PCH has calved succesfully throughout this region.
    Oil development in ANWR would be on the periphery of the Cetral
    Arctic Herd's (CAH) range. Effects of development in ANWR on the CAH
    should be minimal because the herd will rarely contact it. The CAH has
    shown a high degree of resiliance to the effects of oil development
    considering that two oilfields are presently within its home range, and the
    herd continues to increase.
    The secretary of interior's recommendation to allow full leasing in the
    1002 area of ANWR appears to be justifed as far as its effects on caribou are
    concerned. The mitigative measures that were suggested would help
    minimize the intensity of potential disturbances, resulting in an increased
    rate of habituation and greater use of habitat near oil development. A
    phased leasing system will distribute disturbances over time and space, thus
    minimizing the extent of potential disruption to the herd. Once oil
    development is completed, a policy that maintains human occupancy of the
    oilfield to a minimum will allow, over time, a re-occupation of areas where
    caribou use may have declined during construction.

                             I have reviewed the Draft Report Arctic National Wndtife Refu2e.
                      A122111- CO&JtAJ 1421D Resource Assessment. solely for Its content as It refers
                      to the effects of oil development on caribou. All of my comments reflect my                                                    1. P. 28, It 3:        Almost the entire basis for determining the magnitude of
                      own opinion on this subjecL                                                                                                    oil development impacts on the PCH fies in the identification of a core calving
                             Overall. I thought the report provided a thorough examination of the                                                    area. No rationalization is given for selecting greater than 36% (5 of 14
                      various aspects of caribou biology as It related to on development in the                                                      years used) as the cutoff point. Indeed, If a more logical criterion, such as
                      Arctic National Wildlife Refuge ( ANWR). The reports final conclusion that a                                                   50% (7 of 14 years used). wee chosen, then the core calving area is halved in
                      substantial decline In caribou populations would occur under a full leasing                                                    size. No attempt is made to enumerate how many caribou were contained in
                      program. however. do appear to be extreme. In generaL I believe oil                                                            the core calving area beyond the 50 animals/square mile minimum.
                      development In the 1002 area would result In localized displacement of the                                                     2. P.28.%6:            To put the calving ground in better perspective, the
                      PCH caribou during calving and localized changes in movement patterns                                                          entire 14 years of data should have been summarized rather than only 1983
                      during insect seaso& These changes would have a negligible effect on                                                           and 1984. There have been years when the entire herd calved in Canada.
                      caribou productivity. however, because caribou would still have adequate
                      habitat for calving and would 90 be able to access most of the Insect relief                                                   3. P. 28. q 7:         Caribou cows are very sensitive to disturbance during the
                      habitat. The "core" calving area concept In the report probably                                                                calving period. The disturbances caused by oilfield operation are mostly
                      overemphasizes the importance of a portion of the Porcupine Caribou Herd's                                                     confined to the roadway system. Caribou can easily avoid the roadway
                      .( PCH) calving ground. It should be noted that the PCH's calving ground                                                       system. resulting In localized displacement. Cows will then calve at a point
                      extends from the Cannina River In Alaska to the Babbage River in the Yukon                                                     where human activity is no longer preceived as a disturbing factor (1 -2
                      Territory. The PCH has calved successfully throughout this region.                                                             miles). This Is the can In the Kuparuk Oiffield.
                             Oil development in ANWR would be on the periphftT of the Cetral
                      Arctic Hard's          (CAH) range. Effects of development in ANWR on the                                                      4. P. 29, 9 3:         This paragraph suggests that the major insect relief
                      CAH should be minimal becoun the herd will rarely contact it. The CAH has                                                      habitat for the PCH is the coast. However. in most years the majority of the
                      shown a high degree of resillance to the off" of oil development                                                               herd travels inland (southeast into Canada) and uses the mountains for relief
                      considering that two oilfields we presently within its home range, and the                                                     habitat.
                      herd continues to Increase.
                       ,     The Secretary of Interior's recommendation to allow full leasing In the                                                 5., P. 29. q 9:        Most caribou of the CAH that calve In the vicinity of the
                      1002 area of ANWR appears to be justified as far as its effects on caribou are                                                 Canning River usually do so west of the Staines River. During an aerial
                      concerned. The mitigative measures that were suggested would help                                                              survey conducted in the 1984 calving season few cows were found between
                      minimize the Intensity of potential disturbances. resulting in an Increased                                                    the Cannin River and the Tamayarlak River.
                      rate of habituation and greater use of habitat near oil development. A
                      phased leasing system will distribute disturbances over time and spew, thus                                                    6. P. 29, qI 9:        The statement that "little or no calving has been observed
                      minimizing the extent of potential disruption to the herd. Once oil                                                            since 1973" is misleading because no one looked before 1973. 1 was in the
                      development Is completed, a policy that maintains human occupancy of the                                                       Prudhoe Bay area In the summer of 1972. before oilfield development, and
                      olifield to a'minimum will allow. over time. a re-occupation of areas where                                                    did not we any calves. There is no evidence to suggest that.a significant
                      caribou use may have declined during construction.                                                                             number of cows ever calved in the Prudhoe Day area. A more appropriate
                                                                                                                                                     comparison concerning off development and calving caribou is found In the
                                                                                                                                                     Xuparuk Ofirield where there we localized changes in distribution. but
                                                                                                                                                     continued use of the wee by calving caribou.

                                                                                                                                                     7. P. 98. q 2:         The concept that a specific area In a calving ground has a
                                                                                                                                                     unique value Is not supported by scientific data. The only known unique
                                                                                                                                                     aspect of a calving ground is that caribou calve there. Caribou behavior has

                    evolved to minimize predation during calving by cows synchronizing                                                      Productivity was good in all years studied Including those years when the
                    parturition. aggregating during calving. and selecting relatively predator-                                             entire herd calved in Canada or entirely outside of the core calving area.
                    free habitats in which to calve. The aggregation and synchronization results
                    in a high density of calves over a relatively small time and area. which                                                13. P. 108. q 7.8: This report states that caribou would be displaced two
                    "overwhelms" the predators (the chance of any individual calf being caught                                              miles from oil development. However. this displacement would not be totaL
                    is lower than that of other strategies). Caribou cows accomplish this strategy                                          but would result in fewer caribou near the road system. The habitat values
                    by returning to the same area. thus forming a " tradition". However. caribou                                            of the area would be diminished. not completely lost
                    are "dynamically traditional" because the exact location of a concentration in                                          14. P. 109. q 2:     Barriers to caribou movements would not decrease
                    a calving ground varies from year to year. If, for example. a certain portion
                    of the calving ground Is made unavailable to caribou due to heavy snowfall.                                             calving success as long as sufficient calving habitat remained accessible and
                    then calving will occur in another portion of the calving ground. The                                                   available. If the proposed mitigative measures were Implemented. few
                    corollary to this is that I intense oilfield construction causes part of the                                            barriers would occur.
                    calving ground to be "unavailable" to caribou. the cows may be displaced. but
                    there should be no effect on calving as long as there is a sufficient portion of                                        15. P. 109, q 3:     There is little or no difference in the caribou reactions to
                    the calving ground remaining. The only universal attributes of a calving
                    ground is that It is a relatively predator-free and has open space where                                                a buried pipeline and a road without traffic. Large, mosquito-harassed
                    concealing habitat Is minimal.                                                                                          caribou groups will cross elevated pipelines. It is only pipelines next to
                                                                                                                                            roads with traffic that can cause a significant decrease in crossing success.
                    8. P. 101, q 4:       The suggestion that the routes of the pipeline and road
                    should be independent, allowing for a separation between the pipeline and                                               16. P. 109. q 6:     It is highly unlikely that the PCH will refuse to cross
                    road. Is probably one of the most important mitigative measures that could                                              oilfield development during insect season if mitigative measures are are
                    be undertaken.                                                                                                          followed (especially pipeline and major road separation). Suggesting that
                                                                                                                                            caribou avoid areas near oilfield activity (the two mile sphere of influence)
                                                                                                                                            du.-.I-.- -1--do-eam- Ws             Th.      -H. -k- @f I.M. - reffes. to
                    9. P. IU3.149:        Ybe 3UUU to 4UUU caribou from tile CAH that use the                                                                                             -- V- - -.-e-
                    1.002 area. do so infrequenity. Large numbers of CAR caribou would                                                      a partial displacement of caribou during calving and does not occur when
                    pr9bably use the 1002 area only during an extended movement due to                                                      caribou are harassed by insects. Failure of caribou to reach insect relief
                    mosquito harassment. which would last for several days or less. In most                                                 hafiitat is unlikely with proper mitigation (pipeline and read separation).
                    years. few CAR caribou calve in the 1002 area.                                                                          Furthermore, the PCH has been exposed to overhead stimuli. as they usually
                                                                                                                                            winter in forested regions of Alaska and Canada. PCH caribou may react less
                    10. P. 106. q 1:      Comparison of the CAR in the Kuparuk Oilfield to the PCH                                          severely to pipelines than CAR caribou, who live entirely on the tundra.
                    in the 1002 area Is reasonable. There is a calving concentration area within
                    the Euparuk Oilfield and nearly half of the herd repeatedly comes in contact                                            17. P. 110. q 7:     The total kill for the CAR in the winter or 1985-86 is
                    with oil development during the summer. CAR caribou in the Kuparuk                                                      probably substantially greater than the estimate of 800 given in the report.
                    Odfleld probably encounter oil development more often the PCH caribou will.                                             Actual postcard returns tallied $75 animals. Considering almost all or the
                                                                                                                                            kill was illegal it to not Inconceiveable that many people would not report
                    11. P. 107. q 5:      Displacement of the CAR from an historic calving ground                                           their take. The number of caribou killed in 1985-86 may be more than 10%
                    has not ben documented. It has been hypothesized that this occurred,                                                    of the herd and could be a significant factor in the CAR's population
                    although no data exists to show that caribou ever calved in the Prudhoe Day                                             dynamics.
                    area in any number.                                                                                                     18. P. I 11. q 3:    It does appear possible to mitigate the lose of caribou
                    12.P.108A23: The expectation that PCH productivity would decline if                                                     habitat in Resource Category I by decreasing potential disturbing factors so
                    calving was displaced from the core calving are* Is not supported by data.                                              that fewer acres of that habitat type would be affected.

                      19. P. I 11. q 5:     Mitigation Measure 0 1 suggests that ramps and elevated                                                    Mitigation only begins at 400 reet and thewider the separation, the better,
                      pipelines are the alternative to pipeline burial. If pipeline burial is not                                                      depending on the speak circumstances Involved.
                      practicaL the best alternative is elevated pipelines that are separated from                                                            (c) Ramps should not be used as a general mitigative measure. Their
                      roads (Mitigation Measure 25). Ramps are not an effective measure due to                                                         only effective use is in a "corral" situation where Pipelines near a facility
                      the extremely small size of a ramp with respect to an oilfield, and the                                                          might completely encircle an area. Ramps are too site specific and do not
                      relatively high cost of construction Separation of pipelines from roads can                                                      work well near traffic, making them ineffective In most circumstances,
                      be widespread in the area of coverage, and is potentially very cost effective
                      (Pipelines run straight. roads follow dry topography). In theory. placing
                      mitigative measures in areas such ag"natural crossingf' sounds logical, but
                      In practice it is nearly Impossible for two reasons. First. caribou movements
                      are variable. depending on insect levels, weather conditions. and the area
                      selected for use during any particular time period. Secoad. and more                                                             J men Curatolo,
                      Importantly, the development of an WNW will result in a localized change                                                           esident
                      in caribou movement patterns, which cannot be predicted with any great                                                             others Tier SwYlees
                      degree of accuracy beforehand. The most reliable mitigation method Is a
                      generalized scheme where pipelines and roads are separated whenever
                      practical. Over time. this would allow caribou to develop movement patterns
                      through the offield and minimize loss of habitat due to 'as ssibifity.
                      Separation of roads and pipeflues will also decrease the Intensity of
                      disturbances that an present. which will Increase the rate of habituation to
                      the entire project.

                      20. P. I 11. q 7:     Mitigation Measure #2 can be an Important technique.
                      Caribou will habituate to a disturbance much more readily If the disturbance
                      is kept at low levels. Regulating unnecessary traffic In areas of high use by
                      cpribou can be very effective. A limited access road such as the OUktok Road
                      in the Kuparuk Oilfield is a good example. This discussion is also applicable
                      to Mitigation Measures N4.6.7. and 10.

                      21. P. I 11. q 8:    Mitigation Measure 83 Is important and should be
                      followed. The only major loss to the CAH population resulted from hunting
                      along the TAPS haul road.

                      22. P. I 11. V3.14: Monitoring the dynamics of the caribou herds during oil
                      development will provide additional information for focusing on real
                      problems rather than hypothetical once.

                      23. P. 112. q 2:     The CAR and PCH will probably not reach the "carrying
                      capacity' of the habitat contained In their home ranges . Caribou herds do
                      not reach the carrying capacity of their range. except in certain bland
                      populations, because natural and human-caused mortality factors restrict
                      -hard prowth before habitat limitations come Into play. No free-ranging
                      caribou hard has ever reached the carrying capacity of their habitat.
                                                                                                                                                         ot ki

    ATTACHMENT D

    AN ASSESSMENT OF PETROLEUM DEVELOPMENT ON THE STATUS OF THE PORCUPINE HERD

    by

    DR. A. T. BERGERUD

    Professor of Biology, University of Victoria, Victoria, B.C. Canada, V8W 2Y2

    Prepared for the

    Alaska Oil and Gas Association

    January, 1987

    2

    The U.S. Federal government has proposed that the 1002 lands of the
    Arctic Coastal Plain and in the Arctic National Wildlife Refuge, Alaska,
    be opened for exploration and full leasing for petroleum supplies.
    Included within the 1002 proposed lease area are 242,000 acres of 311,000
    acres (78%) of the core calving area of the Porcupine Herd (core defined
    as areas in > 5 of 14 years) and 934,000 acres of 2,117,000 acres
    (43%) of concentrated calving area of the herd (areas with > 50 animals/
    mi_).  Also included is the 1002 area is the habitat where nearly the
    entire heard, now estimated at 180,000 animals, masses in early July to seek
    relief from mosquitoes.  The herd leaves the 1002 area in mid to late July
    and does not return until the following May.  I have been asked as a
    caribou biologist, by AOGA, to evaluate the impact of full leasing and
    development on the viability of the herd and specifically to critique the
    enviromental impact statement prepared by the Fish and Wildlife Service
    on the proposed full leasing and development.

    Background Theoretical Considerations

    The envirement of the caribou (Rangifer taradaus) can be segregated
    into: other animals, a place in which to live, food and weather (Fig. 1,
    Andrewartha and Birch 1954).  The interactions of caribou with insects,
    open habitats, food and weather represent variable contingencies that
    result in facultative responses by caribou that can be modified relative
    to disturbance factors (Fig. 1).  The interactions of caribou with other
    caribou and with wolves in open enviroments are consistant contingencies
    affecting reproductive fitness - these are obligatery responses that will
    respond to change very slowly, if at all, when habitats are modified.

    -3-

    Figure 1.  Diagram of the proposed manner in which the four components
    of the enviroment interact as variable and consistant
    contingencies in the development of movement, aggregation
    gregarious and distrubance behavior of caribou (Bergerud 1974b).

    4

    I feel that the major behavioral responses of caribou in the 1002 area
    are the insect % weather facultative responses and the predator % habitat
    obligatory responses.  Unlike many biologists, I do not feel that food is
    a major factor in the calving and massing of caribou in june and July in
    the 1002 area.

    Are caribou Wilderness Animals?

    Much of the concern for the well-being of caribou arises from the
    view that caribou are wilderness animals that cannot adapt to coinhabiting
    ranges with man.  This concept has arisen, in part, because caribou are
    found on ranges far removed from major developments.  Also, caribou herds
    have declined on the southern edge of their range as settlement proceeded
    (Cringam 1956).  Thirdly, caribou are unwary and easily over-exploited.
    And lastly, caribou utilize slow-growing lichens that are many years in
    recovering following forest fires.
    However, a closer examination of these facts suggests that they are
    not sufficient to define caribou as wilderness animals nor to imply that
    loss of wilderness per __ will bring about the demise of herds.  Obviously,
    mule deer (Odecelleus hamionus) and antelope (Amtilocapra americana) were
    once far removed from european man in the 1700's but they are not called
    wilderness animals today: they have adapted.  The decline of caribou along
    their southern boundary was due to increased predation from man and
    natural predators, as well as from disease contracted from white-tailed
    deer (Odoceileus virginianus) (Bergerud 1974a) and not from outright
    habitat alteration.  There is no evidence that herds abandonned their
    annual rang'es because of an intrinsic aversion to man or man-made

    5

    structures.  The nomadic life style of caribou and its propensity for
    shifting habitats makes it as adaptable to abort term habitat alterations
    as it is to the slow succession of lichen following natural fires and
    regeneration cycles.  The unwary nature of caribou means that they can
    colahabit range with man if not overhunted.  In fact, reindeer (rangifer
    tarandus) are an important domestic animal in Eurasia.  Several caribou
    researchers have noted that caribou are both highly adapted and adaptable
    (Skoog 1968, Bergerud 1974b, Roby 1978, Skogland, pers. comm.).

    Resource-Limited by Food?

    Another basic philosophy that influences how some caribou biologists
    view the impacts of development on caribou is the closely held belief
    that the carrying capacity of the habitat for caribou is determined by
    food resources, the slow growing lichens in winter, and green plants in
    the summer.  It follows from this belief that if caribou are displaced
    by development and lose part of their range, then the potential carrying
    capacity is reduced.  Another concern is that, if the animals are at a
    carrying capacity limited by food, then additional disturbance may stress
    the animals, thereby reducing reproductive rates and increasing mortality
    rates.  A futher refinement is that caribou select their calving grounds
    to maximize the quantity and quality of the diet - to optinally forage
    (Kuropak and Bryant 1940).  Hence displacement from the calving areas
    should adversaly affect the herd.
    As an example of thes type of thinking, Whitten and Cameron (Arctic
    (1984:293) said, speaking of developmental impacts, "For example, a series
    of mild winters might compensate for the negative effects of harassment or
    habitat loss."  Bergerud, Jakischuk and Carruthers replied (Arctic
    1984:295) "The supposition advanced by Whitten and Cameron...assumes:
    (1) that winter conditions limit caribou numbers (this has never been
    substentiazed in mainland North America):
    (2) that harassment results in caribou mortality - never substantiated
    and the extreme case (Pot Nill data) given in our paper represents
    the best available contrary evidence pertaining to this assumption;
    (3) that habitat loss (unspecified) has governed caribou numbers
    (greater evidence for the opposite case is available in the
    literature):
    (4) that ranges are at carrying capacity - which is not the case for any
    of the herds we discussed:
    (5) finally, that the supposition has some basis in fact.  However, this
    supposition has never been researched."
    Such a seemingly innocous statement, as made by Whitten and Cameron,
    reveals a basic philosopy of food limitation, and is the cornerstone of
    many dire predictions of caribou demise with development.
    But in fact, the carrying capacity of this herd is not limited by
    winter food supplies.  The dynamics of the Porcupine Herd were modelled
    in a workshop at the University of British Columbia in 1978.  The herd
    then numbered 110,000.  The simulation model indicated that the herd was
    not limited by winter food supplies.  Food would not be limiting until the
    herd reached about one million animals.  The simulation even indicated
    that if no animals crossed the Dempster Highway and the entire range east
    of the road in the Ogilvie Mts was lost, the herd could still prosper if
    food resources were the only consideration.  The same simulation, however,

    7

    indicated that the herd would be limited by wolf predation at denaities
    far below those imposed by food resources (Walters et al. 1979).

    Both reproductive and natural mortality rates of caribou are
    little affected by winter food supplies.  Fecundity is relatively fixed
    at 1 calf/female/year for females > 3 years-of-age regardless of densities
    (Bergerud 1971, Skogland 1986).  Skogland provided an equation for
    recruitment for females > 1 year in norway, where there are few predators,
    where R - 0.65 - 0.012 Dw - 0.00013 Dw_ where Dw - caribou/km_.  even at
    a density of 10 caribou/km_ of winter range, recruitment would equal 52
    yearlings/100 females.  At a density of 10 animals/km_  the porcupine
    herd would number 1,800,000 animals and even this density would not hold
    since this many caribou would have greatly expanded their range.

    In North America, in herds coexisting with wolves, recruitment is
    commonly less than 25 yearlings/100 females and yet densities seldom
    exceed 2 caribou/km_ (Bergerud 1980).  This disparity in densities and
    recruitment between Noray and North America is due to predation in
    North America.  Predation limits populations far below that provided by
    food supplies (Bergerud et al. 1983).

    Carrying capacity has been defined as that point where recruitment
    natural mortality (Caughley 1977).  For caribou on mainland North America
    the carrying capacity is determined by the abundance of predators
    (Bergerud and Elliot 1984).  Recruitment equalled natural mortality for
    22 herds at 6.5 wolves/1000 km_ (Bergerud and Elliot 1986) regardless of
    the density of caribou on the winter range.

    8

    Long Term vs. Short Term, Individual vs. Herd

    Berberud, Jakimchuk and Carruthers (1984) reviewed the demography
    of 8 herds relative to distrubance by human activities.  They concluded
    that the major impacts were (1) the building of transportation corridors
    that permitted increased human harvests of caribou and (2) the
    improvement in calf survival when wolves were reduced.  Caribou herds
    continued to cross roads, and herds such as those in Newfoundland, still
    prospered when habitate were altered by logging and flooding.  The central
    Arctic Herd in Alaska increased from about 5,000 to 13,000 (early 1970's
    to 1984) despite the Prudhoe Bay oil field.
    The conclusion of bergerud et al.  (1984) were debated in letters
    to the editor by Whitten and Cameron (Arctic 1984:293), Klein and White
    (Arctic 1984:293-296 and Miller and Gunn (Arctic 1985:134-155).
    Rebuttals to all letters were provided by Bergerud and Jakimchuk (Arctic
    1984:294-295, Arctic 1985:155-156).  Klein and White agreed that the
    herds were increasing but thought that disturbance must be viewed on a
    long term basis.  But this is a nonsequitur - if there are no effects of
    disturbance for a shor term, how are they significant on a long term? The
    long term is the addition of short term intervals.  Miller and Gunn agreed
    that the herds were increasing but stated that disturbance must be viewed
    on the basis of the individual, not the herd.  Again, this is a
    nonsequitur - since individuals comprise herds, if the herds are
    prospering, then the individuals are also faring well.
    Now, there are now arguments that the prosperty of the Central
    Arctic Herd in the face of development cannot be used to gauge the success
    of the Porcupine Herd when faced with similar development and the question

    9

    is, why not?  The Central Arctic Herd spends its entire annual cycle
    quite close to the development zone - the Porcupine Herd spends only two
    months.  All the animals now alive in the Central Arctic Herd have been
    born since development commenced; they have adapted.  The basic reason
    that some biologists cannot accept that caribou can cope with development
    is their ingrained views that caribou are "wilderness animals" and that
    food supplies are limiting.  The new research work planned for the
    Porcupine by the Alaska Fish and Game is proceeding on this basis.  Now
    caribou will be radio-tracked by satellites and energy budgets calculated
    daily, perhaps hourly.  It all flows from the unsupported belief that
    nutrients and energy will ultimately limit total numbers of caribou in
    this herd.

    Biology of Calving and Aggregating Behavior

    Before we can evaluate the potential impacts of development on the
    Porcupine Herd we must determine why the animals use the coastal plain in
    the 1002 area for calving and grouping after calving.  Basically, what are
    the environmental factors that determins where caribou locate their
    calving grounds?
    The calving grounds of the migratory herds in the Holarctic are
    usually located on the northern distribution of the herd's range in
    tundra habitats (Appendix I:fig. 1).  The cows leave the bulls and
    commence migration towards these areas generally in April before green
    plants appear.  Some herds migrate northeast, others northwest, and two
    herds south of Hudson Bay even migrate east.  The consistent factor in all
    these migrations is that cows cross the tree-line at right angles

    10

    (Appendix I:Fig. 1) Wolves in North America generally den near tree line
    )Appendix II).  By migrating at right angles to the tree line the cows
    can maximize their distance from wolfes, with the least effort.  Caribou
    cows migrate and calve on the bleak inhospitable arctic tundra to reduce
    contract with wolves (Appendix II) and there very few wolves on the
    calving grounds of the Porcupine Herd.
    An alternative hypothesis is that caribou seek their northern
    tundra calving grounds to optinally forage, primarily on Eriophorun
    angustifelium (Kuropat and Bryant 1980).  I was able to disprove this
    hypothesis in 1984 by compering the nitrogen in focal droppings and plants
    at the time of calving between cows on calving grounds and bulls still
    south of calving grounds.  The bulls were feeding in more nutritious plant
    communities than the cows (Appendix I:Table 1). If the calving grounds
    were realty unique in the quality of forage then the bulls should have
    been with the cows.  If the cows were primarily "interested" in the
    quality of their forage, they should have stayed back with the bulls.
    The fact that cows commonly calve on Eriopherum tussock associations may
    be due to the particular microtopography of these habitits which results
    in little accumulation of snow and early snow melt (Benson 1969).  That
    is not to say that caribou do not optinally forage within the constraints
    of selecting the best overall habitat to avoid predators.  However, over
    all, the diet of the cows in late May and early June is not highly
    nutritious (Appendix I:Table 1) and this has resulted because of their own
    migratory behaviour.
    The location of the calving grounds varies between years because of
    annual varations in snow cover.  The caribou arrived on the calving

    11

    grounds of the Porucpine Herd on 5 May 1976 and 12 May 1975 when snow
    cover was light; they arrived 20 May 1976 and 24 May 1973 with medium snow
    cover and even later on 26 May and 30 May when winter snows had been
    heavy (Curatole and Roseneau 1977).  The calving ground of the Porcupine
    Herd is on the areas of reduced snow cover generally sandwiched between
    the foothills and the slightly colder costal strip (Fig. 2).  In an
    early spring, as in 1974, the animals will be farther west and north than
    in late years such as 1972 and 1973.  In an early year, more caribou will
    calve in the 1002 area than in a later year.  In 1982, the season was so
    retarded that the herd calved in the Yukon (ANWR Progress Rept FY 83-6).
    We can think of the annual variations as caused by snow induced
    limitations to the basic spacing antipredator tactic.  But within this
    tactic, to maximize the distance from tree line, the animals also need
    to find brown substances so that calves can be cryptic, especially to
    avoid predation from golden eagles (Aquila chrysaetos).  Thus snow cover
    effects the distrubtion within the coastal plain but not the overall
    regional distribution.
    We know less about the extrinsic and socialization factors in the
    massing of caribou in late June and July then we know about calving.  In
    all years, the animals concentrate on the 1002 lands.  This occurred even
    in 1982 when the herd calved in the Yukon (ANWR Progress Rept. FT 83-6).
    We also know that the Porcupine Herd is unique that in some years the
    entire heard comes togegher for a few days in July.  This represents the
    most spectacular aggregation of ungulates in North America and compares
    favorably with the aggregating of the wildebeaste (Connochaetes taurinus)

    12

    Figure 2.  The snow profile of northeastern Alaska in late May 1978 (from
    Lent 1980).

                                                            13                                                                                                     14

                        an the Serengeti.                                                                                       may hold for the tidal flats near Batter Island.  Thus we don't know if
                               Initially, after Calvin&, cows with their calves group together                                  the uniqueness of the gathering near Barter Island is because of its
                        in the vicinity of where the calves were born (Lent 1966, Bergerud 1974b).                              juxtaposition to calving locations or if the area, per sag has its own
                        This aggregating represents another &ntipr*dator tactic. A caribou calf                                 special attraction.

                        will benefit if there Is another animal between itself and a predator
                        (the selfish hard concept) (Appendix 11).  Later, with the onset of the                                 Critique of the Arctic National Wildlife Refuge-Alaska Coastal Plain
                        mosquitoes, the caribou in the Porcupine Hard move to the coast where                                    Resource Assessment

                        cooler temperatures and fog provide some relief. The animals are usually
                                                                                                                                      my comments are limited here to the full leasing option and are
                        concentrated Ln,july south of Barter Island in the 1002 lands.                                          restricted to caribou.  This is the worst case scenario and-many of my
                              Why is this particular strip of coast s*L*ctedi The animals way
                                                                                                                                comments will reflect my view that caribou can adapt to full leasing and
                        select the coast adjacent to Barter Island simply because the core                                      developing if the proper mitigating actions ore taken.  I will only discuss
        9               calving area Is near the Jago River, hence a direct route to the coast                                  my major criticisms, which does not mean that I necessarily agree with
         ca             leads to Barter Island. In support of this view, in 1974, when the
          &                                                                                                                     sections not discussed.
                        concentrated calving was &Long the Katakturuk River, the post calving
                        grouping was at nearby Camden Day.  But to the contrary of this sequence$                               2 mile Limit: On several pages it is suggested that maternal cows will
                        when the animals calved near Herschel Island in 1982, they still travelled                              avoid a strip 2-miles out from major roads and development. This implies
                        up the coast after calving to the area adjac  t to Barter Island (ANWR                                  a 4-miLe displacement when both sides of the road are considered.  The
                        Progress Rapt. PY 83-6). This fidelity to t::  coast opposite Barter                                    reference for this avoidance strip is Dau and Cameron (1986). Based on
                        Island could be do@ primarily to (1) tradition and socialization, or It                                 this 2-mile ruLop the report calculate* the acreage lost to csrt@.ou from
                        might result because (2) the animals may, between the and of calving and                                development. Firstly. the concern should not be the lost acreage as it
                        the emergence of Insects, (allow the green phonology west. or, (3) the                                  relates to carrying capacity. The cows have not selected the coastal plain
                        concentration at Better Island may relate to some additional relief factor                              for it forage resources but to avoid predators.  it 'wolves travel the
                        from mosquitoes. ror example, a small herd of 2000 animals on the Hudson                                haul road, as they did the TAPS highway (Roby 1976) it will be
                        Bay Coast to Ontario aggregates In July on the tidal benches where there                                advantageous for caribou to avoid the hab.'tat adjacent to the road.
                        are large cud flats. In the absence of vegetation to hold insects, these                                Secondly, Dew and Cameron (1986) did not show caribou avoidance of a
                        caribou probably gain added relief from mosquitoes.  This same situstion                                2-miL* strip on both sides of travel routes.  Dow and Comecon documented

    16

    a 50% avoidance of adjacent habitats at 2 kilometers from the road and no
    avoidance at 3 kilometers (p. 100:Fig. 4).  Thus there should be 50%
    avoidance at 1.2 miles and no avoidance at 1.9 miles.  Actually, Murphy
    and Caratolo (in press) show that caribou, including cows and calves,
    resume normal foraging and daily activities when 600 meters from active
    roads in the Prudhoe oil field.  Therefore, a maximum statement is that
    maternal cows avoid about a 1 1/2 mile strip on each side of the road, thus
    the displacement statements in the report should be reduced substantially.
    If development proceeds in area 3 as shown on page 7 of the
    assessment statement, there would be 47 miles of road in the core calving
    area.  We could expect maternal cows to be displaced from an area of 141
    mi_ or about 90,000 acres.  However the area between the two parallel
    roads in the hypothetical development would also probably be lost.
    parallel roads to reach different objectives should be avoided.  However
    parallel roads to reach the same objective might be a way to re-direct
    traffic to minimize disturbance, depending upon which route has the most
    caribou nearby.

    P. 28, Para. 1.  "The lower levels of earlier estimates may reflect a
    truly smaller population, less accurate or less complete survey
    techniques....".  Because the Porcupine herd gathers in one or a few
    major aggregations, the census results of the herd by aerial photography
    is highly accurate.  The herd has definitely been increasing.  This
    increase has resulted form greater calf survival (Fig. 3).  The increased
    calf survival occurred because wolves were reduced by rabies in the late
    1970's and early 1980's.  Jakischuk and associates saw considerable more
    wolves in 1971 and 1972 then have been seen in recent years.

    16

    Figure 3. The regression of calf survival (calves/100 __) on year.

                         P. 29, Pars. 4. "ACCQSS to insect-rell*( habitat and (areas resources                                    in cows being productive or not producttvO- Since fecundity is fixed In
                         during this period may be critical to hard productivity." No one has                                     mature caribou the emphasis should always be on survival after the calves
                         documented that fecundity or calf survival have been affected by failure                                 are born.
                         to reach mosquito relief habitat. There are no other large herds In

                         North America that have access to a foggy coastal strip. Even If the
                                                                                                                                  P. 29. Pace. 10. "Riparian areas are used for travel corridors...".
                         animals could not use the coastal strip this would only put then on par
                                                                                                                                  This does not sound feasible since wolves also use riparian areas for
                         with other herds. Note that there were an excellent 39 catves/100 cows
                                                                                                                                  travel. Caribou in Spetsisig B.C. avoid ambush cover in tell willows
                         in July 1976; in that year the animals did not mass an the shares of the                                 (B*rgerud. Butler and Hills r 1964). Also the streams &to In flood in
                         coast. However, It caribou did seek the foothills for Insect relief.                                     late May and early June and are not suitable for small calves. In
                         reduced calf survival would be expected because of increased predation.                                  Svalbard, T. Skogland (Pars. coIsm.) Indicated that bull caribou use the
                               In this paragraph and throughout the report, the word "productivity"
                                                                                                                                  riparian communities and flood plains but cows avoid these dangerous
                         is used as a synonym for "recruitment". This Is an unfortunate usage. To                                 areas. Curstoto (1983) &Lee indicated that bulls used the riparian
                         many ecologists. productivity brings to mind "to produce". the elements                                  community but cows generally avoid them Oee also Roby 1978').'
                         of reproduction, and for others it Implies biomass as is the terms
                         primary and secondary productivity. The use of the word "pcoductivity"                                   P. 108. Pars. 1. "Caribou select "Lving areas because of favorable ...
                         comes with the philosophy of a food carrying capacity@ for many ungulates                                advanced new vegetation ... proximity to insect relief habitat...".
                         in the Lower 48 states (where there are no waives) the number of young                                   Caribou only select calving grounds to avoid pradatars'(Appendix 1.11).
                         born per 100 adult foules does vary witb nutritional conditions.    In                                   The report to too general in using the word "Insect-relief". Generally,
                         these southern ungulates, the final recruitment may indeed reflect the                                   Insect relief is "our to include both mosquitoes and oestrid flies.
                         initial variations to pregnancy percentage*. for caribou, we should use                                  whereas the coastal habitats that the caribou seek are to escape only
                         the terms "fecundity'. "porous percentage", at "pregnancy rate" to                                       mosquitoes. Oestride do not emerge unti,t lots in July, when the animals
                         describe the Initial number of calves/100 cows at birth. prior to                                        have left the 1001 lands.

                         mortality. The emphasis thereafter should be on documenting the survival

                         or mortality statistics; the final yeartings/100 females parameter at                                    P. 108. Pars. 2. "Displacement of the PCH from a coca calving area to a

                         12 months should be called "recruitment". "Productivity" is a catch-all                                  Less desirable oze& would be expected to reduce productivity . Again#
                                                           that the resources of the lead result                                  the word should not be productivity. it the development results in a

    19

    displacement of caribou farther south towards tree line it will result in
    increased prodation (Fig. 4) and reduced survival.  "Loss of important
    habitat has been shown to directly impact ungulate populations (Wolfe,
    1978: Skovlin, 1982)".  This is a general motherhood statement and these
    references are for ungulates living without wolves and are not
    appropriate for the Porcupine Herd.  When caribou herds increase they
    expand their range and when they decline the range shrings (Bergerud
    1980).  Calf survival drives numbers and hence range occupancy.
    "...Whitten and Cameron (1985) contend that the CAH has not experienced
    a reduction in productivity ... because (1) the CAH has been displaced
    from only a part of its calving grounds:...".  The herd could be
    displaced from all of its calving area and still not decline if predator
    numbers were managed.  The CAH herd increased 1972 to 1985 because of
    high calf survival since wolf numbers had declined with development.  As
    their second point, Witten and Cameron argued that the CAH did not
    decline with development because "...(2) suitable alternative
    high-quality habitat appears available...".  The habitat at Prudhoe Bay
    is so poor that White et al. (1973) calculated some negative energy
    budgets and thought that the herd was energy-limited when it numbered a
    few thousand animals in the early 1970's.  Again the habitat was thought
    to be so poor from a forage standpoint that Skogland (1980) listed it as
    the area with the least plant biomass of 6 herds in the Holarctic.  Yet
    today the CAH has grown to >15,000 animals.  Point 2 of Whitten and
    Cameron (1985), referenced in the assassment statement, is an ad hoc
    hypothesis to explain away the herd's prosperity in the face of
    development.  As their last point, Whitten and Cameron felt that the CAH

    20

    Figure 4. The regression of calf survival (calves/100 __) on distance of
    calving ground from tree line.

    21

    has not declined with development because the "...(3) overall density of
    CAH caribou on their calving grounds is much lower than that on arctic
    herds in Alaska".  Again this reflects Whitten and Cameron's dogmatic
    opinion that forage determines numbers.  The CAH calving ground is about
    125 miles from tree line and the PCH, only 30-40 miles.  Given the much
    larger "safe" space, the cows in the CAH are also able to disperse which
    is another antipredator tactic (Appendix II).  The animals in the PCH
    herd, faced with less space, are more aggregated.  Again this is expected,
    if the aimals were dispersed, many would be nearer tree line and at
    greater predation risk.  Since food supplies are not limiting for either
    herd, the greater densities for the PCH are not a problem.  In fact the
    aggregating is a tactic to avoid predators; when animals face food
    problems such as in the high arctic or on Svalbard, the groups disperse
    and densities are low (T. Skogland and F. Miller, pers. comm.).

    P. 108, para. 3.  "Both absolute..."  This paragraph is irrelevant.  One
    cannot use density figures (see above) to argue that the PCH will face
    greater consequences than the CAH from development.  The CAH lives year
    round with development and has prospered;  the PCH will only be near the
    development for 2-3 months.  Densities are functions of aggregating
    behaviour and the lower densities for the CAH than the PCH mean greater
    forage as well as less space for the PCH, and in no way signify the
    density-dependent problems that Whitten and Cameron imply.

    P. 108, Para. 4.  "With th CAH calving density remaining low compared to
    other herds.... overcrowding and consequent habitat stress that right

    22

    result in reduced productivity have not yet accurred, ..."  This
    statement is not correct;  there is no habitat stress.  The CAH cows
    have selected their calving range, with its low plant biomass, to avoid
    predators.  Cows in other herds in North America are also prepared to
    sacrifice optinal foraging to avoid predators (Ferguson 1982, Bergerud
    et al. 1984).

    P. 180, Para. 5.  "The PCH is much more crowded..."  They are not
    crowded - they aggregate to maintain maximum distance from tree line.

    P. 109. Para. 2.  This paragraph continues to discuss insect disturbance.
    But what is involved is primarily mosquitoes.  Oestrid flies are not on
    the wing until the animals leave the 1002 Lands.  Helle in his
    publications was primarily concerned with oestrids and other flies and not
    mosquitoes.  To quote their work in this context of causing mortality is
    stretching the argument.

    P. 109, Para. 6.  "Failure to obtain relief from insect harassment from
    either factor (barrier or displacement) could shorten foraging time,
    leading to poorer physical condition and subsequently to increased
    susceptibility to predation and reduced overwinter survival."
    The 1976 and 1981 cohorts did not apparently use the coast line for insect
    relief and these cohorts did quite well.  These animals are not on a fine
    edge in physical condition.  No one has documented winter starvatioin in
    North America as a result of high insect years.  When the insects abate
    in late August and September, the animals are able to recoop their losses

                                                               23

                                                                                                                                                                             24

                         and fatten for winter.   Remember that the Porcupine hard has a unique to&                                    including areas used for calving.   Why can't the authors be objective?
                         belt tat Insect relief that other herds do not have and even they (PCH)                                       The empirical evidence is there for aLL to som; the CAH Increased
                         desect the mosquito relief habitat by mid-July. Murphy and Curatolo                                           coincident with development because predator numbers were reduced.
                         (in press) showed that caribou at Prudhoe Say, away from the road, feed                                       How can the field findings be twisted to fit preconceived Ideas?
                         53% of the day prior to mosquito emergence, 41% with mosquito harassment
                         and 29% with oestrids on the wing. Oestrid flies harass caribou more than                                     Impacts.and Mitigation
                         do mosquitoes and yet PCH animals contend with costrid flies well Inland
                         in August.                                                                                                          The ons, guaranteed Lmpsct of the development of the 1002 lands

                                                                                                                                       will be that cows with young calves will avoid active roads for a distance

                                                                                                                                       of >1.2 miles. This is based both on theoretical considerations (Dergetud
                         P. 112, Par&. 4. (and p. 132 as well) "These changes ... could result      in
                         a major population decIfne sad change to distribution of 20-40 percent..."                                    et al. igao and empirical observations (Dou and Cameron 1986). The
                         They have provided no data to show a 20-40t population decline.     Neither                                   Loss of,this habitat will not cause additional stress on the animals
                         was . con.en.u. reached on the magnitude of any negative effects on the                                       since they ate not nutritionally Limited.    Nor will activity budgets be
                         PCH populaition size or distribution by the I'& specialists at the Caribou                                    seriously altered by development activities (Murphy and Curatolo in
                         Impact Analysis Workshop (AMR) in November. 1985.     1 believe that the                                      press).  It might be more serious it the animals remained near the coed
                         caribou will continue to use the 1002 lands with development, except near                                     where prodotors way travel. we do not want these cows to habituate to
                         active roads.  Even If there was some displacement, there is no need for                                      traffic because this would suggest that they might become less wary to
                         the herd to decline it volt populations are man&ged to provide positive                                       their natural predators.
                         recruitment or calf survival sufficient to balance notural and hunting                                              An Impact that might affect calf survival would be If the females
                         mortality.                                                                                                    in May failed to cross the east-w*st haul road because of the traffic
                                                                                                                                       and shifted their calving distribution closer to the foothills where
                         P. 112, Par&. 5. "The population decline or distribution change would be                                      t.here are greater numbers of wolves and bears. Such a barrier affect
                         5 - 10 percent for the CAN throughout its range." There is no evidence                                        has not resulted from the TAPS corridor and haul road. The CAN animals
                         to support such a decline.  A change in distribution cannot cause a                                           have crossed the road and shifted their distributions between years.
                         decline unless it changes the reproductive or mortality rates.     Caribou,                                   making use of habitats both east and west of the corridor. Presumably,
                         even in undisturbed populations, frequently exhibit rbrie shifts,                                             these shifts relote to snow cover (jaktmchuk pers. comm.).    The PCH
                                                                                                                                       hard. since it is both more migratory and larger than the CAN. should

                                                           25                                                                                                                  26

                         cross a ptpolLne-road corridor more readily than the CAN.       Also, the                                      access to calving areas for predators by developme'nt (Bergerud 1985).

                         PCH caribou should cross rather than be funneled by the corridor because                                              Even If the calving animals are displaced southwards by the
                         caribou should not be easiiy deflected when undertaking directionaL                                            corridor, the PCH can remain a viable herd-if predator populations are

                         shifts to antiprodator and mosquito-reLief habitat.                                                            managed.  It to an Incredible omission in this Impact statement that
                                Certainly, every effort must be made to allow the animals to                                            predator management was not mentioned.    The reduction of wolves is our
                         continue to use all their potential space to avoid predators.       Initially,                                 major tool to improve calf survival.    Wolves would not necessarily have
                         until the impact of the corridor is understood. traffic will have to be                                        to be reduced on the Coastal Plain.    Control operations could take Piece
                         prohibited in the period hay 15-Jun* 10 within several miles of cows .                                         on the winter range. The goal would be to have recruitment equal
                         moving west or north towards the road.     Another effort to mitigate the                                      natural mortality + hunting mortality. which means, for the Porcupine
                         effect of the corridor should. be to reduce Its visual impact as seen by                                       hard, that about 12% of the herd should be yearlings in AprLI-May
                         animals entering the are& (moving north and west). Once in the area* the                                       (Bergerud and Elliot 1986). This oil d*ve    ILopment may provide advantages
                         animals will find their way out.    If ramps are built they are more                                           for predators.  Once we disturb the status-quo, we must be prepared to

                                                                                                                                        . n... rh- predators. This management is the fait-safe position.
                         important on  the south side of the road than on the north side. Murphy
                         and Curatoto  (in press) have shown that disturbance is greater when there                                            I believe that the P  ICH will cross the haul road in seeking mosquito
                         is an active  road combined with 4 pipeline.    Theoretically, the vehicle                                     relief along the coast.   The cow and calf that CuratoLo (1986)
                         appears as a  predator - and the pipeline as the ambush cover. The                                             radio-tracked in the CAII hard crossed the road 8 times in one mosquito
                         pipeline and  haul road should be separated by at least I km with the                                          season.  Once a Large hard starts across it will continue even if a
                         pipeline north of the road. Pipelines should be cryptic (painted &teen                                         vehicle approaches. Certainly Large herds moving west and north will
                         and brown), be motionless and scentless.                                                                       hove to be monitored hourly as they approach the corridor and &it traffic
                                Another potential Impact Is that the road facilities will increase                                      hatted or rerouted. However. even it the animals did not cross       .and gain
                         predator access to the hard.    Wolves can be expected to move north down                                      the coastal strip, I believe that the hard wuoutd be little affected in
                         river valleys and then so  Ive laterallyt using the road to cross rivers                                       Its. vitality.
                                                                                                                                         . I   The one fact that we cannot escape is that the wilderness character
                         east and west. The cows, by calving between north-south river valleys.
                         have in the past taken advantage of the rivers as potential bar     .riers to                                  of the coastal plain will be lost for decades. The post calving
                         east-wast movements of prodaterso especially since the rivers are In                                           aggregation of the Porcupine Herd to the "at spectacular large wa@l
                         f:t.@e jr. ,&to may and early Jurs.  We do not vent tc in::vsse the ezse C,                                    display on the "orth American continent.     we must do all that we can to

    27

    see that this massing does not become a memory as did the thundering
    buffalo herds of the plaines.  The animals should continue to mass in the
    undisturbed KIC lands, adjasent to the coast, in a wilderness setting.
    Because I believe caribou can coexist in close proximity to an
    ethical man.  I look forward to the day when I can go on a guided tour
    down the HAUL road and view this massing of the mighty legions in July.
    The day will surely come when the old rigs will have been dismantled,
    the pipes disassembled, the scars left to heel, and the wind again
    sweeps unrestricted across the cotton grass plains.  The caribou will
    still be there in uncounted numbers, coming as always down their
    ancestral tracks, and, we too will be there to see and marvel at the
    majestics of our fellow species.

    28

    REFERENCES

    ANDREWARTHA, H. C. and L. C. BIRCH. 1934.  The distribution and
    abundance of animals.  Univ. of Chicago Press. 782 pp.
    BENSON, C. S. 1969.  The seasonal snow cover of Arctic Alaska. Research
    Paper No. 51. Arctic Inst. of North America, 86 pp.
    BERGERUD, A. T. 1971.  The population dynamics of Newfoundland caribou
    WILDL. Monogr. No. 25. 35 pp.
    BERGERUD, A. T. 1974b.  The role of the environment in the aggregation,
    movement and distrubance behaviour of caribou.  I.U.C.N.
    Publications, New Series No. 24:552-584.
    BERGERUD, A. T. 1980.  A review of the population dynamics of caribou
    and wild reindeer in North America.  2nd Int. Reindeer/Caribou
    Symp. 356-381.
    BERGERUD, A. T. 1985.  Antipredator strategies of caribou: dispersion
    along shorelines.  Can. J. 2001.  63:1324-1329.
    BERGERUD, A. T., N. E. BUTLER, and D. R. Miller, 1984.  Antipredator
    tactics of calving caribou: dispersion in mountains. Can. J. 2001.
    62:1566-1575.
    BERGERUD, A. T. and J. P. ELLIOT. 1986.  Dynamics of caribou-wolf
    fluctuations in British Columbia, Can. J. 2001. 44:1515-1529.
    BERGERUD, A. T., R. D. JAKIMCHUK, and D. R. CARRUTHERS. 1984,  The
    buffalo of the north: caribou (Rangifer taraudus) and human
    developments.  Arctic 37:7-22.

    29

    BERGERUD, A. T., E. MERCER, K. CURNEW, and M. NOLAN.  1983.  Growth of
    the Avalon caribou herd.  J. WILD. Manage. 47:989-998.
    CAUGHLEY, G. 1977.  Analysis of vertebrate populations.  John Wiley and
    Sons.  N.Y. 234 pp.
    CRINGAN, A. T.  1956.  Some aspects of the biology of caribou and a study
    of the woodland caribou range of the Slate Islands, Lake Superior
    Ontario.  M.A. thesis, University of Tronto.  300 pp.
    CURATOLO, J. A. 1985.  Sexual segregation and habitat use by the Central
    Arctic caribou herd during the summer.  2nd North American Caribou
    Workshop, Val Morin, Quebec.  pp. 193-198.
    CURATOLO, J. A.  1986.  Evaluation of satellite telemetry system for
    monitoring movements of caribou.  Rangifer Special Issue No. 1:
    73-79.
    CURATOLO, J. A. and D. G. ROSENEAU.  1977.  The distribution and movements
    of the Porcupine Caribou Herd in northeastern and the
    Yukon Territory 1976.  Unpubl. Rept. Renewable Resouces
    Consulting Service Ltd.  59 pp.
    DAU, J. R. and R. D. CAMERON.  1986.  Effects of a road system on caribou
    distribution during calving.  Rangifer Special Issue No. 1:95-101.
    FERGUSON, S. H. 1982.  Why are caribou on Pic Island?  M.Sc. thesis,
    University of Victoria, Victoria B.C. 171 pp.
    KUROFAT, P. and J. P. BRYANT. 1980.  Foraging behavior of cow caribou on
    the Utukok calving ground in northwestern Alaska.  2nd Int.
    Reindeer/caribou Symp. Roros, Korway. pp. 64-69.
    LENT, P. C. 1966.  Calving and related social behavior in the barrenground
    caribou.  Zeit. Tierpsychol. 23:702-256

    30

    LENT, P. C. 1980.  Synoptic snowmelt pattersn in arctic Alaska in
    relatin to caribou habitat use.  2nd Int. Reindeer/caribou
    Symp., Roros, Horway. pp. 71-77.
    MURPHY, S. M. and J. A. CARATOLO. (in press - 1987).  Behavior of
    caribou during summer in the Prudhoe oilfield, Alaska.  Can.
    J. Zool. (in press).
    ROBY, D. D. 1978.  Behavioral patterns of barren-ground caribou of the
    Central Arctic Herd adjacent to the trans-Alaska oil pipelines.
    M.Sc. 1980.  Comparative summer feeding strategies of arctic and
    alpine Rangifer. J. Anim. Ecol. 19:81-98.
    SKOGLAND, T. 1986.  Density dependent food limitation and maximal
    production in wild reindeer herds.  J. Wildl. Manage. 50:314-319.
    SKOOG, R. O. 1968.  Ecology of the caribou in Alaska.  Ph.D. thesis.
    University of California, Berkeley.  699 pp.
    WALTERS, C. J., R. HILBORN, R. PETERMAN, M. JONES. and B. EVERITT. 1979
    Porcupine caribou workshop draft report on submodels and scenarios.
    Unpubl. Rept. Institute of Animal Resource Ecology.  University
    of British Columbia, Vancouver. 42 pp.
    WHITE, R. G., B. R. THOMSON, T. SKOGLAND, S. J. PERSON, D. F HOLLEMAN and
    J. P. LUICK. 1975. Ecology of caribou at Prudhoe Bay, Alaska.
    Biol. Papers, Univ. of Alaska, Fairbanks, Spec. Rept. No. 2:151-187.

    Migration and antipredator spacing in caribou/reindeer

    by

    A. T. Bergerud

    Department of Biology, University of Victoria, Victoria, British Columbia,
    V8W 2Y2, Canada.

    2

    Advances in understanding the reproductive fitness of polygynous
    mammals have been rapid since Trivers  emphasized the different reproductive
    roles of the sexes.  The fitness of females in enhanced by endeavors that
    increase the survival of young: while male effort is directed at activities
    that maximize advantages in intresexual competitoin .  These different sexual
    strategies can help us evaluate the relative importance of antipredator
    tactics vs optinal foraging prodictions in the divergent behaviour of the
    sexes.  The data presented here suggest female reindeer/caribou (Rangifer
    tarandus) of both tundtra and forest races seek enviroments away from
    predators at calving time.  These enviroments commonly have low phytomass
    and late plant phenology.  Males, to the contrary, in the spring seek
    evironments of high phytomass and early plant phenology were they maximize
    growth and condition; such locations are generally nearer to predator
    travel routes than the locations the females select for calving.  These two
    divergent strategies provide an explanation for spring migration and the
    segregation of the sexes in caribou and may have application to other
    ungulate species.
    The females of the tundra races in North America and the USSR migrate
    200-600 km in April and May to traditonal calving grounds, generally on the
    north and of each herd's annual range (Fig. 1).  The movements are
    directional and most important, perpendicular to the tree-line (Fig. 1). If
    the cows arrive early, they halt and remain until parturition.  Is the
    Northwest Territories, Canada, the growing season advances northeast in
    isoclines parallel to the tree-line.  The bulls lag behind    following the
    green phenology north .  AT the time the calves are born, the bulls are
    still >150 km southwest of the cows.  For the cows farther north, the

    3

    parturition.
    A similar north-south progression in phanology is evident in Alaska, as
    well as strong altitudinal effects.  I compared the diet quality of
    segregated males and females at calving time for three of these migratory
    herds in Alaska by means of fecal nitrogen analysis.  Fecal nitrogen has been
    used as a gauge for dietary digestibility and dietary protein for several
    species 6-9.  Caribou select plants high in nitrogen in the spring 10-11.  The
    females on the calving grounds had a lower quality diet than the males who
    in all three herds were located at lower elevations of farther south (Table
    1).  Males and females did not differ in fecal nitrogen where they shared
    the same range in a non-migratory herd on the Slate Islands, Canada (Table
    1).  These results are consistant with the measurements of weight-gain and
    fat deposits that show males resums positive energy balance in the spring
    prior to preparturient females 12,13.
    Calving grounds of tundra carlbou are not optimum for females in regard
    to food resources or favorable weather for neonates 4,14,16.  The grounds are
    generally elevated uplands with reduced phytomass, exposed to storms and with
    colder temperatures and later phenology than surrounding locales.  However,
    the calving locatinons generally have reduced snow cover because of
    topographic gradients 16,17.  These bare substrates provide a cryptic
    back-ground for newborn calves.
    These calving grounds are only optimum, I believe, relative to
    predation risk.  The migratory wolves (canis lupus) that depend on caribou
    commonly den near three-line or south of the calving grounds 16,18,19.
    Dens are rare on calving grounds 16,20, which have a reduced diversity of
    alternative prey.  Wolves whelp about the same time caribou calve.  When
    caring for young, wolves have a reduced cruising radius and generally cannot
    reach calving grounds.  Thus I believe cows should maximize their distance
    north of tree-line, where wolves and alternative prey including bulls, are
    more numerous.  Yet females should go no farther north than the locations
    that still have snow-free substrates providing crypsis for neonates and
    foraging for females.  Since these selected sites, the calving grunds,
    represent a small proportion of the total range, females aggregated there
    can reach densition >16 animals/km 2 15,16.  Tactics of the selfish herd may
    be a factor in this aggregating 21 but wolves can surplus kill young calves
    when caribou are abundant 22.  The chief advantage of such remote locations
    is a reduced encouter rate with their major predators, wolves.
    Since about 1976, radio transmitters have been placed on adults in 24
    herds of forest caribou in North America (Fig. 1) and new information has
    been secured for these less known populations on movements and distribution
    in the spring.  Like tundra animals, woodland females leave winter ranges up
    to 6 weeks before parturition and travel directionally 2 to 150 km at speeds
    of 2-9 km/day to calving sites to which they subsequently return in later
    springs 23-25.  Unlike tundra caribou, these females are generally solitary
    and dispersed at calving.
    Three patterns of alving females have been described. (1) In
    mountainous areas, woodland females move upslope and sisperse.  They often
    calve above the alpine tree-line on brown substrates where the brown calf is
    cryptic 10,24.  These habitats, like tundra calving grounds, have increased
    exposure to weather, reduced food resources and a later growing season than
    habitats at low elevations 10. (2) In non-mountainous regions with large
    lakes and archipelagoes, females seek small, scattered islands for
    A

    5

    pertutition, if the surrounding waters are free of ice 26,27.  These females
    remain on the islands throughout the summer and some islands can
    consequently become overgrased 28.  (3) in neither mountains nor island refuges
    are available, woodland females scatter widley, densities of <.05/km2 in
    homogeneous forest-bog complexes have been recorded 23,25.
    Behaviour patterns common to all three dispersed patterns are (1)
    females are least aggregated during calving than during and other period of
    their annual cycle (Table 2), (2) females remain stationary (hiding) during
    and after calving, with small home ranges (Fig. 2), and (3) the calving
    locations are widely scattered 23-28 (Fig.2).  Woodland bulls, like tundra
    bulls, remain in early greening plant communities (lower elevations) with
    greater phytomass than calving habitats 10,24.
    The forest/mountain females by moving upslope maximize the distance
    between themselves and wolves traveling in the valleys 10,24.  Further,
    moose (Alces alces) calve below tree-line and are encountered first by
    predators moving upslope searcing.  Cows on islands are extremely safe
    since they are widely spaced across barriers and have water for escape if
    discovered.  Females in the more southern woodland populations do not have
    sufficent space above tree-line to migrate completely away from wolves
    and alternative prey (spacing-away), but they space-out to more remote
    habitats less travelled by predators.  By being rare, they should reduce
    searching effort by predators.
    Thus, I propose that the evolutionary or ultimate reason for the
    migration of females is not to reach a specific area (the calving ground)
    but rather to leave their predators behind.  The proximate response is
    philopatry to a traditional calving location, solitary and dispersed in

    6

    forest animals (spacing-out) and aggregated and clumped in tundra animals
    (spacing-away.  The enviromental factors of available space and the
    distribution of their chief predator, wolves, have paced the divergence of
    these two tactics of a common anti-predator strategy.  lastly, I not that
    saiga (Saiga taterica) females also make long migrations in the USSR to
    common parturition sites where predators are rare 29,30 and that the sexes of
    many other species of ungulates are segregated in the spring at parturition
    time.  In these instances, the optimal foraging and predation risk
    hypotheses should be tested as possible explanations.  I thank Jim Davis,
    Patrick Valkenburg and Heather Butler for their assistance.

                                 vast* I   rd
                                                 St nitrogen is ff"es as are" Pl"gs L                  CO-Psr" at -81-4-9 bet..*,
                                    semi*@ and miss 40 the slot@ logged@. Dangle (Imales ase .I*S sot Segregated) and hr.,
                                    O19wat49F bards to Aledw whars Coming wage aftesprod an calving &eased@ ved 0,102 wtro                                                                    c
                                                                                                                                                                          2       11    C                                      11    z    11
                                                                                                                                                                                  Is                                                                                      S,
                                    at lone Olawations     I INS Seem assets.

                                                                                                                                                                   cr
                                                                                                                                                                          14                                         .9  n          4     Is   C6
                                    Nord                    Need Location             go            Percent                  t-t.8t
                                                         lotsws@. tmg&&"*         begmen             (e"I                     of                                                                                         r
                                                                                                                                                                                  0
                                                                                                                                                                                                                     n
                                                                                                                                                                                                                         "     ;    "D    n-
                                                                                                                                                                                                              n      o   a    ow          0
                                 Collection                  a elevation                          Nitrogen                differvato

                                                                                                                                                                                                        0
                                    40tes               29               .4                                                                                                                             -
                                                                                      ?       ft

                                                                                  a
                                                                                  ,"seat                                                                                                                                                                                  1.0
                                 Rate Islas"          As*. ar         49% 67-         a  3.69 * 0.014 3.76 t 0.73         t    0.67t                                                    4A   %a                                                                           469
                                 early Jam                    1413-212W                       (38)*           (17)        sot sign                                                                  . . . . . . .                                        c
                                                                                                                                                                                                                                                         C6               0
                                 Delta need. Ak       AA-. &A?-       W. Me           so 1.78 t 0.061    2.32 a 0.117     t - 6.369                                                                                                                                       a
                                 rAy 17-36             sagas             "a a                 (22)            (16)        p 4 0.0003
                                 For"Je. Alt         ar. IAb-              143.       is 1.03 a 0.031    2.14 a 0.079     c: - MIN                                 0                   - - - - - - - -
                                                                                                                                                                                                        c:
                                 fty 27 - in" a       10506              725 a                                (10)        p 4 0.0002                               00                                                                                    on.
                                 ves"We Antis. Ah 69*301.     IGG-   ".. In* ISO         I." a 0.031- 2.14 A 0.026        c   4.2"4
                                 Jam 4-12              In a              300w                 (35)            419)        F   0.0005

                                                                                                                                                                                                                                               a-                         to
                                                                                                                                                                                                              S-                               to                         a
                                 ottgoges Is Gress pleetabon                             2.10 a 0.346 3.39       0.378    t   2.152
                                 "so eaces that day Is Aladw                                  (7)             (1)         F 4 0.05

                                                                                                                                                                                                                                                                          cr
                                                                                                                                                                                                                                                                          c
                                 !,.V" also                                                                                                                                                                                                             a
                                 'foral signs" low 3 o"Werms yeantiess On do calving around me 1.16 2 0.074                                                                                                                                                   X
                                 seft
                                    great" Includes ter =test Istolo po"Wifece, satin app.. arsomid see"$. and                                                     0
                                 artoonne mmmstrosim leaves me cle@ema"l for Conote$. Meekness gleffescauces                ead
                                                                                                                                                                   0
                                                                                                                                                                   c
                                 Ingeng. Salim ma -DfM uleartfolse. visbass, -in" ter Iowa" Van Kr1eM11OwMM it-we.                                                                                                                                                        CC
                                                                                                                                                                   ;6
                                 2.35 (way 20. Delia). 2.86 (juse 7. western Antis). and thrre. 2.44 (Jam a. reetystle).                                           to                  Ob   0     UP    a    c-      0        a,   w
                                                                                                                                                                   L     C,
                                                                                                                                                                                                                                                                          00.
                                 410"s Volvo for ftaft "To !Luz. 4-64 (any 29. 001"). 3.03        (Key 37. fortrate).
                                                                                                                                                                                                                                                                          -0
                                 utemberm neven. 2.n time a. ususen &fttgg). Many =108 ON thin Weatarn Avctie hard at*                                                                                                                                                    c
                                 %salve tub Selig bet a      amid sot be sellosted.                                                                                c                                         $A
                                                                                                                                                                   Mr                                                                                                     00

                                                                                                                                                                   c
                                                                                                                                                                   0

                                                                                                                                                                                  r.   ck                    a,      a, w          CD

    LITERATURE CITED

    1.  Trivers, R. L. in Sexual Section and the Descent of Man, 1871-1971 (ed
    Campell, B.) 136-179 (Aldine, Chicago, 1972).
    2.  Clutton-Brock, T. H., guiuness, F. E., & Albon, S. D. Red Deer: Behaviour
    and Ecology of Two Sexes (Chicago Press, Chicago, 1982).
    3.  Kelsall, J. P. The Migratory Barron-Ground Caribou of Canada (Queen's
    Printer, Ottawa, 1968).
    4.  Skoog, R. O. thesis, Univ. California (1968).
    5.  Whitten, K. R. & Cameron, R. D. in Reindeer/Caribou Symposium II, Norway
    (eda Relmers, K., Gaare, E. & Skjenneberg, S.) 159-166 (Direktoratat for
    vilt og ferskvannafisk, Trondheim, Norway, 1980).
    6.  Lancaster, J. Nature 163, 330-331 (1949).
    7.  Herbert, D. M. thesis, Univ. British Columbia (1973).
    8.  Leslie, D. M. & Starkey, E. E. J. Wildl. Manage. 49, 142-146 (1985).
    9.  Nieminen, M., Kellokumpu, S., Vayrynan, P. & Hyvarinen, M. in Reindeer/
    Caribou Symposium II, Norway (eds Reimers, E., Gaare, E., & Skjenneberg,
    S.)213-223 (Direkcoratet for vilt of ferskvannafisk, Trondheim, Norway
    1980).
    10. Bergerud, A. T., Butler, H. E. & Miller, D. R. Can, J. Zool. 62, 1566-
    1575.
    11. Leader-Williams, N. thesis, Univ. Cambridge (1980).
    12. Leader-Williams, N. & Ricketts, C. Oikos 38, 27-39 (1982).
    13. Dauphina, T. C. Jr. Biology of the Kaminuriak Population of Barren-Ground
    Caribou. pt. 4. Canadian Wildlife Service Rept. Ser. 38 (1976).
    14. Burgerud, A. T. J. Wildl. Manage. (in the press)
    15. Parker, G. R. Biology of the Kaminurisk Population of Barren-Ground
    Caribou pt. 1. Canadian Wildlife Service Rept. Ser. 20 (1972).
    16. Fleck, E. S. & Gunn, A. Characteristics of Three Barren-Ground Caribou
    Calving Grounds in the Northwest Territories (NWT Wildlife Service,
    Yellowknife, NWT, 1982).
    17. Lent, P. C. in Reindeer/Caribou Symposium II, Norway (eds Reimers, E.,
    Gaare, L., Skjenneberg, S.) 71-77 (Direktoratat for vilt og
    ferskvannafisk, Trondheim, 1980).
    18. Jacobsen, R. Wildlife and wildlife habitat in the Great Slave and Great
    Bear Lake Region 1974-1977 Environment Studies No. 10 (ALUR, Dept. of
    Indian Affairs and Northern Development, Ottawa, 1979).
    19. Kuyt, E. Food Habits and Ecology of wolves on Barren-Ground Caribou
    Range in the Northwest Territories Canadian Wildlife Service Rept. Ser.
    21 (1972).
    20. Miller, P. L. & Broughton, E. Calf Mortality during 1970 on the Calving
    Ground of the Kaminuriak Caribou Canadian Wildlife Service Rept. Ser.
    26 (1974)
    21. Bergerud, A. T. in The Behaviour of Ungulates and its Relation to
    Management (eds Geist, V. & Walther, F.) 552-584 (IUCN Publ 24, Vol II,
    Morges. Switzerland, 1974).
    22. Miller, F. L., Gunn, A. & Broughton, E. Can. J. Zool. 63, 295-300 (1985).
    23. Fuller, T. K. & Keith, L. B. J. wild. Manage. 45, 197-213 (1981).
    24. Edmonds, E. J. & Bloomfield, M. A Study of Woodland Caribou (Rangifer
    tarandus caribou) in WEST Central Alberta (Alberta Energy and Natural
    Resources, Edmonton, Alberta, 1984).
    25. Brown, W. K. thesis, Univ. Waterloo, Ontario (1986).
    26. Shoesmith, M. W. thesis, Univ. Manitoba, Manitoba (1978)
    27. Simkin, D. W. A Preliginary Report of the Woodland Caribou Study
    Ontario (Ontario Dept. Lands For. Sec. Rept. No. 59, 1965).

    28. Ferguson, S. H. thesis. Univ. Victoria, Victoria, B.C. (1982).
    29. Bannikov, A. G., Zhirnov, L. S. Lebedeva, L. S. & Fandeov, A. A.
    Biology of the Saiga (Israel Program for Scientific Translations,
    1961).
    30. Baker, R. R. The Evolutionary Ecology of Animal Migration (Hodder
    & Stoughton, London, 1978).

    Figure 1.  The sigration of females in tundra herds in the spring is at right
    angles to the tree-line.  Cows return to calving grounds on the northern edge of the
    population's distribution and generally beyond the range of wolves that
    den at or near tree-line (spacing away).  Bulls remain farther south
    feeding on early greening plant growth.

    Figure 1.  Five woodland caribou females returned in spring migration to
    individual calving locations at high elevation.  The cows were
    spaced-out from each other and had restricted home ranges.  The bulls
    were at lower elevations feeding on new plant growth.  The cows calved
    at maximum distances form alternate prey, moose, and wolves and bears
    hunting at lower elevations.  Data are adapted from studies by Edmonds
    and Bloomfield 24 in Alberta.

                                       MounTASIS
                                                       ftr4t *as                                                     INS
                                         ISO                                                                          N

                                                                                                                          1.0

                                             "of""
                                              me

                         fb

             d"U'vas
               ALPIN't

                TUK*A MOD
                CAAM" WOCUND A
                    WOMIMV      -Rom - no
                RAMO-TOACMS S"WISOCOL
                soooo CAMISM

    ABSTRACT

    Survival of caribou (Rangifer tarandus) calves until 4 months of age
    was monitored for 8 years in 4 herds in northern British Columbia, Canada.
    The chief cause of mortality was predation by wolves (Canis lupus) and
    grizzly bears (Uraus arctog) and this mortality was correlated within
    years between all herds.  More calves died in years with late springs
    when extensive snow patches remained during calving in June than in early
    springs when larger snow free areas existed.  Cow caribou prior to
    calving and after birth sought to space-out on snow-free areas in small
    aggregations at high elevations above treeline.  By being high, the
    females increased the distance between themselves and wolves and bears
    travelling valley bottoms as well as the main alternate prey moose (Alces
    alces) that calved only in forest cover at lower elevatioins.  Also with
    early springs the reduced snow meant more space for dispersion.  The
    variation in calf survival for 3 herds was negatively correlated with the
    heterogeneity of the calving area.  Snow cover disappeared in smaller
    patches in more rugged mountains regardless of spring phenology therein
    providing a more constant search area for predators between years.  More
    uniform mountains had either extensive areas of snow cover (late years)
    or brown substrates (early years). thus greatly varying the space
    predators had to search between years.  As stochastic variation in snow
    cover at calving time alters the searching ability of predators, the
    aggregation responses of prey and the apatial overlap between predators
    and prey, it promotes shor-term stability of tye prey and lessons the
    probability of extinction.

                             C. J. Zool.

    Displacement and dispersion of Parturient Caribou at Calving as
    Antipredator Tactics

    A. T. Bergerud, Biology Department, University of Victoria, Victoria,
    B.C., Canada V8W 2Y2

    R. E. Page, Research Branch, Ministry of Forests, Victoria, B.C.,
    Canada V8W 3Z7

    3

    INTRODUCTION

    A central problem in predator-prey ecology is the behavioural
    responses of prey to the distribution of predators.  Prey attempt to
    avoid areas where predators search (reviews by Stein 1979, Morse 1980,
    Sih 1982) whereas predators concentrate in areas of high prey densities
    (reviews by Hassell 1978, Cowie and Krebs 1979).  If the predators are
    relatively mobile, the predator response should dominate.  But what
    response should dominate if both predators and prey are moible such as
    caribou (Rangifer tarandus) and wolves (Canis lupus)?  With both prey and
    predators mobile the responses could cancel each other (Sih 1984).
    Yet another possibility could be that the extrinsic enviroment would
    intervene, at one time favoring the movement of the prey yet later the
    predator.
    The paradox of why predators rarely cause the extinction of their
    prey in the real world as they do in the laboratory also remains of
    theoratical interest.  Murdock and Datan (1975) point out that laboratory
    experimental and mathematical modelling have outstripped empirical field
    studies.  Field studies in turn have emphasized invertebrate systems
    where the predator is generally more mobile than the prey.  Further,
    Murdock and Osten in their review state (p. 13)"...we have no
    explanation for the stability of most systems...".  This study should
    contribute to predation-stability theory as it pertains to a highly
    mobile, mammal predator-prey system.
    We studied a wolf-bear (Uraus arctos) caribou-moose (Alces alces)
    system in northern British Columbia from 1976 to 1983.  Pregnant caribou,
    in this system, leave valley bottoms which are travelled by wolves and
    bears just prior to calving and disperse into mountains as an
    antipredator tactic while nonproductive caribou remain at low elevations
    (Bergerud and Butler 1978, Hatler 1982, Bergerud et al. 1984, Page 1985).
    The calves of cows that moved to valley bottoms in June suffered greater
    mortality from Wolf and bear predation than those that stayed high
    (Bergerud et al. 1984).  We hypothesize that the success of the predator
    avoidance strategy depends, in order of importance, upon (1) the distance
    that the females can space from the travel rowtes of predators and
    alternative prey (displacement). (2) the dispersion of the cows, and
    (3) the extent of cryptic brown space (snow free areas) available for
    dispersion and crypsis.  The main alternative prey, moose, scatter into
    forest cover at lower elevations at calving.  The behavioural response
    of predators looking or caribou in turn should vary with the space they
    must search as it affects the relative profitability of hunting moose or
    caribou.

    METHODS

    Caribou in northern British Columbia traditionally gather on the
    plateaus above timber-line in the fall prior to breeding, allowing a
    near-complete serial census.  Four herds discussed in greatest detail
    are (1) Spatisi - these animals congregate on Caribou Mountain and
    nearby Tomias Mountain (approx. 57 30'N, 128 W, see Boonstra and
    Sinclair 1984); (2) Level Mountain - 38 30'N, 131 W, (3) Kawdy - 59 N,
    131 W - these aninals also aggregate near Badman Point 59 N, 130 W and
    (4) Horseranch - 59 13'N, 128 30'W.  All the herds calve high in the
    mountains.  The distance between calving locations is approximately 80

    km between Level and Kawdy, 240 km between Kawdy and Spatsiri, 200 km
    between Level and Spatsisi, and 15 km between Kawdy and Horseranch.
    Horseranch was an experimental population where wolves were reduced for
    3 years (1978, 1979 and 1980) (Bergerud and Elliot 1986).
    We monitored the summer servival of calves in these four herds from
    1976 to 1983 to investigate factors limiting population increase.  Our
    basic technique was to measure recruitment when the new generation was
    >4 months-of-age in the last week of September and the first week of
    October.  If a helicopter was available the animals were classified as
    to calvs, cows, and bulls and recruitment was based on calves/100   .
    If only a fixed-wing aircraft was available caribou were classified only
    as to calves, large bulls, and others, and recruitment was based on the
    percentage of calves of total animals.  Radio-tracking investigations by
    Hatler (1985) have shown that males and females are least segregated at
    this time in the annual cycle.
    To determine the causes of early mortality calves <3 days old were
    captured and radio-equipped with collars that sent a mortality signal
    if the calf was motionless for >4 hours.  Ten calves were monitored at
    spatsisl in 1979, a late spring, and 23 calves were monitored at Level
    Mt. in 1980, an early spring.  The calves were weighed and notes taken
    on the birth site and the reunion sequence with the dam.
    At spatsisi in 1977 and 1979, we classified the reproductive status
    of females (> 2 years) from the ground in June by presence or absence of
    a distended udder and wether a calf was at heel.  Females were similarly
    segregated from a helicopter at Level Mtn. in 4 years, from 1978 to 1981
    at the end of calving about June 10.

    6

    A meterological statistic was needed as an index to the percentage
    of mountain slopes covered with snow during calving in early June. We
    wished to quantify the extent of cryptic backgrounds (brown substrates)
    available for the dispersion of expectant females spacing-out from
    predators.  Landsat satellite photographs were available only in 1977
    and 1978.  Cloud cover obscured the ground in late May and early June in
    the other years.  Our promary index was the April 1 water equivalent of
    snow pack measured at Dease Lake, B.C. (58  26' N, 130  01'W).  WE had
    to use the April 1 statistics since Dease Lake, at only 820 m elevation,
    never had snow remaining by June 1,  Dease Lake is within 100 km of the
    mountains used by all but the Horseranch females.  In 1980, a new snow
    station was established in the Eaglenest Mountains (57  37  N, 129  01
    W) at an elevation of 1540 m.  Some females that aggregate in the fall at
    Cairbou Mountain calve is the Eaglenest Range at elevations of 1400 m and
    above (Hatler 1982).  WE compared these June 1 water equivalent readings
    from the Eaglenest with calves/100 females from 1980-83.
    A seasonal snow statistic that we used to gauge the overall severity
    of the winter was the average snow dept remaining at the end of each
    month.  We combined the readings from stations at Dease Lake, Iskut and
    Cassiar.
    The wolf population near Level Mountain was censured in 4 winters
    from 1977-81 by D. Hatler (Bergerud and Elliot 1986).  At spatsisi wolves
    were counted in the winter of 1977-78 (Bergerud and Butler 1978) and
    again in 1979-80 (Page 1985).

    RESULTS

    Annual variation in calf survival

    WE found that there were large annual variations between years in
    the percentage of calves in the three control herds and these variations
    were correlated (Fig. 1).  These variations held whether recruitment was
    expressed as either the percentage of calves of total animals or as
    calves per 100 females (Fig. 1).  These variations were not aritifacts
    of sampling since we generally segregated calves and adults in 50% or
    more of the entire estimated population so that percentages differing
    by >3% were statistically different based on limits statistics.
    The large annual variations in recruitment were not explained by
    changes in reproductive rates.  The main percentages of females (>
    2-year-of-age) giving birth to calves in 3 years was 84   2.6% (CV -
    only 8%) for 2 of the study herds (Fig. 2).
    However by 2 weeks after the first calf was born in these 2 herds
    there were only 38   8.5 calves per 100 females (CV - 54%) or a mortality
    rate of 55% by 1-2 weeks of age.  We could not find the bodies of the
    missing calves and feel that the calves were completely eaten by bears
    and wolves.  An analysis of the scats of bears and wolves showed that
    they contained beef and skull fragments of calves suggesting 100%
    utilization of calf carcasses (Page 1985. Bergerud and Elliot 1986).
    The major cause of death of calves in their first summer in
    British Columbia was predation by bears and wolves.  We documented this
    by observing predator chases (Bergerud et al. 1984), scat analysis
    (Page 1985) and an experiment in which wolves were removed at Horseranch
    (Bergerud and Elliot 1986).  When we visited the sites where the

    3

    radio collared calves died we generally found only the bitten collars,
    calf hair, and smell pieces of skin (Page 1985).  Page (1985) estimated
    that probably 12 of the 17 deaths of calves with radios were due to
    predation.
    One hypothesis we considered was that the viability of calves
    hence their susceptibility to predation, could vary depending on the
    previous winter's severity and maternal nutrition.  To the contrary, the
    34 young calves we captured struggled vigorously and generally weighed
    8-9 kg which is approximately 3 kg greater than calves in the Arctic
    (pers. files).  There was no significant difference in the weight of
    <1 day old calves between 1979, a hard winter and late spring, and
    1980 a mild winter and early spring (8.0   0.75 vs. 9.3   0.55 kg,
    t - 1.45, n - 16).
    An analysis of varience of the mean winter snow depths and the
    percentage of calves in the herds in the fall for all populations (the
    three control populations and Horseranch where wolves had been removed)
    was significent (F - 4.26, 24 df, P - 0.0168).  However, the influence
    of the experimental removal was also significant (F - 3.10, 1 df, P -
    0.097).  Thats is, Horseranch, in contrast to the control herds, had
    practically the same proportions of calves regardless of snow depths in
    3 winters when wolves were removed )16.7, 17.2, 16.1%) vs. greatly
    reduced percentages when wolves were present (6.3, 10.9, 4.2 and 6.0%).
    The significance of snow cover on calf percentages was improved with the
    removal of the variance from these three experimental cohorts (F - 8.09,
    P - 0.0097).  The interaction of control and experimental populations
    was not significent (P - 0.2193).  Thus, we rejected the hypothesis

    9

    that variations in snow cover acting through maternal condition and
    neonats viability were the explanation of variation in calf survial on
    the three control areas.  In the absence of wolves there was little
    effect of weather on summer calf servival.
    We could not explain the annual variations nor the correlations in
    the annual survival of calves between populations on the basis of changes
    in the abundance of predators or alternative prey.  We saw grizzlies
    hunting calves in all years we were in the field.  There was no obvious
    change in bear abundance.  The number of wolves censured in the winter
    adjacent to Level Mountain were:  1977-78, 49-54, 1978-79. 43-44+;
    1979-80, 44-46 and 1980-81, 46-50+ (Bergerud and Elliot 1986).  We
    counted 72 wolves in spatsisi 1977-78 and 43 wolves in 1979-80.  The
    estimated moose density near Level Mountain was:  January 1979, 0.34/km-2,
    March 1980, 0.24/km-2 and February 1981, 0.18.km-2.  None of the values
    were statistically different (Elliot et al. 1984).  The moose population
    near the Horseranch Range, also showed no statistical difference in two
    winter counts: 1979, 0.30/km-2, and 1980, 0.48/km-2 (Elliot et al. 1984).
    Even if there were changes in numbers of predators and/or alternative
    prey, they could not explain the sequence of runs in calf recruitment we
    generally noted from 1977 to 1983 (Fig. 1). Moose, wolves and bears, do
    not have life history parameters that would alter their numbers quickly
    enough to be reflected in the annual perturbations in the survival of
    caribou calves.

    Snow cover and survival

    The annual changes in calf survival were correlated with the extent

    10

    of the snow pack of DEASE Lake on April 1 (Fig. 3) and in the Eaglenest
    Mountain on June 1 (Fig. 4).  Calf survival was higher following springs
    (1978, 1980 and 1983) with reduced snow cover than in years with more
    snow cover in the spring (1976, 1977, 1979, 1981 and 1982).
    We tried to correct the water equivalent readings at Dense Lake for
    subsequent melt from April 1 to June 1 using the mean daily temperature.
    However these corrections did not improve the correlation between the
    April snowpack and calf survival shown in Fig. 3.  In fact, the mean
    April-May temperatures were negatively correlated with the April 1 water
    equivalent readings, r - 0.729, n - 8.
    In an early spring the extent of melted areas is considerably greater
    than in a late spring (Fig. 5).  Hence parturient cows can displace and
    disperse themselves farther into the mountains away from the travel
    routes of wolves and bears (Fig. 4, 5, Table 1).  The mean group size
    of cows with calves was less than that of animals without cales (Fig.
    6) as expected from a dispersal to scattered snow-free areas at high
    elevations.
    The annual variations in calf percentages within each of the 3
    control herds was correlated with topography.  When the mountains were
    uplifted as in Spatsisi (heterogenous) the variations in annual
    recruitment were less than when the mountains were volcanic (more
    homogeneous) as at Level Mountain (Fig. 7).  The topography at Horseranch
    was also uplifted and the coefficient of variation is recruitment for the
    4 years without control was 41%.
    The topography should affect snow accumulations and residual snow
    cover at calving.  The undulating topography at Level Mountain would

    11

    provide more wind swept surfaces and even accumulations of snow than
    would the more sheltered landscapes at Spatsisi.  Thus in an early
    year the patches of brown substrate would be larger at Level Mountain
    than Spatsisi (Fig. 8) which would require that predators search
    larger areas to locate caribou (Fig. 9.).

    DISCUSSION

    The maximum killing rate of a searching predator should depend on
    the product of three functions the rate at which the predator encounters
    groups of prey, the rate of detection of groups of various size, and the
    probability of a successful capture of a calf from a group once detected
    (Taylor 1981).  Maternal cows should take actions to reduce the success
    rates of wolves and bears in encountering, detecting, and capturing
    calves.

    Tactics to reduce encounters (Displacement)

    Regardless of group size, cows in mountains appear to space
    themselves maximally from predator travel routes along water courses
    (Bergerud et al. 1984, Edmonds and Bloomfield 1984, Hatler 1985).  This
    spacing sould also remove them from moose that are calving in forest
    cover at lower elevations and male caribou feeding at lower elevations.
    These strategies should increase searching time and decrease encounters
    with predators primarily hunting moose and nonproductive caribou (Fig.
    9).
    The movements of cows to alpine habitate to avoid predators
    resulted in these caribou grazing in habitats where the vegetational

    12

    phenology was several weeks delayed compared to that along watercourses
    at low elevations (cf. Edwards 1983).  This selection of antipredator
    habitats that are suboptimal for foraging is well illustrated by
    satellite photography (Fig. 5).  At the time of the photograph, on
    3 June 1978, the cows had dispersed away from the forest habitats and
    were located on the highest bare spots immediately below the snowline.
    The cross hatched areas (originally red on the Landsat photograph)
    represent new, green, flushing vegatation, mostly willow (Salix app.)
    along water courses at elevations below 600 m that the caribou have just
    left.  This new, green growth is highly nutritious and a preferred food
    of caribou in the spring (White et al. 1975, Skogland 1980, Boertje
    1981, Bergerud et al., 1984).
    This altitudinal shift is contrary to Klein's (1970) view that
    caribou follow altitudinal gradients coincident with plant phenology to
    optimally forage.  Cow caribou in British Columbia do move higher in the
    spring but this takes them away from the most nutritious food, to
    habitats where predation risk is reduced (Bergerud et al. 1984).

    Tactics to reduce detection (Dispersion and Crypsis

    Caribou that calve in forest cover are widely dispersed in small
    groups with cows frequently alone (Shoesmith 1972, Fuller and Keith
    1981).  These small groups should reduce conspicuousness.  In this
    study, the mean group size of groups with calves present was 2.4 (n -
    52) at Level Mountain (calves excluded).
    The group size of cows with calves did not change between 2 years
    in ths study despite variation in the space for dispersion (Table 1).

    13

    This constant group size suggests an overriding need to remain
    inconspicuous.  If groups size increased there would be a multiplicative
    loss of crypsis because of the need for cows and calves to communicate
    for identification.  We noted that when barren-ground caribou move in
    large aggregations calling is continuous.  Bears in the Arctic appear to
    orient to these vocalizations (pers. obn).
    Cows were generally on the south side of mountains with larger
    areas of brown backgrounds than north slopes (Fig. 5, 9).  Additionally,
    the prevailing southerly winds carried the scent of caribou to higher
    topography and away from the lower elevation where wolves were more
    common (Bergerud et al. 1984).
    Cows with calves in the mountains were also sadentary.  Five cows on
    Umbach Mountain at Specsizi remained there an average of 6 = 2.1 days,
    whereas 8 females in the valley bottom frequented by wolves stayed there
    only 2.9 = 0.8 days (Bergerud et al. 1984).  Reduced movement should
    reduce encounter rates with mobile predators. if an appropriate initial
    location has been chosen that minimizes encounters with those predators.
    Enhancment between multiple predators, rather than interference,
    should occur in ths system.  Any hiding cow-calf pairs flushed by a
    predator would become more conspicuous to other predators, since the
    flushed caribou would leave scent trails and cross new covered areas.
    Both bears and wolves hunt by searching large areas and can run faster
    than a young calf in rough terrain, hence the hiding tactic would be
    partially abrogated by a functional predator response.

    Tactics to reduce capture success

    14

    The chance of being captured when discovered should decline with an
    increase of group size because of shared-risk, mutual vigilance and
    improved lead time for escape (Bergerud 1974b).  The idea that an animal
    is safer when it can keep another animal between itself and its predator
    (the selfish herd concept) is now well recognized (Williams 1964,
    Hamilton 1971, Wittenberger 1961).  However, cows with young calves in
    British Columbia never form large herds as is common for migratory
    caribou.  This suggests that in the absence of complete displacement
    there is an need to ramain inconspicuous and escape detection rather
    than to depend on eluding capture after discovery.  Maternal cows were
    especially alert.  We noted on several occasions that in an adult group
    where there was only one calf, it was the mother of the calf that
    remained standing when the herd bedded.  These maternal cows also engaged
    in the most frequent "look-ups" when the groups fed.
    If cows aggregated, it might increase the success of capture by
    predators.  One behaviour of bears and wolves is to change herds, cows
    ans calves, in the confusion, have little time to reform maternal-filial
    pairs (pers. obs., F. Miller, pers. comm.) and calves can be left behind
    either sleeping or disoriented from their dams.  In the small groups in
    British Columbia females did not take flight until they had their calf
    at heel.  The cows generally know where the calf was bedded and were able
    to reunite quickly when rushed by a predator.

    General

    We compare the primary tactics of moose and caribou to counter the
    success of mobile predators, such as bears and wolves in Table 2. Some

                                                                                                                                                                                                                   15
                                                                                                    16

                      frequent areas where the major alternative Pray Of moose are relatively                                        caribou populations aggregate at calving and others, such as these In
                      scarce (fuller and Keith 1981, Bergetud -st -al. 1984, H. Cummings, Pais.                                      northern British Columbia, space-out. The aggregating caribou are
                      comm. ). If predators hun   t based on profitability theory (Royama 1970)                                      migratory. usually moving several hundred kilometers north of tree         line
                      then the specid-out animals can reduce encounter rates if they are scarce                                      prior to parturition. Wolves generally don near tree line (Kuyt 1972,
                      enough to be unprofitable to search for. Again, the basic strategy is                                          Jacobson 1979, Fl*ck and Cunn 1982). thus, aggregations an calving
                      to reduce encounter rates.                                                                                     grounds take place In an area of low wolf numbers (Kels&LL 1968, Miller
                           A Large asinaL such as carlbout even If fairly cryptic (Ipig- S)p                                         andI Broughton 1974). We term this displacement response, spacing-&vay.
                      will have a difficult time avoiding detection If It Is,withift the sensory                                     for migratory cows, the tactics of sharinl-rlsk, Increased vigilance and
                      range of predators to the open. However, vigilance gas provide a long                                          swarming would not suffice if the majority of the wolves followed the
                      lead time and a reasonable probability of escapa'if do     totted. The                                         caribou to the calving grounds. The few volves that are present on
                      anleat can then make a rapid move to a %" hiding area whets there are                                          calving grounds are able to kill calves at surplus love     Is (MLII*r at &I.
                      few predators and possibly again escape encountering predators for some                                        1985). Miller at at     (1985) have seen out wolf kill three calves in 6
                      time before being rediscovered.                                                                                minutes of hunting on a calving ground. Handling time is not a restraint
                           Moose. contrary to caribou, appear to rely    move on avoiding                                            in the functional response. The primary antiprodstor tactic of these
                      detection than on spacing to avoid ancountOTS1     cows bids their calves                                      migratory cows is displacement to reduce the encounter rates with
                      in forest cover (1.41;t 1974) and defend their calves (Table 3). Moose                                         predators, many of which remain farther south with alternative prey,

                      should also benefit from reductions in kill rates when caribou ate                                             including bull and yearling caribou.

                      common, since caribou *&Ives are such easier to kill than moose calves                                              If these large bards &too displayed dispersion they would be

                      (Haber 1977). wolves may switch from moose to caribou when caribou are                                         scattered nearer to tree line and abrogate the value of displacement.

                      common (Holleman and Stephenson 1981, James 1983). Predators would not                                         Spacing-away to most effective by being aggregated. It is the large

                      search for both prey simultaneously because of their different habitats.                                       space of the Arctic above tree line that permits the spacing-away option.

                      Thus, this I species prey system should have greater stability then a                                               The caribou that space-out rather than speco-away are the more
                      caribou only systems consistent with theory (Southwood 1975. Murdock and                                       sedentary woodland caribou. They do not have sufficient space above

                            1973, Hassell 1978).                                                                                          line for complete displscectnt; this Incomplete displacement has

                          The study extends the   principle, that habitat heterogeneity promote$                                     load to dispersion. Some bards *yen scatter in tree cover but the
                      stability In predator-prey  systems (Ruffacker 1938, Murdock and Oaten                                         caribou in this study spaced-out in the ppen.     both groups that space-out

    17

    1975), to mobile vertebrates.  Caribou populations commonly show little
    population change when calf recruitment equals 10-12% of the herd
    (Bergerud 1974a, Bergerud and Elliot 1986).  The mean percentage of
    calves for all three of our control study areas was 10-11% and the herds
    changed little from 1980 to 1983 (Bergerud and Elliott 1986).  However,
    the mean annual deviations from 10% were only 3% at Spatsazi vs. 6% at
    Level and Kawdy.  The more topographically diverse Spatsizi with enhanced
    patchiness had the most stable recruitment of the three study areas
    (> topography, > patchiness, > stability).
    Density independent stochastic variations such as snow cover
    intuitively should not be stabilizing (Hassell 1978).  However,
    stochastic variation may be less destabilizing than time logs (Bartlett
    1957, May 1973.  There have been long predator-prey oscillations in our
    system (Bergerud and Elliot 1986) and in other northern caribou-wolf
    systems (Skoog 1968, Haber 1977).  These escillations appear to result
    more from a numerical predator response than from changes in functional
    responses (Skoog 1968, Haber 1977).  Snow cover, as it affects relative
    prey densities (hence searching time and efficiency), appears to cause
    considerable annual variations in calf survival about long-term density
    trends.  Thus the stochastic variaton adds noise to the system.  But
    also, snow cover varies the distance between the subhabitats of moose and
    caribou, therin varying travel time and hunting profitability (promotes
    switching) for predators.  In the sense that this stochastic variation
    alters the aggregating response of prey and the spatial overlap of
    predator and prey, it promotes short-term stability and lessens the
    possibility of extinction (Hassell and May 1973, Murdock and osten 1975,
    southwood 1975, Beddington et al.. 1978).

    18

    ACKNOWLEDGEMENTS

    We would like to acknowledge the fact that D. F. Halter gathered
    the distribution, demographic, and wolf census data for Level Mountain
    for the four years 1978, 1979, 1980, and 1981.  Donald Eastman and the
    Fish and Wildlife Branch provided logistic support.  T. Skogland and
    Frankl L. Miller provided helpful reviews.

    Bartlett, M. S. 1957.  On theoretical models for competitive and
    predatory biological systems.  Biometrika 44, 27-42.
    Beddington, J. R., C. A. free and J. H. Lawton.  1978 Characteristics
    of successful enemies in models of biological control of insect
    pests.  Mature 273: 513-519.
    Bergerud, A. T. 1974a.  Decline of caribou in North America following
    settlement. J. Wildl. Managa. 38: 757-770.
                      1974b.  The role of the enviroment in the aggregation,
    movement and distrubance behaviour of caribou.  In The Behaviour of
    Ungulates and its Relationship to Management.  Edited by V. Geist
    and F. Walther. I.U.C.W. New SER. Publ. 24:552-584.
                    1985.  Antipredator tactics of caribou: Dispersion
    along shorelines.  Can. J. Zool. 63: 1324-1329.
                   , and H. E. Butler. 1978.  Life history studies of caribou
    in Spatsizi Wilderness Park.  Parks Branch Rept.,  Ministry of
    Recreation and Conservation, Victoria, B.C. 156 pp.
                                and D. R. Miller.  1984.  Antipredator
    tactics of calving caribou:  Dispersion in mountains. Can. J.

    19

    Zool. 62: 1566-1575.
                   and J. P. Elliot.  1986.  Dynamics of caribou and wolves
    in northern British Columbia.  Can. J. Zool. 64: 1515-1529.
    Boertja, R. D. 1981.  Nutritional ecology of the Donall caribou herd.
    M.Sc. thesis, University of Alaska, Fairbanks.  294 pp.
    Boonstra, R. and A. R. E. Sinclair.  1984.  Distribution and habitat
    use of caribou (Rangifer tarandus caribou and moose (Alcas alcas
    andersoni) in the Spatsizi Plateau Wilderness area, British
    Columbia. Can. Field. Nat. 98: 12-11.
    Cowie, R. J. and J. R. Krebs.  1979.  Optimal foraging is patchy
    environments.  In British Ecological Society symposium on population
    dynamics.  Edited by R. M. Anderson, B. D. turner, and L. R. taylor.
    Blackwell Scientific, Oxford. pp. 183-205.
    Edmonds, E. J. and M. Bloomfield.  1984.  A study of woodland caribou
    Rangifer tarandus caribou in west central Alberta, 1979-83.
    Alberta Fish and Wildlife Division, Edmonton, Alberta.  203 pp.
    EDwards, J. 1983.  Diet shifts in moose due to predator avoidance.
    Oecologia 60: 185-189.
    Elliot, J., D. Eastman, D. Hatler, and I. Matter.  1984.  Northern B.C.
    wolf-caribou study.  B.C. Ministry of Enviroment, Fish and Wildlife
    Branch, Victoria, B.C. 86 pp.
    Fleck, S. S. and A. Gunn.  1982.  Characteristics of three barren-ground
    caribou calving grounds in the Northwest Territories, N.W.T.
    Wildlife Serv., Yellowknife, N.W.T. Progress Rept. No. 7, 138 pp.
    Fuller, T. and L. B. Keith.  1981.  Woodland caribou dynamics in
    northeastern Alberta. J. Wildl. Manage. 45: 197-213.

    20

    Haber, G. C. 1977.  Socio-ecological dynamics of wolves and prey is a
    subarctic ecosystem.  Ph.D. thesis. University of British Columbia,
    Vancouver.  786 pp.
    Hamilton, W. D. 1971.  Geometry for the selfish herd. J. of theor.
    biol. 31: 295-311.
    Hassell, M. P. 1978.  The dynamics of arthroped predator-prey systems.
    Princeton Univ. Press, Princeton. N.J.
    Hassell, M. P. and R. M. May. 1973.  Stability in insect host-parasite
    models. J. Anim. Ecol. 42: 693-736.
    Hatler, D. R. 1982.  Studies of radio-collared caribou in the Spatsizi
    Wilderness Park area, British Colubmia.  Unpubl. Rep. for Spatsizi
    Association for Biological Res.  Smithers, B.C. 102 pp.
                1985.  Studies of radio-collared caribou in the Spatsizi
    Wilderness Park area, British Columbia, 1980-1984.  Unpubl. Rep. for
    Spatsizi Assocation for Biological Res. No. 3.  Smithers B.C. 226
    pp.
    Holleman, D. R. and R. D. Stephenson. 1981.  Prey selection and
    consumption by Alaskan wolves in winter.  J. Wildl. Mange. 45:
    620-678.
    Huffaker, C. B. 1958.  Experimental studies on predation.  I. dispersion
    factors and predator-prey oscillations.  Hilgardia 27: 343-383.
    Jacobson, R. 1979.  Wildlife and wildlife habitat in the Great Slave
    and Great Bear Lake Regions 1974-1977.  A.L.U.R., Dept of indian
    Affairs and Northern Development Ottawa, Environment Studies No. 10,

    21

    James, D. D. 1983.  Seasonal movements, summer food habits and summer
    predation rates of wolves in northwest Alaska.  N.Sc. thesis
    University of Alaska, Fairbanks.
    Kelsall, J. P. 1968.  The migratory barren-ground caribou of Canada.
    Queen's Printer, Ottawa.  340 pp.
    Klein, D. R. 1970.  Tundra ranges north of the boreal forest. J. Range
    Manage. 23: 8-14.
    Kuyt, E. 1972.  Food habits and ecology of wolves on barren-ground
    caribou range in the Northwest Territories.  Can. Wildl. Serv. Rep.
    No. 21. 30 pp.
    Lent, P.C. 1974.  Mother-infant relationships in ungulates.  In the
    behaviour of ungulates and its relation to management.  Edited by
    V. geist and F. Walther.  I.U.C.N. New Ser. Publ. 24: 14-55.
    May, R. M. 1973.  Time delay versus stability in population models with
    two and three trophic levels.  Ecology 54: 315-325.
    Miller, F. L. and E. Broughton. 1974.  Calf mortality on the calving
    ground of the Kaminuriak caribou.  Can. Wildl. Serv. Rep. Ser., No.
    26. 26 pp.
    Miller, F. L., E. Broughton and A. Qunn. 1985.  Surplus killing as
    exemplified by wolf predation on newborn caribou.  Can. J. Zool. 63:
    295-300.
    Norse, D. N. 1980.  Behavioral mechanisms in ecology.  Harvard Univ.
    Press.  Cambridge, Mass. 383 pp.
    Murdoch, W. W. and A. Oates.  1975.  Predation and populatin stability.
    Adv. Etol. Res. 9:1-125.
    Royama, T. 1980.  Factors governing the hunting behaviour and selection
    of food by the great tit (Parus major L.).  J. Anim. Etol. 39:
    619-659.
    Shoesmith, M. W.  1978.  Social organization of wapiti and woodland
    caribou.  Ph.D. thesis, University of Manitoba, Winnipeg.  155 pp.
    Sih, A. 1982.  Foraging stratagies and the avoidance of predation by an
    aquatic insect, Notenecta hoff     .  Ecology 63: 786-796.
           . 1984.  The behavioral response rate between predator and prey.
    Am. Nat. 123: 143-150.
    Skogland, T. 1980.  Comperative summer-feeding strategies of arctic and
    alpine Rangifer.  Anim. Ecol. 49: 81-98.
    Skoog, R. O. 1968.  Ecology of the caribou (Rangifer tarandus granti) in
    Alaska. Ph.D. thesis.  University of California, Berkeley. 699 pp.
    Southwood, T. R. E. 1975.  The dyanics of insect popul     .  In
    Insects, science, and society.  Edited by D. Pimentel. Academic
    Press, N. J. pp 151-199.
    STein, R. A.  1979.  Behaviroal respons of prey to fish predators.
    In Predator-prey systems in fisheries management.  Edited by
    R. N. Stro  , and M. Clepper.  Sport Fishing Inst., Washington, D.C.
    Taylor, R. J. 1981.                            destabilizing influence upon
    prey populations.  Am. Nat.  118: 102-109.
    White, R. G., B. R. Thompson, T. Skogland, S. J. Person, D. R. Holleman
    and J. R. Luick.  1975.  Ecology of caribou af Prudhoe Bay, Alaska.
    In Ecological investigations of the tundra biome in the Prudhoe Bay
    region, Alaska.  Biological papers of the Univ. of Alaska.  Special
    Rep. No. 2: 150-201.
    Williams, G. C. 1964.  Measurement of consociation among fishes and

    23

    comments on the evolution of schooling.  Papers of the Mus. of Mich.
    State Univ., Biol. Ser. 2: 351-383.
    Wittenberger, J. F. 1981.  Animal social behavior.  Duxbury Press,
    Boston. 722 pp.

    Table 1. Comparison of the locations of females at calving time on Level
    Mountain between a June with below normal snow and a year with
    average snow conditions.

    Displacement and		Extent of Snow

    Dispersion, groups	Below Normal	Average	Differences

    with & without		10 June 80		9 June 81	1980-81

    calves			mean % SE		mean % SE

    Mean elevation (m):

    With calves			1703   44.7 (16)	1533   47.3 (13)	170 1

    No calves			1596   31.7 (14)	1488   29.3 ( 1)	108

    Average distance from

    wolf routes (km):

    With calves			17.4   1.19 (16)	13.2   1.22 (13)	4.2 2

    No calves			13.5   2.25 (10)	12.6   1.26 (16)	0.9

    Mean number

    adults/group:

    With calves			1.9   0.37 (18)	1.0   0.69 (12)	0.1

    NO calves			3.8   0.95 (13)	2.7   0.39 (18) 	1.1

    1t - 2,599, P < 0.05

    2t - 2,456, P < 0.03

    25

    Table 2.  Tactics to reduce the rate of predation.

    				Tactics to Reduce:

    Species and		Encounter		Detection		Capture

    grouping		Rate			Rate			Rate

    Moose dispersed	Space-out		Use forest cover	Defend calf,

    			use islands		& hide calf		use cover and

    									obstacles

    Caribou aggregated	Migrate away	Calve on brown	Share-risk &

    (spaced-away)		from predators	substrates,		vigilance plus

    				& alternative	spaced-out		awarming, long

    				prey, including	briefly at		flushes

    				noncalving		pasturition

    				caribou, remain

    				mobile

    Caribou dispersed		Space away from	Calve on brown	remain

    in open			travel routes of	substrates,		vigilant for

    (spaced-out)		wolves & alter-	spaced-out,		long lead time,

    				native prey,	remain upwind	flee uphill

    				remain

    Caribou dispersed		Shift to		Give birth		Use cover &

    in forest			habitats with	spaced-out in	predator obst-

    (spaced-out)		low numbers of 	forest cover	cles, water

    				predators & 1				barriers

    				alternative prey,

    				remain sedentary

    26

    LIST OF FIGURES

    Figure 1.  Annual variations in the precentage of calves of total animals

    surveyed in the fall.

    Figure 2.  Decline in calves per 100 famales (> 2 years) 2 weeks after

    birth.

    Figure 3.  A comparison of the percentage of calves in the fall and the

    snow pack (as    of water equivalent) in theprevious April at

    Dease Lake.

    Figure 4.  A comparison of the elevation of cows with calves in June and

    calves/100 females in the fall for caribou at Caribou Mountain

    (Spatsizi herd) with the water equivalent of the snow pack on June

    1 in the Eaglenest Mountains where these caribou gave birth.
    	(Elevation of cows from Hatler 1985).

    Figure 5.  A satellite photograph (1:500,000) showing snow cover at Level

    	Mountain on June 3, 1977, a relatively late year, compared to June

    	3, 1978, an early year (50% less snow).  The hatched area indicates

    	new green vegetation, mostly willow.  Cow locations were not

    	avaiable for 1977.

    Figurte 7.  The topographical profile of the three study areas.  The

    	graphs in the upper right corner are the chronology of calf

    	percentages.  Percentages greater than 10% are listed as plus and

    	chose below are negative.  Calf survival varied more with moderate

    	relief at Level than at Spatsizi, were the topography was more

    	rugged.

    27

    Figure 8.  The volcanic mountains at Level Mountain (above) were more

    	undulating, with reduced snow cover, compared to the uplifted

    	mountains at Spatsizi (below).  These mountain caribou are quite

    	brown, blending with brown substrates but contrasting with white

    	backgrounds.

    Figure 9.  Spacing model.  (above) When caribou are spaced-out and total

    	numbers are low it is not profitable for a predator to search for

    	caribou.  When caribou are aggregated and total numbers are high

    	predators know where the animals are and an icrease in density does

    	not result in an increase in searching effort.  (below) Snow cover can

    	alter the space for dispersion and can change relative densities

    	and the searching effort of predators.  In an early spring caribou

    	can disperse higher into the mountains and away from alternate prey

    	and the travel route of predators in valleys than in a year with

    	greater amounts of snow in June.  In late springs wolves denned on

    	Level Mountain but probably not in early springs (1978 and 1980).
                                                                                                                                                                                                                                                                 in

                                                YEARS 7S           03 SOT? 01 79               09

                                                                                                                                                   100-             */,try, jum i-       io        EZ./&/#r #-Is

                                                                                             0    SPArSIZI
                                                                                             a    LEVEL                                                                                                                ft
                                                                                                                                                    so-
                                                                                             0    KAWOr                                      0+
                                                                                                  NONSCRANCH                                 0+
                                         Ito -                                                    f1tv collroft;                              0
                                                                                                                                              2

                                                                                                                                              a:
                                                                                                                                              w
                                                                                                                                              IL
                                     >                                                                                                        (n   40-
                                     _j                                                                                                       w
                                                                                                                                              >
                                                                                                                                              _j

                                     1-   10-                                                                                                       go-
                                     z
                                     w

                                                                                                                                                   0                                                                   At-          da-
            L
                                                       v-df4f                                                                                                   1977        1979            1978        1979        1990       i9sl
                                                                                                 a                                                                 SPATSIZI                                 LEVEL
                                          0
                                                        so          @o         1;0         200       250
                                                              WATER EQUIVALENT

            frilmme

                                                                                                          OLF Dill
                       1900.
                                                                                                                   Ik
                       1400-         loss
                    z
                    0                Nola
                    -  1700-

                    J                              CASLE MfSr      /see
                                                  sArow surioN        3
                       :
                       400
                       3001

                     1.;  30-
                     2
                                    loss

                          20-
                                             vifflo,

                     0    10-                                                                                                           0 cow"m
                     2             0.940                    1908
                          5

                          0-
                     V             46      1@0    40     2;0     Ili*
                     Al JUNE I WATER   KOUIVALENT (mm) AT ItAGLIENIST

                                                                                                                                    --7: 3=75`@*ZVg

                                                                                                            SPATSIZI                        CV   33%+@/
                        woo.                    GROUPS VATH CALVES (o   52)                         2600-
                        z
                                            0GROUPS WITHOUT CALVES ove5i)                           2000

                                                                                                    1500-
                           40

                                                                                                                     M MAVEL MUMS
                          20-                                                                   E
                                                                                                                           L -I @Aw
                        z                                                                       z           KAWDY                          cv    47%+
                                                                                                    2000
                                                                                                0
                        w                      F
                        (L                                                                           0
                           0                                                                        Is 0
                                   1      a       3      4       5      >5
                                            ADULT GROUP SIZE                                    >   1000-
                                                                                                w

                                                                                                             LEVEL       MEMN MAK                   + A/.\
                                                                                                    2000-                                  CV   02%-

                                                                                                    1500-

                                          SPACINO-AWAY'
                                            MC VV

                          MRACAW-Olff
                          WrIC

                                        CAAY SPOON

                                  &Are W

                                     DENSITY

                                     0 sex
                                        SCARW
                                        MAW
                                        CAMWU
                                                                                                                                                 X-0
                                                      sww
                 .2000-

                  0
                   1500-

                                                                                       rip
                  J
                   1000                MWA
                                       AwrAr                                                          X!

                              c

                             EARLY             LATE                                                                           INk
                                                                                    ..........

                                                                                                                                            @L I  wn-
                                                                                                    ;4i'j-

                                                                                                       A

                                                                        ATTACHMENT E                                Barring    new   domestic    discoveries    to   replace     depleted
                                           TESTIMONY ON THE                                                         reserves, and assuming the demand for petroleum does not
                          DRAFT LEGISLATIVE ENVIRONMENTAL     IMPACT STATEMENT                                      increase, the U.S. may need to import 12 million barrels per
                               "ARCTIC NATIONAL WILDLIFE REFUGE, ALASKA,                                            day by the year 2000.       Thus, without significant new dis-
                                  COASTAL PLAIN RESOURCE ASSESSMENT'                                                coveri ,es, our nation could be dependent upon foreign sources
                                            Anchorage, Alaska                                                       for 60-75% of its demand, within the next 10-15 years, almost
                       Presented by the Alaska oil and Gas Association       (AOGA)                                 double the present level of dependency'.
                                             January 5, 1987
                                                                                                              Currently the U.S. consumes more than 25 percent of worldwide
                I am Tom Cook, Alaska Exploration Representative            for Chevron                       petroleum production even though it has less than 4 percent of
                U.S.A. Inc.    Today I am appearing before you on. behalf of the                              proven worldwide reserves.       Policy decisions which slow or pro-
                Alaska Oil and Gas Association.     AOGA is a trade association whose                         hibit replenishment of domestic reserves only exacerbate this
                member companies account for the majority of oil and gas explora-                             problem.     Opportunities to explore for and develop new reserves
                tion, production and transportation activities in Alaska.         Let me                      must be forthcoming.
                say at the outset that AOGA strongly supports the Department of
                Interior's proposed recommendation that the entire '1002* area,                               As we have seen in recent years, the U.S. is vulnerable to serious
                also known as the Coastal Plain, be authorized for oil and gas                                supply disruptions because of its dependence on foreign oil.
                exploration and production. We have restricted our comments today                             Foreign sources of petroleum are concentrated largely in the
                to three aspects of the '1002(h) report", but will submit detailed                            middle East where two-thirds of the proven reserves of the non-
                written comments on the entire report before the January 23, 1987                             communist world exist.       Saudi Arabia alone possesses over one-
                deadline specified in the Federal Register Notice.                                            fourth of the free world's reserves.        Increased future dependency
                                                                                                              on these politically unstable Middle Eastern areas is highly un-
                Mr. Mike Bradshaw of Conoco will first address the national                                   desirable from a national interest viewpoint.
                interest in developing the petroleum resources            discussed in
                Chapter VII, then Mr. Mark McDermott of ARCO will comment on the                              As domestic production continues to decline, and imports continue
                biological content of Chapters if and VI.         I will conclude our                         to rise, U.S. vulnerability to supply disruption will increase.            A
                statement with comments on the recommended stipulations applicable                            reliable domestic energy supply is ; key eactor in maintaining a
                to-the are;, together with an endorsement of the proposed full                                viable foreign policy.
                leasing Alternative A selected for recommendation by the Assistant
                Secretary for Fish and Wildlife and Parks, William P. Horn.                                   It is in the.national security and economic interest to encourage
                                                                                                              exploration for new domestic reserves wherever the potential
                       Comments on National Need for Oil and Gas (Chapter VII)                                exists, on the Coastal Plain of ANWR and other promising areas.
                                                                                                              Any decision to delay that search is a step toward increased
                Thank you.     For the record,     I am Mike Bradshaw, operations                             dependency on foreign supply.         Lead times to develop frontier
                Director-Alaska for Conoco Inc.      There are many factors that are                          Alaska oilfields are very long, typically 10 to 15 years from
                relevant in determining why opening the ANWR Coastal Plain to oil                             discovery to first production.       If a major discovery were made on
                and gas leasing, exploration and production is          in the national                       the Coastal Plain today, first production would not be likely
                interest.                                                                                     before the year 2000.

                     The U.S. is rapidly depleting its domestic         reserves of oil                       Increa .sing consumption, decreasing domestic production, and rising
                     and gas.                                                                                 imports, coupled with delay in opening promising new areas to
                                                                                                              exploration and development are all factors which collectively
                     Domestic crude oil production from existing        fields is fore-                       will contribute to the likelihood of a future energy crisis.           1986
                     cast to  decline from the 8.9 million barrels      per day average                       was a year of drastic change throughout the oil-and gas industry.
                     in 1985 to 6.2 million barrels per day by          1991, if prices                       Exploration    is currently at a near         standstill,   marginal    and
                     remain at $15 per barrel.       Current domestic production has                          uneconomic fields are being shut-in, and research and development
                     already fallen to about 8.5 million barrels        per day.    Dome-                     have been drastically reduced.         continuity of exploration and
                     stic production is forecast to fall as low as 4 million                                  development are necessary to replace depleted reserves.         Delays in
                     barrels per day by the year 2000.                                                        the exploration process today will cause greatly reduced future
                o    Currently Alaska supplies our nation with approximately 20%                              production.
                     of the total U.S. production.                                                            Those who oppose oil resource development argue that the reserve
                                                                                                              potential of the Coastal Plain may represent only a few months
                                                                                                              supply of oil to the nation.       This statement, though misleading,
                NS3:377/AOGA FINAL/01-05-87         -1-

                                                                                                              TIS3:377/AOGA FINAL/01-05-87         -2-.

              illustrates very well the significance of such a reserve if it is                                                    Biological R2view Comments
              discovered and produced from the Coastal Plain.        A few months is
              indeed significant when compared on the same terms with the 18                                fly name   is  Mark   McDermott   and   I  am a   Senior    Environmental
              month supply in the largest oilfield ever discovered in North                                 Coordinator for ARCO Alaska, Inc.       Following a detailed review of
              America - Prudhoe Bay.     But, the statement is misleading for two                           the LEIS Chapter 11 - Existing Environment and Chapter VI -
              very important reasons.    First, no oil field can be fully produced                          Environmental Consequences, the Alaska Oil and Gas Association
              in a few months.    Prudhoe Bay, for example, may produce oil and                             strongly endorses the DOI recommendation to lease the entire
              gas for at least 30 years.         Second, the statement assumes a                            '1002* Coastal Plain area for oil and gas exploration, development
              reserve estimate which would offset total daily consumption rather                            and production based on the following points and conclusions:
              than an offset to imports during the life of the field.           From a
              national security perspective, offsetting imports is a more                                   Prudhoe Bay Region/TAPS
              important comparison.      Prudhoe Bay, on average, could offset
              approximately 13% of foreign oil imports for 30 years (assuming 10                            Often the National Environmental Policy Act OIEPA) -mandated EIS
              billion barrels recoverable reserves and 7 million barrels per day                            process   tries   to   predict   environmental    consequences     of  new
              imports).                                                                                     developments with little or no previous field experience to guide
                                                                                                            the predictions. Clearlyi for the ANWR Coastal Plain, test cases
              The report estimates a 19% chance of finding economically recov-                              have already been run at Prudhoe Bay, Kuparuk, Milne Point,
              erable oil on the Coastal Plain.         This promising outlook for                           Lisburne,   and Endicott,     and with the Trans Alaska Pipeline.
              success helps explain industry's high interest in exploring the                               Collectively,    the experience of      the   regulatory agencies      and
              Coastal Plain because it is a ten-fold increase over the statis-                              industry is summarized in the LEIS on page 2:             "The evidence
              tical industry success rate in Alaska.       Historically only one out                        generated during the 18 years of exploration and development at
              of fifty, or 2%, of the exploratory wells drilled in Alaska has                               Prudhoe Bay    indicates minimal      impact on wildlife resources.
              ever resulted in a commercial discovery                                                       Hence, it is reasonable to assume that development can proceed on
                                                                                                            the Coastal Plain and generate similar minimal effects."
              Economic benefits of further North Slope development to the nation
              are extremely significant.     In addition to the direct benefits to                          Furthermore, we support the statement, also on page 2 of the LEIS,
              the state and Federal governments from bonus payments, rentals,                               that 'Most adverse effects would be minimized or eliminated
              royalties, and taxes, the discovery of large new reserves would                               through carefully applied mitigation, using the lessons learned
              significantly reduce oil imports and the associated national trade                            and technology acquired from development at other North Slope
              deficit.  Nearly half of the U.S. trade deficit today results from                            oilfields and from the construction and operation of the Trans-
              imported oil.                                                                                 Alaska Pipeline System (TAPS)'.

              oil development on the North Slope of Alaska has provided hundreds                            Indeed, we would like to point out that all of the dire predic-
              of billions of dollars to the U.S. economy, representing a benefit                            tions of environmental degradation made 15 years ago, prior to the
              to all of the 50 states.       Therefore, petroleum development from                          construction of TAPS, have subsequently been proven to be un-
              the Coastal Plain, especially on the order of magnitude of Kuparuk                            founded.   The predicted demise of major caribou herds, deteriora-
              or Prudhoe Bay, would promote economic development not only within                            tion in water quality and major losses of habitat simply have not
              Alaska, but also throughout the United States.           Jobs would be                        occurred.   Instead, the development of Prudhoe Day and the TAPS
              created as the demand for goods and services increase and the                                 have allowed Alaskans to enjoy economic prosperity in harmony with
              positive impacts would be felt well beyond the petroleum industry.                            a high quality environment and thriving wildlife populations.

              if highly prospective areas such as the Coastal Plain are placed                              National Environmental Policy Act
              off limits to petroleum exploration, the nation may experience a
              future energy crisis which will make the 1973 embargo and the                                 We understand that the draft document is a legislative EIS largely
              1979-1980 price escalation seem mild by comparison.                                           following the requirements of the flational Environmental Policy
                                                                                                            Act.   We would like to point out that many of the environmental
              in summary, we believe it is clearly in the national interest to                              consequences predicted to occur for the 5 alternatives appear to
              open the Coastal Plain of ANWR to leasing and development.                                    be based on 'worst case" evaluations.       In April 1986 the NEPA-EIS
                                                                                                            guidelines were changed from requiring a *worst case* assessment
              I will now turn the microphone to Mark McDermott with ARCO who                                to one of "most likely to occur.* Vic feel that many of the major
              will comment on the biological aspects of the draft report.                                   conclusions of significant effects carry the earlier 'worst case'
                                                                                                            assesq
                                                                                                                  ment to an extreme and thus we ask that the authors re-
                                                                                                            consider many of their conclusions in light of the *most likely to

              fIS3:377/AOGA FINAL/01-05-87        -3-                                                       NS3-377/AOGA FINAL/01-05-87          -4-

               occur" assessment of impacts.     The standard for the "most likely                         While AOGA embraces the responsible use of mitigation procedures
               to occur" case exists in the experience from other North Slope                              in the Arctic, it is inappropriate to emphasize habitat loss alone
               oilfields. Many of these specific points will be detailed in our                            without consideration of actual effects or lack of           effects on
               written comments.                                                                           wildlife populations from development.
               Caribou                                                                                     Muskox

               We agree that caribou, both from a standpoint of numbers and                                We feel that the conclusions regarding potential impacts of
               distribution, is the specie most likely to encounter developmental                          development on muskox are unnecessarily severe and unfounded.
               activities in the *1002" area.     The LEIS quote from page 6 states                        While it is true that very few data characterizing muskox res-
               that "Changes could include displacement and reduction in the size                          ponses to oil field development are available, it is also' true
               of the Porcupine Caribou Herd.      The amount of reduction and its                         that the muskox have shown ready adaptability to human presence
               long-term significance for herd viability is highly speculative'                            and have even been semi-domesticated in several areas.               This
               (emphasis added).     We- ask that these acknowledged qualifications                        adaptability to human presence will significantly reduce the
               be presented throughout the environmental consequences section to                           'worst-case* conclusions stated in the LEIS.
               ensure that all readers of the document are fully aware of the
               highly speculative nature of some of the hypothesized impacts.                              Mammalian Species
               Carrying Capacity                                                                           We feel that it is important to point out that the remaining
                                                                                                           mammalian species including moose, dall sheep, wolves, arctic fox,
               In the management of wildlife populations, the concept of habitat                           wolverines and brown bears are present on the' Coastal Plain in
               carrying capacity is key to defining management goals.        It is an                      relatively   low population densities or         for  relatively short
               established fact    that the Porcupine Herd does not approach the                           periods during the year.       Thus, we support the conclusions of
               carrying capacity   of its range.   Indeed, former Alaska Fish & Game                       minimal or negligible impacts on these species.
               Commissioner, R. Skoog, in his Doctoral dissertation.0968) stated
               that "It seems likely that the Alaskan caribou population has                               Fishery Populations
               remained far below range carrying capacity and that the total
               habitat has never been fully occupied.           in reality,     caribou                    We support the conclusion that only minor to negligible effects on
               populations seem to have maintained densities much lower than the                           coastal fishery resources or fishery habitat will occur.          Experi-
               maximum dictated by food alone, and hence the reduction in total                            ence at Prudhoe Bay and Endicott has provided aksignificant volume
               range becomes less    meaningful." Thus, we agree with the conclu-                          of data to support this judgment.
               sions that habitat    is not currently limiting the growth of the
               Porcupine Herd and    that the small loss of habitat represented by                         Threatened and Endangered Species
               likely development    in the '1002* area will not impact growth or
               productivity of caribou.       Consequently, we disagree with the                           we also support the conclusions of minor. to negligible impacts on
               speculation that a 'reduction of caribou population is likely to                            endangered and threatened animal species such as bowhead and grey
               occur as a result of small reductions in habitat availability and                           whales and the peregrine falcon.         We  feel that the transient
               value.                                                                                      nature of their presence on the Coastal       Plain and the history of
                                                                                                           developmental interaction in the Prudhoe Bay field clearly demon-
               "Core Calving Area" Concept                                                                 strate the lack of meaningful impacts on     these species.     Regarding
                                                                                                           the plant, Thlaspi arcticum, we feel that conclusions and set-back
               Significant year-to-year variability in calving distribution has                            stipulations based on the presence of this specie are overly
               been recorded for the Porcupine Herd all across the Arctic coast                            restrictive because the plant has not been determined to be
               from east into Canada-and west to the Canning River. Concentrated                           threatened.or endangered.
               calving has been observed across the entire so-called core calving
               area during only 5 of the past 14 years.           Therefore, calving                       Recreation
               habitat is more appropriately represented as a true continuum
               across the Coastal Plain including portions of the Arctic coast                             we would like to underscore the extraordinarily low use of the
               outside the "1002* study area.       The Porcupine Caribou Herd has                         coastal Plain as a recreational area.      History indicates that only
               demonstrated numerous times in the past, including this past year,                          a small number of individuals have actually utilized the Coastal
               that it can and will successfully calve miles from the (quote)                              Plain for. recreation in the form of hunting, fishing, camping or
               .core calving area' (unquote).     Thus, the "unique and irreplace-                         hiking.   It is extremely expensive to reach the area; a trip from
               able" nature required for designation as Resource Category 1 does
               not apply.

               NS3:377/AOGA FINAL/01-05-87        -5-                                                      NS3:377/AOGA FINAL/01-05-V          -6-

               the contiguous states costs thousands of dollars and requires an                             Stratigraphic type drilling is an unnecessary duplication and its
               air charter flight to reach the Coastal Plain.           Wet and moist                       surface impact would be in addition to that eventually required
               ground conditions make hiking difficult during the 8-10 week                                 for on-structure wells.     Also, Alternative C would just be another
               .summer." Extreme cold and darkness during most of the year                                  delay in the eventual production from the area.         Neither Alterna-
               further reduce recreational use of the Coastal Plain.       For most of                      tives D, no action, nor E, wilderness designation, would determine
               the year this is an extremely harsh and hostile environment.                                 whether or not substantial petroleum reserves exist in the "1002"
                                                                                                            study area.    Alternatives D and E preclude reasoned planning and
               While there is no reason to believe that leasing and development                             would deny the nation the positive benefits that could come from
               would lead to a permanent loss of aesthetic values, over 30 miles                            oil and gas production on the Coastal Plain.
               of Coastal Plain from the "1002' area east to the Canadian border
               are already    classified as wilderness, thus preserving the com-                            We fully support the proposed recommendation on page 169 which
               plete spectrum of arctic ecosystems represented in the Arctic                                contains the following statement:         even though the billions of
               Refuge.                                                                                      barrels of oil reserves have been brought on line and the infra-
                                                                                                            structure developed to bring that oil to U.S. markets, the fish
               Summary                                                                                      and wildlife resources of the Prudhoe Bay area remain extremely
                                                                                                            healthy.   The Central Arctic Caribou Herd has increased substan-
               Before I ask Mr. Cook to conclude our statement, I would like to                             tially during the period that development has occurred within the
               acknowledge the 5 years of extensive field investigations, data                              heart of its range.    Estimated at about 3,000 animals in 1972, the
               collections and analyses by over 50 trained professional scien-                              herd now numbers more than 13,000.      Similarly, important waterfowl
               tists,  including   wildlife    and  fishery   biologists,    botanists,                     species continue to successfully nest and rear their brood within
               zoologists, chemists, geologists and resource specialists who                                the developed area.    Although circumstances within the '1002" area
               contributed to this draft report. We consider the factual basis                              may be somewhat different, the evidence derived from the Prudhoe
               for the scientific analysis to be adequate and the conclusions to                            Bay experience leads one to be quite optimistic about the ability
               be reasoned.   However, we cannot support some of the speculation                            to explore for and develop the hydrocarbon potential of the "1002"
               on environmental consequences found in the report which result in                            area without significant deleterious effects on the unit's wild-
               an over estimation of potential impacts.                                                     life resources."

               Concluding Remarks                                                                           Thank you for this opportunity to comment.

               As previously stated AOGA supports the full leasing of the ANWR
               Coastal Plain under reasonable measures for environmental pro-
               tection.   Except for a few provisions, the proposed stipulations
               found in the report and the land use stipulations found in the
               Agreement Between. the Arctic Slope Regional Corporation and the
               United States of America (incorporated into the report by refer-
               ence), appear reasonable.      The proposed mItigation measures are
               generally consistent with current and proven industry practices
               for the protection of wildlife and the environment.        The applica-
               tion of reasonable mitigation can ensure that development is
               conducted in a manner compatible with the purposes of the Refuge
               and ensure that no unnecessary adverse environmental             impacts
               occur.  Our written comments will address in detail, those mea-
               sures that we believe are unduly restrictive.

               AOGA strongly endorses Alternative A, full leasing of the '1002"
               study area, as the most acceptable alternative consistent with the
               national interest.    Alternative B, partial leasing, is based on a
               speculative premise that a traditional core calving area exists
               and is necessary for the maintenance of a healthy caribou herd.
               This has not been demonstrated in the scientific literature and
               there is a large body of data which indicates otherwise.          Alter-
               native C makes no positive contribution.         Surface and regional
               geologic information already confirm that the area has oil poten-
               tial.  The amount can only be verified by on-structure drilling.

               NS3:377/AOGA FINAL/01-05-87         -7-                                                      NS3:377/AOGA FIRAL/01-05-87          -8-

                                           TESTIMONY ON THE                                                  1 or 2 giant oil fields should be balanced against the very strong
                         DRAFT LEGISLATION ENVIRONMENTAL IMPACT STATEMEUT                                    contribution to the national interest that such discoveries could
                              "ARCTIC NATIONAL WILDLIFE REFUGE, ALASKA,                                      represent.
                                 COASTAL PLAIN RESOURCE ASSESSMENT"
                                           Washington, D.C.                                                  Our industry has demonstrated its compatibility to explore for,
                      Presented by the Alaska oil and Gas Association      (AOGA)                            develop, and produce oil in the Alaska Arctic without significant
                                            January 9, 1987                                                  adverse impact on wildlife and the environment.        The dire predic-
                                                                                                             tions of environmental degradation and harm to wildlife made 15
              I am Wayne Smith, District Manager of Amoco Production       Company and                       years ago, prior to the development of the giant Prudhoe Bay field
              President of the Alaska Oil and Gas Association (AOGA).             I am                       and the construction of the Trans-Alaska Pipeline have proven to
              appearing before you today on behalf of AOGA which is a trade                                  be unfounded.     The predicted demise of major caribou herds,
              association whose member companies account for the majority of oil                             deterioration in water quality a    Ind major losses of habitat simply
              and gas exploration, production and transportation activities in                               have not occurred.
              Alaska.   AOGA strongly supports the Department of the Interior's
              proposed recommendation that the entire "1002* area, also known as                             Instead, the development of Prudhoe Bay and the Trans-Alaska
              the Coastal Plain of the Arctic National Wildlife Refuge (ANWR),                               Pipeline have permitted the production of 5 billion barrels of
              be authorized for oil and gas leasing, exploration and production.                             much needed oil with minimal environmental impact.         During the 15
                                                                                                             year period of development wildlife have thrived in the midst of
              Currently, Alaska supplies our nation with approximately 20% of                                oil field development and evidenced by the fact that the Central
              its total domestic production.       Lead times are long in frontier                           Arctic Caribou Herd has grown from about 3,000 to a population now
              Alaska regions--at least 10 years from discovery to first pro-                                 estimated at over 13,000 animals.
              duction, but more likely to extend as long as 15 years in the case
              of the ANWR Coastal Plain.      Without significant new discoveries,                           With regard to the issue of protecting the Porcupine Caribou Herd
              our nation could be dependent upon foreign sources for 60-75% of                               which uses the Coastal Plain on a seasonal basis, there has been a
              its petroleum needs within the next 10-15 years, almost double the                             development since the issuance of the draft report which I would
              present level of dependency.                                                                   like to mention.      On December 3, 1986, the United States and
                                                                                                             Canada have devised an agreement for the management and conserva-
              Production from existing Arctic Alaska oil fields which are                                    tion of the Porcupine caribou Herd.         This agreement which also
              presently being produced at about 1.8 million barrels per day will                             involved the native subsistence users of both the Canadian and
              begin a precipitous decline by 1988.       It is a matter of technical                         American Arctic assures that appropriate steps will be taken to
              certainty that the present level of production from Alaska's 11orth                            guarantee the well-being and preservation of the Porcupine Caribou
              Slope will decline to about 500,000 barrels per day by the year                                Herd.   In view of this development, the final report to be sub-
              2000, earliest date by which new production from the ANWR Coastal                              Witted to the Congress should be revised to reflect this new
              Plain would likely be available.                                                               measure of protection afforded the Porcupine Caribou Herd.
              If highly prospective areas such as the Coastal Plain are placed                               I would like to acknowledge the 5 years of extensive field
              off limits to petroleum exploration, the nation may experience a                               investigations, data collections and analyses by over 50 trained
              future. energy crisis which will make the 1973 embargo and the                                 professional scientists, including wildlife and fishery biolo-
              1979-1980 price escalation seem mild by comparison.                                            gists, botanists, zoologists, chemists, geologists and resource
                                                                                                             specialists who contributed to this draft report. We consider the
              Increasing consumption and rising imports along with decreasing                                factual basis for the scientific analysis . to be adequate and the
              domestic reserves and production, coupled with delay in opening                                conclusions to be reasoned.       However, we cannot support some of
              promising new areas to exploration and development#              are all                       the speculation on environmental consequences found in the report
              factors which collectively will contribute to the likelihood of a                              which result in an over estimation of potential impacts.
              future energy crisis.
                                                                                                             Except for a few provisions, the proposed stipulations found in
              The resource assessment contained in the draft LEIS for the                                    the report and the land use stipulations found in the Agreement
              Coastal Plain supports our view that            the area may contain                           Between the Arctic Slope Regional Corporation and the United
              significant reserves.     The Coastal Plain has great potential for                            States of America (incorporated into the report by reference),
              making a substantial contribution to our domestic energy supply.                               appear reasonable.    The proposed mitigation measures are generally
                                                                                                             consistent with current and proven industry practices for the
              Even the most optimistic production scenario will physically                                   protection of wildlife and the environment.         The application of
              utilize only a very *small area of the Coastal Plain.           The very                       reasonable mitigation can ensure that development is conducted in
              small area which would be affected by discovery and development of                             a manner compatible with the purposes of the Refuge and ensure

              NS3:365/AOGA FINAL/01-09/87          -1-                                                       N83:365/AOGA FINAL/01-09/87         -2-

                                                                                                          Paragraph 2 correctly points out that wide year-to-year variations
             that no unnecessary -adverse environmental impacts occur.             Our                    in calving distribution can occur due to weather influences and
             written comments will address in detail, those measures that we                              the arrival of spring snow-melt.         This acknowledged effect of
             believe are unduly restrictive.                                                              weather further erodes the core-calving area concept and points
             AOGA strongly endorses Alternative A, full leasing of the '1002'                             out the wide annual variability and adaptability of caribou.
             study area, as the most acceptable alternative consistent with the                           Paragraph 3 cle  Iarly shows this annual variability.      During 1983,
             national interest.    Alternative B, partial leasing, is based on a                          1984, and 1985, calving estimates varied from 74% to 35% and 82%
             speculative premise that a traditional core calving area exists                              respectively in the 1002 area.          These data clearly show the
             and is necessary for the maintenance of a healthy caribou herd.                              adaptability of the PCH to yearly variations in weather conditions
             This has not been demonstrated in the scientific literature and                              and point out that calving distributions do vary widely.
             there is a large body of data which indicates otherwise.           Alter-
             native C makes no positive contribution.         Surface and regional                        Therefore, we ask that conclusions regarAing the relative impor-
             geologic information already confirm that the area has oil poten-                            tance of the Jago highlands as a core-calving area be de-
             tial.   The amount can only be verified by on-structure drilling.                            emphasized throughout the report.
             Stratigraphic type drilling is an unnecessary duplication and its
             surface impact would be in addition to that eventually required                              Page 29, paragraph 3:      Similar to calving distribution, caribou
             for on-structure wells.    Also, Alternative C would just be another                         demonstrate wide variation in their selection and use of insect
             delay in the eventual production from the area.        Neither Alterna-                      relief habitat.    Although many groups move towards the coast, the
             tives D, no action, nor E, wilderness designation, would determine                           report correctly points out that many also move to higher foothill
             whether or not substantial petroleum reserves exist in the "1002'                            and mountain areas for relief.          We feel the report does not
             study area.    Alternatives D and E preclude reasoned planning and                           sufficiently recognize the wide variation in acceptable insect
             would deny the nation the positive benefits that could come from                             relief habitat, and thus places undue emphasis on the coastal
             oil and gas production on the Coastal Plain.                                                 areas.   We also point out that the Prudhoe Bay development pads
                                                                                                          and roads have actually created insect relief habitat and have not
             AOGA's expresses     its full support of the Department of the                               prohibited CAN access to coastal areas for insect relief.         We ask
             interior's   proposed   recommendation    to   Congress   which    states                    that this section clearly point out the favorable experinnce at
             * ... even though the millions of barrels of oil resources have been                         Prudhoe Bay.
             brought on line and the infrastructure developed to bring that oil
             to U.S. markets, the fish and wildlife resources of the Prudhoe                              P:?e 21-11, Other mammalian species:       Population size and distri-
             Bay area remain extremely healthy.        The Central Arctic Caribou                         b   ion data for other mammalian        species in the 1002 area are
             Herd has increased substantially during the period that develop-                             summarized as follows:
             ment has occurred within the heart of its range.           Estimated at
             about 3,000 animals in 1972, the herd now numbers more than                                  Species                                 Population Density in 1002 Area*
             13,000.    Similarly, important waterfowl species continue to
             successfully nest and rear their brood within the developed area.                            Muskox                                  Approx. 476 individuals
             Although circumstances within the *1002' area may be somewhat                                Moose                                   Does not exceed 25
             different, the evidence derived from the Prudhoe Bay experience                              Dail Sheep                              Very rare
             leads one to be quite optimistic about the ability to explore for                            Wolves                                  Does not exceed 5-10 animals
             and develop the hydrocarbon potential of the 01002" area without                             Arctic Foxes                            Common with annual fluctuations
             significant deleterious effects on the unit's wildlife resources'.                           Wolverines                              Few-accurate figures are
                                                                                                                                                  unavailable
             Thank you for the opportunity to present this statement.                                     Brown Bear                              Approx. 108 bears

                                                                                                          * Population density statements         taken from 1002 report, pages
                                                                                                          29-33.

                                                                                                          As can be clearly seen from these data, very few individuals of
                                                                                                          these species are found in the 1002 area.       We ask that the report
                                                                                                          conclusions be strengthened to point out the extremely low density
                                                                                                          of use for these species, and thus the low'potential for any
                                                                                                          impacts on these species due to development.

                                                                                                          Page 34, paragraphs 3 and 4:         The report does not consider the
                                                                                                          results from th   e high ly successful 1986 whaling season.        During

             NS3:365/AOGA FINAL/01-09/87         -3-                                                      IIS4:481/AOGA/02-04-87               -9-

             this season, Kaktovik took 3 whales and Nuiqsut took I whale.                                          CHAPTER III    Assessment of Oil and Gas Potential
             These successful hunts took place while offshore drilling and
             drillship activity were allowed to occur during a portion of the
             fall bowhead migration.    We feel this experience clearly documents                        Page 49, column 2 paragraph 2: "These 26 prospects were subjected
             the compatibility of offshore drilling activity with subsistence                            to technologic al tn d ec onomic conditions to determine the degree to
             whaling.                                                                                    which their resources could be recovered, resulting in estimates of
                                                                                                         conditional economically recoverable resources.*
             We ask that these.data be added to this section of the report.                              It should be recognized that these technological and economic
             Page 43, column 1, paragraph 3:      "The 1002 area has received no                         criteria could be different for different lessees, rpsulting in
             industrial use other than oil and gas exploration under the 1002                            variable reserve estimates, high and low.
             program.'               .1                                                                  Page 49, column 2, paragraph 2- 'It is estimated, if there is
             Reindeer herding and commercial whaling were practiced in the early                         economically recoverable oil present (the chance of which Is
             part of the century.                                                                        estimated to be about 20 percent),@..'

             Page 45, column 2:   Statistics on recreational use of the 1002 area                        This estimate is misleading to those who are not familiar with
             seem unduly inflated.    Permit data on file with the USFWS indicate                        typical industry risk and success ratios.      While a 20% chance might
             that 1983, 1984 and 1985 had only 6, 33 and 33 permitted users                              be considered unfavorable to others outside the petroleum industry,
             respectively for the 1002 area.       Additionally, it is not clear                         it is an excellent chance from an industry standpoint.       The record
             whether the "less than 3000" recreational visits per year include                           in Alaska shows only I out of 10 exploratory wells drilled en-
             the *Kaktovik residents also engage in snowmobiling" or not.          if                    counters any hydrocarbons at all, and of those that do, only I out
             so, the number is deceptively large.                                                        of 5 finds a commercial field.     Hence, out of 100 exploratory wells
                                                                                                         drilled, only 10 would encounter oil.      Of those 10, only 2 would
             We ask that these figures be included in the report to emphasize                            have discovered economically developable fields.      This represents a
             the low frequency of recreational use for the area.                                         2 percent chance of success compared to the 20 percent mentioned
                                                                                                         above.    In other words, 20 percent represents a considerable
             Page 45, column 2. varaorat)h 5!      *The Arctic Refuge Js #--he only                      increase over past ;industry success 'in Alaska.
             conservation system unit that protects, in an undisturbed condi-
             tion, a complete spectrum of the various arctic ecosystems in Nocth                         Page 51t  column 1. paragraph 4: 'However, the estimation of recov-
             America.'                                                                                   erable resources was limited to those prospects (all structural)
                                                                                                         which can be identified and delineated with reasonable degree of
             There is ample evidence in the report referring to recreational and                         certainty, and which are physically large enough that they could
             subsistence use of the area to show that the area is not                                    reasonably be expected to contain commercial quantities of oil.o
             undisturbed.
                                                                                                         A reserve estimate based on these criteria should represent a
             Page 46, col u   LL p agraph 2:     'The 1002 area is the most biologi-                     minimum.   Recoverable resources from stratigraphic traps could be
             cally productTnve parzrof  the Arctic Refuge for wildlife and is the                        considerable since many of the plays identified on p. 63-67 are
             center of wildlife activity on the refuge.,                                                 stratigraphic in nature.    Further, the minimum economic field size
                                                                                                         would be expected to decrease as infrastructure from larger fields
             This statement is contrary to the wildlife population data cited in                         is developed.    Prospects that were deemed too small to be econo-
             the preceding parts of this chapter which point out the relatively                          mically viable on their own may come into play later on in the
             low abundance of wildlife species and the relatively short period                           development cycle.    Additionally, all of this discussion precludes
             of use of the 1002 area.     we suggest deletion or at least clari-                         the uncertainty of oil prices and the effect of price fluctuations
             fication and quantitative justification for this statement.                                 on the economic viability of any prospect.
             Page 46, paragraph 3:     This paragraph acknowledges the esthetics                          a e      col umn 2, parag aph 1: "If most of the Ellesmerian rocks
                 the coastal plain
             of                         area but fails to recognize that the                             are ihin, in most of the 1002 area, the assessment number would
             easternmost   portion   of  the ANWR coastal      plain   has    similar                    be reduced considerably.    Drilling of one or two wells in critical
             aesthetics and is currently designated as wilderness.                                       areas would resolve this question.'

             Even with full leasing under Alternative A, this 30 miles of                                Although the drilling of one or two stratigraphic wells would
             coastal plain from the 1002 area east to the Canadian border and                            provide additional geologic detaili it only prolongs the process of
             further into Canada will remain as wilderness, thus preserving the                          determining and evaluating the resource potential of the Coastal
             complete spectrum of arctic ecosystems represented in the Arctic                            Plain.   The level of geological information currently in hand is
             Refuge.   Furthermore, we believe that leasing and development will                         sufficient to begin an exploratory phase of drilling on the Coastal
             not lead to a permanent loss of esthetics.

             NS4:481/AOGA/02-04-87              _10-                                                     N94:481/AOGA/02-04-87              _11-

              Plain.   As exploratory wells are drilled to evaluate oil and gas                                    CHAPTER IV     Development and Transportation Infrastructure'
              prospects, stratigraphic information will be obtained to updAte
              resource and reserve estimates.
                                                                                                              The scenarios for exploration, development, production and trans-
              Pag   58, column 2, paragraph 6: "No prospects were adequately                                  portation set forth in chapter IV are realistic and reasonable
              resolved   within the detached and highly deformed Mesozoic and                                 descriptions of how petroleum development and operations may be
              Tertiary   rocks ...... Structural. analogs in Canada - the Alberta                             conducted on the Coastal Plain,        We believe that Chapter IV is
              disturbed belt - and in the Montana-Wyoming thrust belt suggest                                 responsive to Section 1002(h)(3), which requires an evaluation of
              that the   probability of traps occurring in the subsurface in this                             the etfects of further oil and gas exploration, development, and
              structural setting is high, although determining their location on                              Section 1002(h)(4), which requires a description of transportation
              the basis of existing seismic data is difficult.'                                               facilities.   We offer the following comments and suggestions           V
                                                                                                              the contont of Chapter IV:
              These statements indicate that the resource estimate might actually
              be higher than what is stated in the report.                                                    Page 15,  column 1, paragraph 3:     "Without exploratory drilling as
                                                                                                              a confirmation and delineation tool, all estimates must be con-
              Pag   61, Table 111-2:      Data on Petroleum Prospects in the 1002                             sidered uncertain.-
              Area.
                                                                                                              We fully support this important caveat.           Drilling an adequate
              The data presented in the Table indicate that many       of the prospects                       number of exploratory wells is the only means of' reducing the
              have   been    identified    by   only   one   seismic    line.    it    is                     inherent uncertainty of the estimates which form the basis for the
              difficult, if not impossible, to identify the areal extent of a                                 scenarios described in Chapter IV.
              prospect from only one seismic line. Hence, the reserve estimates
              for these prospects could be understated.                                                       Page-75, near top of column 2: 'Specific locations and sources of
                                                                                                              water and gravel for exploration and development activities have
              Page 68, column 2, paragraph 4: 'The PRESTO model also allows for                               not been identified; and it is understood that these resources,
              input of a minimum economic field size.         Any field smaller than                          especially water, are not readily available on the 1002 area.*
              this economic field size is not,counted in the prospect or area
              conditional resource estimates."                                                                Throughout the '1002' draft there are numerous references to
                                                                                                              gravel and water shortages with the implication that there are no
              The economical viability of small fields should improve as the                                  known ways in which these resources can be obtained in quantities
              infrastructure is developed for larger fields.           To exclude the                         sufficient to support development and operations.         We believe the
              reserve potential of smaller fields strictly by, size does not                                  report overstates potential problems in obtaining needed water and
              seem reasonable.                                                                                gravel.

                                                                                                              With regard to the availability of gravel, it is acknowledged on
                                                                                                              page 20 of the report that 'The valleys of larger streams are
                                                                                                              underlain by large quantities of coarse sand and gravel". Further,
                                                                                                              data available from the drilling of thousands of shallow shot-holes
                                                                                                              throughout the 1002 area substantiate that much of the area is
                                                                                                              underlain in the very near surface with gravel.         These data from
                                                                                                              the group seismic surveys are available to the Department of the
                                                                                                              interior and should be used to substantiate the availability of
                                                                                                              gravel for construction.
                                                                                                              We also believe that the report overstates the problems attributed
                                                                                                              to the scarcity of water from the 1002 area. While we acknowledge
                                                                                                              that fresh water may not be readily available in much of the 1002
                                                                                                              area (as is the case generally in the Arctic), there are ways of
                                                                                                              providing for water as demonstrated in the Prudhoe Bay area.
                                                                                                              Water availability varies by location, and solutions to provide
                                                                                                              water must be considered on a site-specific basis.                Specific
                                                                                                              solutions are addressed in later comments.

              NS4:481/AOGA/02-04-87               -12-                                                        NS4:4BI/AOGA/02-04-87              -13-

             Page 75, col 11 2                        -On      North Slope, explor-                       expenses and impacts by limiting the number of surface locations
                          um       last paragraph:        the
             atory wells to       pth of approximately 12,000 feet can usually be                         required.
             drilled in a single season.     It is possible that many wells would
             require two seasons."                                                                        Page 78, column 1, full paragraph 3:         *...about 10 years will
             The presumption that a 12,000 foot exploratory well can usually be                           elapse before production starts from a new lease.*
             drilled in a single season is not necessarily correct.          Further,                     This may be an overly optimistic time frame, if seasonal restric-
             the presumption that wells which cannot be drilled in a single                               tions are indiscriminately placed on operations and construction.
             winter season will require a multi-season effort should be examined                          Permit acquisition may contribute to a more lengthy time frame.
             on a case-by-case basis.    While we agree that operations should be                         Twelve to fifteen years could be required from lease acquisition
             scheduled to avoid significant disturbance to wildlife and the                               to first production.
             environment, conducting exploratory operations into or through the
             summer may be warranted if adverse impacts can be avoided.                                   Production infrastructure
             Page 76, column 1, paragraph 2:      "Heavy construction equipment is                        Page 80, column 2         raph 5:   "The drilling pad--- covers 20-35
             used to prepare the wellsite for the drilling operation and to                                            '00         g
             prepare an airstrip large enough for Hercules C-130 aircraft.'                               acres ... 160   0 ! P2:;!,'000 cubic.yards of gravel."
                                                                                                          This is not typical at present but relates to the 40-50 wells/pad
             The assumption that all exploratory drilling operations would be                             suggested on page 81 (paragraph 2).      Typical latest technology on
             mobilized and     supported by C-130 aircraft       results   in over-                       Kuparuk River Field (D.S. 3G) is 24 wells on an 11.5 acre site
             estimating water and gravel requirements, vegetation disturbance,                            (including reserve pit area) with only 46,000 cubic yards of gravel
             wildlife displacement and loss of habitat.       Exploratory wells can                       (for wellheads at 25 feet spacing).       With reduction in wellhead
             also be mobilized and supported by Rolligons and other surface                               spacing (which is already achievable) a 40-50 well pad could be
             vehicles as has been demonstrated by past experience on the North                            little bigger than the Kuparuk River      Field example given above.
             Slope.                                                                                       Well spacing for the Endicott field, now under development, is
                                                                                                          about 10 feet from wellhead to wellhead.
             Page 76, column 2' pa'rag  rUh 1% 'On the 1002 area, obtaining the
             water needed for dri    Ili ng, and more particularly for ancillary                          Page 81, column   "  )ar agraph 1:   @These roads would have a crown
             needs such as -'ice roads and airstrip construction, poses the major                         width,of ap'roxi;a`t4_y 35 feet ....
             engineering problem.*                                                                                   p
                                                                                                          Kuparuk River field standard is 32 feet for main roads and only 24
             Here again, the problem of water availability is overstated,                                 feet for other roads.
             particularly for an exploratory well. The roads and ice airstrips
             can be constructed from snow.     Snow fences have been successfully                         Page 81, column 2, paragraph 1:     'Construction of a marine facility
             used for the collection of snow for such construction.          Snow/ice                     to service development ... would be necessary because long hauls ...
             melters can be used to obtain water for drilling and camp use. As                            from Prudhoe Bay are impractical."
             a last resort, water can be hauled or even air-lifted to an
             exploratory operation.      Also, there are lakes (depending upon                            A marine facility would be required for major equipment sealifts
             locality) which do not freeze to the bottom.       The three scenarios                       in summer open water seasons.     However, year-round transportation
             for obtaining water described on page 76 are also feasible                                   services to drillsite facilities would be via Prudhoe Bay.
             alternatives for obtaining wateror reducing the requirements for
             water.                                                                                       Pa Se 8"           1.        qaragraph 2:       ... construct a second
             Page 77, column 2           aph 1:  'Following is a discovery of oil                         pi pe1ine p= to TfAUPIS'    ..
             from explora tign drHIrlaigg, a confirmation or delineation well is                          Given the certain and precipitous decline from existing North
             drilled during the next drilling season.       ... further delineation                       Slope production, which will have occurred long before any new
             drilling occurs during subsequent drilling seasons.'                                         production will be available form the 1002 area, it is very
                                                                                                          unlikely that a new trunkline from the Prudhoe Bay to Valdez would
             Delineation drilling may not require a sequential season-by-season                           be required.
             time frame.   Delineation wells often can be drilled,in a signifi-
             cantly shorter drilling time than a rank exploratory well depend-                            Page 82, column 2, full paragraph 2:         'A concept used in the
             ing on (among other factors) the depth of the production horizon.                            Kuparuk River field pipeline, but ii-ot incorporated in TAPS, was
             Also, one or more delineation wells can be drilled from the same                             construction of only one road for use as -both a main transporta-
             location by directional drilling which in         itself would reduce                        tion artery and a pipeline maintenance road.*

             NS4:481/AOGA/02-04-87              -14-                                                      NS4:481/AOGA/02-04-87             -15-

              if the main road is not adjacent to the pipeline, adequate access                                                   CHAPTER V    Alternatives
              on a year-round basis will be needed to the pipeline.

              Page 83, column 1, paragraph 1:     "Access to valves, which require                        The five alternatives ranging from full leasing (Alternative A) to
              frequent maintenance ... wilderness designation (alternative E) describe a full spectrum of
                                                                                                          possible alternatives for the future management of the 1002 area.
              This is not the case, although on the rare occasion when a valve is                         The options as listed occur in the order of industry preference.
              automatically closed it may need to be reopened manually.                                   That is:     full leasing, followed by limited leasing, further
                                                                                                          exploration, no action. The least preferred would be a wilderness
              Page 831 column 1, paragraph 2:     "A pump station is required every                       designation for the Coastal Plain.      No action would be far better
              50-100 miles ... 2 or 3 pump stations probably would be required ...                        than wilderness status.       The area is currently managed as a
              The first would be located near the oil field."                                             wilderness.    If no action   is taken, then the Coastal Plain will
                                                                                                          continue to be managed as     wilderness, but options will still be
              For 150 miles no intermediate pump station would be necessary.                              open for'the future.
              The first and only pump station would be located at the oil field.
              A pipeline of this length would certainly not be designed with 2                            We strongly endorse Alternative A, full leasing of the "1002'
              or 3 pump stations, but with one and a pipeline diameter                                    study area, as the most acceptable alternative consistent with the
              sufficient for a the anticipated maximum flow.                                              national interest.

              Page 81,_ column 2, paragraph 4:    'Maintaining  continuous control of                     Alternative B, partial leasing, is based on a speculative premise
              the pipeline ... would require a complex communication system".                             that a traditional core calving area exists and is necessary for
                                                                                                          the maintenance of a healthy caribou herd.          This has not been
              Although   complex,   such   communication    systems , are     standard                    demonstrated in the scientific literature and there is a large
              technology.                                                                                 body of data which indicates otherwise.

              Page 84, column 1, paragraph 2:       'Airfields may be required at                         Alternative C makes no positive contribution.       Surface and regional
              pipeline construction camps and pump stations or airfields may be                           geologic information already confirm that the area has oil poten-
              shared with oil development facilities.'                                                    tial.   The amount can only be verified by on-structure drilling.
                                                                                                          Stratigraphic type drilling is an unnecessary duplication and its
              Permanent airstrips (5,000-6,000 feet long and 150 feet wide and                            surface impact would be in addition to that eventually required
              five feet thick) are not likely to be required to support the                               for on-structure wells.    Also, Alternative C would just be another
              pipeline during construction or operation.       To consolidAte faci-                       delay in the eventual production from the area.
              lities, only one or two permanent airstrips are likely to be needed
              to support all operations in the 1002 area.        Temporary ice air-                       Neither Alternatives D, no action, nor E, wilderness designation,
              strips may be required to support exploratory drilling and pipeline                         would determine whether or not substantial petroleum reserves
              construction.                                                                               exist in the *1002" study area.        Alternatives D and E preclude
                                                                                                          reasoned planning and would deny the nation the positive benefits
              Page 85,_ column 2_, @ull paragraph 4:    "the actual availability of                       that could come from oil and gas production on the Coastal Plain.
              grave 1 is unknown ..
                                                                                                          Page 89, column 1,     paragraph 1:     'if the Congress chooses to
              Here again, we offer the comment that data from thousands of                                authorize le aing in    th e entire IOU2 area, the legislation would
              shot-holes drilled as part of the 1002 area group seismic surveys                           probably contain the   important elements of the Mineral Leasing Act
              provide evidence of widespread gravel availability in the near                              and the NPRA legislation, with special provisions to meet the
              surface of the 1002 area.                                                                   unique needs of the Arctic Refuge.'                       I

                                                                                                          Without offering specific suggestions as to lease terms and the
                                                                                                          provisions for leasing, which may be applied to the 1002 area, we
                                                                                                          would like to point out a few problems with the NPRA leasing
                                                                                                          program.   First, the NPRA program did not provide for unitization
                                                                                                          which (among other things) is the basis for the consolidation of
                                                                                                          facilities. Provisions for unitization are necessary if redundant
                                                                                                          operations and facilities are to be minimized.       Second, given the
                                                                                                          long lead times for development in the 1002 area, there should be
                                                                                                          provisions for holding a lease (or unit) beyond the primary term of

              NS4:481/AOGA/02-04-87             -16-                                                      NS4:481/AOGA/02-04-87              -17-

             the lease by virtue of "shut-in' production.           Third, the overall                                           C11APTER VI    Environmental Consequences
             suite of stipulations and regulations applied to exploration,
             development, and production in the 1002 area must not be unduly
             burdensome.      Collectively,     the   stipulations     and     regulatory                       The general comments pertaining to Chapter II apply also to Chapter
             framework imposed on the NPRA were burdensome to the point of                                      VI.   The following are specific comments on Chapter VI:
             precluding industry interest in evaluating the NPRA.
                                                                                                                Page 95, paragraph 8:       "In Alternative A, three portions of the
             Page  "" column "      item 3:    'Development will be unitized within                             1002 area  ..... are all predicted as being developed,             and the
             th   10.2 are., and   0. pri vately owned subsurfaceresources in the                               assessment considers all three areas as developed concurrently ...
             vicinity of Kaktovik.'                                                                             Therefore, the analysis and consequences may represent a higher
                                                                                                                level of development than may actually occur at any specific time
             Exploration as well as    development should be allowed to occur under                             if the area were opened to leasing."
             unitized operations.      Further, given the proximity of state sub-
             merged lands, private     lands, and federal lands (1002 area onshore                              We would agree that the analysis represents a worst          case scenario
             and the OCS), unitization policy should be coordinated between all                                 and therefore most subsequent environmental effects outlined in
             lessors and their   managing entities.                                                             Chapter VI are overstated from what is likely to occur.
             Page      c2_1umn 2, item 5:    'Development, production and, transpor-                               e      paragraph 2:    For additional comments, see our Comment #5
             t, _          I from the 1002.area are considered to be independent                                Pag
               't@. on of 0.                                                                                    on pa::' 10 of this document. We feel that the designation of USFWS
             of any offshore production; however,           infrastructure could be                             Resource Category I for a portion of the calving habitat available
             shared.*                                                                                           to the PCH is inappropriate.      Significant year-to-year variability
                                                                                                                in calving distribution has been recorded for the Porcupine herd
             Please see previous comment on item 3 regarding unitization.                                       all across the coastal plain from well into Canada and west to the
             Given the proximity of state, federal, and private lands it is                                     Canning River.    Therefore, calving habitat is more appropriately
             possible that common reservoirs may extend under all categories of                                 represented as a true continuum across the coastal plain.              Thus,
             land ownership.     If this proves to be the case, the management of                               the 'unique and irreplaceable' nature required for designation as
             onshore land should not be considered independently of offshore                                    Resource Category I does not pertain.
      9      lands.
      14                                                                                                        Page  98, section on Effect on Physic I Geography and Processes:
                                                                in this Table seem to                           There are no mitigation sections in th                   I.,
      011    Page 91, Table 5-1-      Some of the estimates                                                                                                   subheadings:
             be overstated.      There does not appear to be a great deal of
             difference between the full leasing option and the limited leasing                                       "Consequences of Geological and Geophysical Exploration'
             option.   The number of facilities, amounts of gravel, and acres                                         'Consequences of Exploratory Drilling"
             indicated in the table seem excessive,             such As:      processing                              "Consequences of Development Drilling"
             facilities, permanent airfields, and drilling pads.          Table 5-1, as                               'Consequences Resulting from Construction of Roads, Pipelines,
             well as Figure 5-1 are very hypothetical cases. Development might                                        and Marine and Production Facilities"
             be something like this or it might be one large field or a
             combination.of closely located fields.                                                             Mitigation sections are found in the remaining two main subheadings
                                                                                                                in this chapter: 'Effects on Biological Environment' and 'Effects
             Page 92, column I  '_ P: Ida:raph 4:  "A program to drill off-structure                            on Socioeconomic Environment". thus it would seem appropriate to
             test wells wool  d pro       subsurface geological information.'                                   include mitigation sections in the 'Effects on Physical Geography
                                                                                                                and Processes." This is particularly true in           light of the very
             The drilling of additional wells/stratigraphic tests would not                                     large body of knowledge that has been developed over the past two
             necessarily determine the presence or absence of oil or the abso-                                  decades on this subject.       There are literally hundreds of proven
             lute presence or absence of the Ellesmerian section.                Industry                       mitigative techniques commonly applied on North Slope oilfields by
             feels that it has sufficient data to lease and explore for oil and                                 virtue of the fact that arctic environmental engineering is in a
             gas. Alternative C represents an unnecessary delay in.exploration                                  mature stage of development.
             and, ultimately, production.
                                                                                                                Pa                                                                        in-
                                                                                                                e2e laOtOi1o paragraph I and 2:     *Preliminary results of those
                                                                                                                v  tig     ns show gradients of increase in pH, salinity, alkali-
                                                                                                                nity, turbidity, and sediment loads from control ponds to ponds
                                                                                                                adjacent to reserve-pits (R.L. West and E. Snyder-Conn, unpublished
                                                                                                                data).   Trends of increase in the vicinity of reserve pits were
                                                                                                                also shown for heavy metals such as aluminum, barium, chromium,
                                                                                                                zinc and arsenic, as well as for certain hydrocarbons...."

             NS4:481/AOGA/02-04-87                _18-                                                          NS4:48l/AOGA/V-04-87                 _19-

             We feel that the conclusions regarding relative impacts from                                      remobilizing equipment is not necessary, c)          opening other gravel
             potential discharges of reserve pit waters are overly severe and                                  borrow pits is not necessary, and d)        the material will revegetate
             not substantiated by actual field monitoring data or current                                      naturally and rapidly.
             practice information from Prudhoe Bay areas. It is not appropriate
             for DOI to cite unavailable and unpublished data in support of                                    Page 100, paragraph 8:      'The almost unavoidable minor oil leaks and
             these allegations.     To the contrary, available data indicate that                              spill ..... which wc)u Id contaminate the tundra and, possibly, the
             -any impacts are extremely localized and limited to the immediate                                 aquatic environment    ......
             vicinity surrounding the pit.        No effects have been observed in
             fish or   wildlife species from active reserve pits and we feel                                   Spills of oil are easily noticed on ice and snow and rarely escape
             adequate  technology exists to close pits in an environmentally safe                              detection, even in quantities of less than a gallon.                Further,
             manner.                                                                                           these spills are easily and routinely cleaned up and disposed of
                                                                                                               properly.    All that is required is that the snowloil mixture be
             West and  Snyder-Conn report basic conclusions, cited in the draft                                scooped up by shovel or front end loader.         Thus, the actual amount
             1002(h)   report, that were derived from the misapplication of                                    of spilled   oil that lasts until spring is exceedingly minor.
             statistical analyses.      Based on the ANOVA analysis performed in
             West and Snyder-Conn's draft report, they would not have concluded                                Pa_g! . .1.0 1 Lparagraph 17:   *Construction of a solid-core cause-
             that ponds adjacent to reserve pits were significantly different                                  way     woul d require breaching to permit fish passage...."
             from con tro 1 ponds because they did not apply thq! statistics to
             answer  that question.     What they did conclude by their analyses,                              The breaching of gravel causeways f6r fish passage is not a neces-
             based on the comparison they carried out, was that reserve Pits                                   sary requirement.      Although fish do pass through large breaches
             differed from control ponds.          The difference was that USFWS                               (Endicott Environmental Studies 1985) they also go around causeways
             compared reserv4@'-pits to control ponds, and ARCO compared ponds                                 with and without large breaches (Endicott Studies 1985, Prudhoe Bay
             near reserve pits to control ponds.          There is no- question that                           Waterflood Studies 1981, 1982, 1983 and 1984).              The Waterflood
             reserve pit water quality differs from natural ponds.           The appro-                        studies demonstrated that the West Dock Causeway was not an impedi-
             priate question is how natural ponds near reserve pits differ from                                ment to the migration of large           fish.    The 1985 Endicott and
             control ponds.     USFWS has not adequately analyzed the data to                                  Colville River Fish Studies showed       that even the smallest migratory
             answer this question.                                                                             anadromous fish, young-of-the-year       Arctic cisco, were able to get
                                                                                                               by both the West Dock and Endicott       causeways to reach the Colville
             We recommend deleting any references to West and Snyder-Conn's                                    River.
             report or their conclusions.
                                                                                                               Page 103, paragraph 5:        Meehan    (1986) is a draft report that
             Page 100, paragraph 3:     'There are two approaches to abandoning an                             contains a significant number of       errors Including many erroneous
             exploratory well reserve pit:       1.  Leave it as is.'@ ....                                    conclusions on (1) gravel spray and (2) dust.                We also have
                                                                                                               significant additional concerns over the methods            used and data
             Recent studies in the Canadian Arctic (French, 1985) and in the                                   interpretations. We request that all calculations,           extrapolations
             NPRA, Alaska (Nuera Reclamation, 1986) document the minor environ-                                and conclusions based on Meehan (1986) be omitted.
             mental effects of abandoning a drilling reserve pit without
             closure.   However, it is current industry practice to 'button up"                                Pa                            'Since 1972
                                                                                                               .,ge  103'  paragraph 7:                     some 23,000,    mostly small,
             the reserve pit adjacent to exploratory wells.           All recent state                           il ls have been reported to the Alaska Department of Environmental
             and federal lease sale stipulations require complete closure and                                  Conservation.    The largest spill of 658,000 gallons was the result
             containment of reserve pits.      Therefore, the purposes of discussing                           of sabotage in 1978.     A spill of over 200,000 gallons near Atigun
             future options for reserve pit closeout on the Coastal Plain,                                     Pass in 1979....'
             option #1 is not relevant and should be deleted.
                                                                                                               It should be-pointed out that neither of these incidents occurred
             P e    0    _2aragraph 4:       ...... Therefore, this method requires                            on the North Slope, although they are an indirect outgrowth of
             r : g o b i Llf'_Yli ngconstruction equipment, opening a gravel pit else-                         North Slope development.
             where, and hauling in material to fill in and 'mound up" over the
             reserve pit area  .......                                                                         Page 104, paragraph 1:      *to date, the cumulative effect       of spills
             Recent experience from exploration wells on the North Slope do not                                has not been significant'.
             support this statement.      Reserve pits can be excavated into the                               We would concur with this assessment.        However, the main reason for
             permafrost and then closed out by filling with the original mineral                               the lack of significant impact is completely absent from the
             soil and capped by the tundra mat material.          This allows the pit                          discussion.    Of the 82,216 gallons spilled in 1985, very little
             conts-nts and capping soil to freeze back and        form a stable mound                          actually reached the environment because it was properly cleaned
             over the pit and to accommodate revegetation.        Experience indicates                         up.  The discussion leaves the reader to c-onii-Mude that all 82,216
             that a)   this method is a very effective mitigation technique, b)

             NS4:481/AOGA/02-04-87                -20-                                                         NS4:481/AOGA/02-04-87                 -21-

            gallons went into the tundra or wetlands.         Spill prevention and                             9.    Rehabilitation and     revegetation of disturbed sites,
            cleanup is aggressively pursued on the North      Slope and to date has                                  including gravel spray removal,        reseeding,    replacing
            been effective. Most spills occur on gravel       production pads while                                  damaged vegetation mat.
            snow is on the ground and are therefore easy to spot and cleanup.
            Those that do escape detection or occur in the summer off gravel                                   10.   Road watering to minimize dust generation.
            pads are treated with sorbent pads and rehabilitation and reve-
            getation procedures.                                                                               11.   Improved culvert design and placement to avoid impound-
                                                                                                                     ments.
            Page 104, paragraphs 4 and 6, Mitigation Section
                                                                                                          Pa   '04   paryra2h       "The expected modification of approximately
            The preceding discussion of impacts to vegetation, wetlands, and                              12?e650 Lcres   0 8 percent of the 1002 area) would be a moderate
            terrain  types covers in detail the possible impacts     from:                                effect (Table VI-1) on area vegetation and wetlands.*
                  1.   seismic surveys                                                                    The estimate of 5,650 acres for direct impacts of gravel appears to
                  2.   ice pads and roads                                                                 be reasonable based on the proposed scenario. Further, the classi-
                  3.   gravel pads and roads                                                              fication of moderate impact for this area is appropriate. However,
                  4.   reserve pits                                                                       classifying 7,000 acres of secondary impacts as moderate is either
                  5.   oil and fuel spills                                                                a)  too large an area to be placed in the moderate category, as
                  6.   gravel mining                                                                      defined, or b) too severe a category for that broad an area.
                  7.   secondary effects of roads, such as dust,     thermokarst,
                       gravel spray and impoundments.                                                     The moderate category requires either a *local modification of
                  8.   seawater spills                                                                    considerable severity* or a 'widespread modification of lesser
                                                                                                          severity". Since 12,650 acres is 0.8 percent of the Coastal Plain,
            The following Mitigation Section for these impacts      discusses only a                      it does not fit the category of 'widespread".       Therefore, the 7,000
            portion of these impacts and does 'so in the briefest possible                                acres of secondary effects are defined as local modification having
            manner.    It is not for lack of subject matter or data, however,                             'considerable severity*., It is difficult to defend the hypothesis
            since 18 years of Arctic experience and many millions of dollars                              that 7,000 acres of road dust, gravel spray and thermokarst would
            have been spent on effective mitigation techniques. The following                             reach this degree of impact.
            commonly   employed mitigation techniques should be discussed to
            properly   balance the discussion:                                                            Page 106, paragraph 2:    *Later studies (Cameron and Whitten, 1979,
                                                                                                          1980; Cameron and others, 1981; Whitten and Cameron, 1985)       indicate
                  1.   Snow depth,    routing and USFWS oversight procedures                              an absence of calving near the Coast at Prudho            ,e Bay during
                       followed during seismic surveys.                                                   1976-85, possibly due to avoidance of the activity area by       calving
                                                                                                          caribou'.
                  2.   Current accepted design parameters. for ice pads and
                       roads, (i.e. Brontosaurus welli NPRA, ARCO) that requires                          This is a widely quoted, through erroneous, conclusion of        the low
                       sufficient thickness, siting considerations.                                       numbers of cows with calves found in the Prudhoe Day area.         ADF&G,
                  3.   Site selection                                                                     for the peiiod 1978-85, reports average caribou densities        of 0.0
                                        criteria for roads and pads that avoid                            caribou/km while Gavin (1979) reports densities of 0.01-0.05/km
                       critical habitats.                                                                 for the predevelopment period of 1970-79.      Thus, the conclusion is
                                                                                                          that total caribou densities have always been low. In regards to
                  4.   The trend towards   smaller gravel pads and reserve pits,                          calving, inspection of Table I shows the same consistent low
                       decreasing the wellsite 'footprint'.                                               historical numbers with little'change through development.
                  5.   Aggressive fluid management of reserve pits to prevent                             At a recent caribou workshop at Alyeska (Demography and Behavior of
                       overtopping and leaking._                                                          the Central Arctic and Porcupine Caribou Herds in Relation to Oil
                                                                                                          Field Development, Oct. 1986) all ADF&G and USFWS participants
                  6.   Chemical screening of all reserve pit fluids prior          to                     including Messrs Cameron and Whitten, reached the consensus that
                       surface disposal to insure water quality standards are                             "the Central Arctic Herd (CAH) has never calved in the Prudhoe Bay
                       met.                                                                               area in large numbers.'
                  7.   Comprehensive oil spill contingency planning.                                      We suggest this paragraph and Table Vi-4 be amended to show this
                                                                                                          area as a historically low density calving area (see Table 1).
                  8.   Spill clean up procedures, including proper disposal of                            Regardless of the pre-development data the fact remains that this
                       contaminated snow in winter and sorbent pads in summer.                            herd has continued to proliferate during the period of maximum
                                                                                                          development at Prudhoe Bay.

            NS4:481/AOGA/02-04-87              -22-                                                       NS4:481/AOGA/02-04-87              -23-

                     TABLE I - TOTAL NUMBERS OF cows @ND CALVES WITHI14 THE                                  Page 106, paragraph 4.:     'The 242,000 acres of calving habitat are
                             PRUDHOE BAY AREA (1165 km ), 1970-1979.                                         proposed for designation as Resource Category I in accord with FWS
                                         From Gavin, 1980.                                                   mitigation policy.'
                                  Calves per                                   Densi ty 2                    We feel strongly that this is an inappropriate designation and
            Year   Cows Calves 100 Cows        Yearlings Bulls Total Caribou/km                              over-extension of the FWS mitigation policy.            We recommend that
                                                                                                             this designation be eliminated. See comment for page 98, paragraph
            1970    24      17        71            8                49        0.04                          2, above.
            1971    16       7        44            7                30        0.03
            1972      8      5        63            4                17        0.01                          Page 107, parMraft 2:         Calculations of secondary modifications
            1973    24       9        38            9                42        0.04                          should be changed to    exclude any data extracted from Meehan (1986).
            1974    34       9        27            8                51        0.04
            1973    27      13        48            4                44        0.04                          Page 17         and 109:    These three pages of literature citations
            1976    19       4        21            5                28        0.03                          dicu!.   th!"Prudhoe Bay caribou behavior studies in detail.            Data
            1977    14      11        79            3                28        0.03                          are reported which discuss disturbance and displacement of caribou
            1978    29      is        50            7         6      57        0.05                          movement patterns throughout the field as a result of developmental
            1979    13       7        50            a         4      32        0.03                          activities.

                                                                                                             We readily agree that some degree of modified behavior and dis-
                                                                                                             placement has occurred in response to habitat alterations in the
                                                                                                             Prudhoe field.      However as discussed in comments for page 28,
                                                                                                             paragraph 1, above, habitat is not limiting caribou population
                                                                                                             growth for any Alaskan herds at the present time.             Therefore, a
                                                                                                             degree of habitat loss as a result of development on the coastal
                                                                                                             plain will be inconsequential to growth and productivity of the
                                                                                                             herd.

                                                                                                             In the management of wildlife populations, the concept of habitat
                                                                                                             carrying capacity is the key to defining management goals for a
                                                                                                             herd.   It is an established fact that neither the CAH nor the
                                                                                                             Porcupine Herd approach the carrying capacity of their ranges.
                                                                                                             indeed* Sknog (1968) stated the *it seems likely that the Alaskan
                                                                                                             caribou population has remained far below range carrying capacity
                                                                                                             and that the total habitat has never been fully occupied.                  In
                                                                                                             reality, caribou populations seem to have maintained densities much
                                                                                                             lower than the maximum dictated by food alone, and hence the
                                                                                                             reduction in total range becomes less meaningful.' Thus, we agree
                                                                                                             with Skoog's conclusion that habitat is not currently limiting the
                                                                                                             growth of the Porcupine Herd and that the loss of habitat repre-
                                                                                                             sented by likely development in the 1002 area will not impact
                                                                                                             growth or productivity of resident caribou.

                                                                                                             P                                                    (1985) found consis-
                                                                                                             t:ge 107_ paragraph 5:      "Whitten and Cameron
                                                                                                                tly 10,   numbers of caribou and generally low percentages of
                                                                                                             calves in the Prudhoe Bay oilfield from their annual surveys of the
                                                                                                             CAH calving grounds, 1972-82, with caribou being displaced to
                                                                                                             adjacent areas already used for calving.'

                                                                                                             Based on Gavin (1980) which demonstrated consistently low numbers
                                                                                                             of caribou and low percentages of calves throughout the period
                                                                                                             1970-1979, the conclusion is reached that numbers have always been
                                                                                                             low in the Prudhoe Bay Region.       White et al. (1975) suggests that
                                                                                                             the high percentage of wet and moist areas near Prudhoe Say makes
                                                                                                             this area loss attractive to caribou. This was the conclusion of

            NS4:481/AOGA/02-04-87                -24-                                                        NS4:481/AOGA/02-04-87                -25-

               the Alyeska Caribou Workshop in October 1986 (see comments for page
               105, paragraph 2).                                                                                Page lo'L-pa   ragra ph 7:   -Based upon the work of Dau and Cameron
                                                                                                                 T1985), Carl   bou  are displaced approximately 2 miles out from
               Page 107, paragraph 5:     'Dau and Cameron (1985), in what may be the                            development ... within this 2 mile area of influence are about
               most systematic study of caribou displacement by oil development,                                 357,000 acres of the total core calving grounds in the 1002 area."
               reported that maternal caribou groups showed measurable declines in
               habitat use within approximately two miles on either side of the                                  This statement is a misrepresentation of the study conclusions.              in
               Milne Point Road in the Central Alaskan Arctic.'                                                  fact the relationship between calves and distance from the road
                                                                                                                 (Milne Point) is statistically insignificant. Dau and Cameron did
               The "two mile" reference is a typographical error.              The actual                        find fewer maternal groups near the road than away from it, but the
               distance is *two kmo.                                                                             partial displacement was for 2 kilometers, not 2 miles.

               Pa     108' paragraph 2:      'Displacement of the PCH from a core                                Additionally,    their data show, a high degree of year-to-year
               c,?e
                  vi ng area  to a less desirable area would be excepted to reduce                               variability -- so much so that they had to resort to a mathematical
               caribou productivity."                                                                            transformation of their data in order to show stabilized variances
                                                                                                                 so a test of significance could be run. Their data also show that
               -It is implied that any   displacement of the PCH would necessarily be                            non-maternal caribou were not displaced by the road corridor and
               into a less desirable     area.   As the report points out, there is                              that "partial displacement--was shown within a zone of 0-3 km.
               over two million acres of known concentrated calving area, not
               counting peripheral areas.       Since the PCH has calved throughout                              The USFWS uses these data to imply that a complete displacement of
               this area successfully in the past, and there is no known effect of                               all caribou groups occurred out to 2 miles.               This is a gross
               decreased productivity in the years that the herd used those areas                                over-extrapolation of the data and we ask that this section be
               exclusively, there is no reason to conclude that the areas outside                                rewritten to more propertly reflect the study results.
               the core calving area area less desirable. Therefore, the expects-
               tLon that the herd's productivity will suffer is not supportable.                                 Regardless of the conclusions regarding partial displacement, a
                                                                                                                 comparison of the study data from 1978 to 1985 clearly documents an
               Page 10:,          @h 3: Although the absolute density for the PCH                                increased density of animals through the period of maximum develop-
               Is almo t  partagra
                          14    .es, and the Western Arctic almost 15 times greater                              ment in the area.      We feel this increased density clearly demon-
               than the  CAH, none of these herds approach the carrying capacity                                 strates that the CAH has continued to grow and thrive concurrently
               of their respective ranges.         Therefore, any arguments against                              with the development of the oil field.           This conclusion must be
               extrapolation of CAH data to the PCH based on relative densities                                  noted in any discussion of the Dau and Cameron data.
               on the fact that the PCH may occupy coastal plain habitat in
               higher densities than the CAH are not valid.         (See comment to page                         Page 109, paragraph 6:        'If caribou refuse to cross through any
               107-109, above).                                                                                  development areas, E-hen 194,000 acres would be unavailable as
                                                                                                                 habitat.    That area encompasses 52 percent of total insect-relief
               We ask that the   above point be clearly made in the        conclusions of                        and over 80 percent of Coastal insect-relief habitats.           This would
               environmental impacts for alternative A.                                                          mean that all coastal insect-relief habitats within the 1002 area,
                                                                                                                 except for a small area in the eastern portion, would become
               lag    W.   paragraph 5:     *The lack of observable adverse effects                              unavailable under full development.
               fr N displacement exhibited by the CAH would be unlikely for the
               PCH.  The PCH is much more crowded in its calving habitats, and a                                 The hypothesis that the PCH would be eliminated from virtually all
               substantially greater proportion of important calving habitats                                    it's coastal insect-relief is predicated by the supposition that
               would be involved with development that included their core calving                               the PCH would *refuse to cross through any development areas'.
               area."                                                                                            There are no studies in the literature to support the hypothesis
                                                                                                                 that a properly designed pipeline and road would present a total
               The fact that the PCH has higher calving densities than the CAH is                                physical barrier to caribou movements.            Yet. there are abundant
               not sufficient to argue that displacement would be likely to cause                                examples of herds throughout the world regularly crossing roads,
               adverse effects.     Two other conditions would have to be met:            1)                     roads with pipelines, hunter's firing lines, and even improperly
               alternative high quality calving habitat is not available in                                      designed pipelines such as the Norilsk gasline in Russia (Shideler,
               sufficient quantities. The large area used by the PCH for calving,                                1986). The supposition is unsupportable.
               and their historical use and success in that habitat, would
               indicate that this is not the case. 2) The densities achieved by                                  Pa e 109, _paragraph 6:      "The second factor is to assume the ap-
                                                                                                                 p,g
               the PCH during calving are near some threshold limit above which                                      Ximatly pm@.le     sphere of influence for oil development used
               range destruction or negative intraspecific interactions would                                    previously.     Under that assumption, Caribou crossing through the
               occur. This has not been demonstrated.                                                            development area would avoid using approximately 72,000 acres or 29
                                                                                                                 percent of identified coastal insect-relief habitat withing the
                                                                                                                 1002 area...."

               HS4:481/AOGA/02-04-87                -26-                                                         NS4:481/AOGA/02-04-87                 -27-

            The 2-mile sphere of Influence is based on the Dau and Cameron                                 Although the conclusions of this paragraph are preceded with
            (1985) study that was conducted during the calving season, not                                 "could" and "if', the statements are still gross over-generaii-
            mosquito harassment season.       Conclusions regarding movement of                            zations with no basis in fact.      The extensive Prudhoe Bay exper-
                                                                                                           ience indicates that these statements are false. The Kuparuk River
            mosquito harassed groups seeking coastal areas cannot be drawn                                 oilfield experience clearly shows that caribou can and do readily
            from studies of the distribution of caribou during calving.           Dau                      move across developmental structures.       Proven mitigation measures
            and Cameron (1986) foundthat *during June, the relative number of                              such as elevated pipelines and crossings ensure that access to
            caribou within lkm of the (Milne Point) road was positively cor-                               insect relief habitat will remain.      Thus, projections such as 80%
            related with distance from the road; there was no relationship                                 loss of available relief habitat are unfounded.
            between number of caribou and distance from the road for either May
            or Jujy/Aug.' it is well recognized that measurable behaviors that                             We ask these gross generalizations be removed from the report.
            can occur during calving, such as avoidance, are often absent at
            other times of the year, such as during insect harassment.                                     P:ge 1.12a, paragraph 4:            could result in major population
                                                                                                           d :1in     d change in distribution of 20-40 percent                  this
            Page '10    paragraph 3 and 4:    Available literature clearly shows                           estimate is uncertain.'
            that caribou can 'nrdo      readily acclimate to aircraft overlight
            noise.   CAN animals throughe)ut the Prudhoe Bay area characteris-                             Although this projection is followed by the uncertainty statement,
            tically show little disturbance to typical overflights.                Any                     we feel strongly that this statement is completely unfounded and
            perceived negative effects can be readily mitigated by maintaining                             unsupportable.   No data are provided to support this estimate and
            a minimum aircraft altitude of 500 feet (AGL) during overflights.                              we are given no basis for its determination. We conclude that the
            Also the experience with the Delta herd, where calving grounds are                             estimate is highly speculative and ask that the entire paragraph be
            located next to overflight, bombing, and strafing areas, further                               deleted from the final report.
            documents the acclamation of these animals to aircraft noise.
                                                                                                           Pa e 111, PaEa2ra h         "For the CAN, a moderate change in dis-
                                                                                                           tr1buti.n     del?
                                                                                                                              ne
            Thus, we ask that this section be rewritten to more properly                                             or            n that portion of the CAN using the 1002 area
            reflect the acclamation of caribou to aircraft.                                                could occur.   The effect on the entire CAN population throughout
                        item 110: Reduction of surface occupancy in the insect                             its range may also be moderate.      Those effects on the segment of
                 11'.                                                                                      the CAN within the 1002 area would be similar to those on the PCH
            Pa?,                                                                                           that occur from disturbance, displacement and barriers to free
            re ef habitat to 3 miles from the coast.                                                       movement.   The population decline or distribution change would be
            in the Kuparuk River oilfield, experience has shown that 3/4 mile                              5-10 percent for the CAN throughout its range."
            of reduced occupancy from the coast is sufficient to ensure
            adequate insect relief habitat.      This distance appears sufficient                          The basis for concluding that a moderate change         in the CAN dis-
            since actual insect relief habitat Is the coast line proper,                                   tribution or numbers has not been presented.       in fact, all the data
            shallow coastal water, offshore islands and coastal bluffs - a                                 presented would lead one to the opposite conclusion.            There is
            relatively narrow band.      Once this narrow band Is provided, the                            abundant discussion in the report regarding why the CAN is dif-
            second requirement is to provide for relatively free movement along                            ferent and can be expected to respond differently to development
            the coastline.     Elevated pipelines and other normal mitigation                              than the PCH. The facts of lower overall densities, lower calving
            measures similar to those applied in the Kuparuk Oilfield have                                 densities, more distributed rather than concentrated calving,
            proven effective     in allowing passage.         Thus,   we   ask    this                     incomplete range utilization, greater habituation and the over-
            stipulation for a 3 mile reduced surface occupancy zone be changed                             whelming fact that the CAN has already demonstrated its accom-
            to reflect the currently proven experience of 3/4 mile.                                        modation to development are all discussed In the report.          All of
                                                                                                           these argue towards a minimal impact of the proposed scenario on
            P                                                                                              the CAN.   Further, the proposed development scenario borders the
            cge lt1Y2, fparagraph 2:    Neither the CAN nor PCH are      at carrying
              paci      or  their respective ranges and therefore         incremental                      extreme eastern extension of the CAN'S calving areas, while it
            habitat loss due to development of the coastal-plain can be expect-                            overlaps substantially with the PCH.      Given all these differences
            ed to result in only minimal displacement of the herd. See comment                             discussed in detail in the report, it appears to be inconsistent
            page 107-109 above.                                                                            with the conclusion that the 'effects .... would be similar.' The
                                                                                                           qualification of 'on the segment of the CAN within the 1002 area"
            Page  ",    paragraph 3:   'A major change in distribution.          could                     is specious because there is no distinct subpopulation of the CAN
            .v                                                                      of
               .cu r if the 1002 area were fully developed     . . .  nearly 80%                           that  uses   the   1002   area.    That   a    population    decline    or
            coastal insect relief habitat could be affected if development                                 distribution change would be 5-10 percent' is not supportable.
            proves to be a barrier to caribou movements.'                                                  Based on Table VI-1, the environmental effect on the CAN should be
                                                                                                           negligible.

            NS4:481/AOGA/02-04-87               -28-                                                       NS4:481/AOGA/02-04-87              -29-

             Predicted population declines, particularly in the CAB cannot be                               P      111,                 'Table VI-6 shows that habitat values c'
                                                                                                            gge         paragraph 4:                                                 ould
             supported by any scientific or logical hypotheses.          In fact, the                           lost , or greatly reduced throughout about one-third (256,000
             CAR has continued to grow at a 13% year rate while continuing to                               acres) of the muskox range within the 1002 area.'
             calve in areas of oil development.         A prediction of population
             decline for the CAR, based on oil development in the fringe areas                              These figures should be decreased by at least half based an the
             of their calving habitat, directly contradicts the results of 10                               previous discussion.
             years of detailed scientific study of the CAR.
                                                                                                            Pase 114, paragraph I and 2: We feel that the conclusions regard-
                                                                                                            Ing potenti,
             PAN          cagraph 3:   *Displacement from calving areas would have                                        , developmental effects on muskox are unnecessarily
             a negNbep:ffect on muskoxen production.'                                                       severe and unfounded.       While it is true that very little data
             Displacement from calving areas may have a negative effect on                                  characterizing muskox responses to oil field development are
                                                                                                            available, it is also true that the muskox has shown ready
             muskoxen production if they are near or at their pl)per limit of                               adaptability to human presence and has even been semi-domesticated
             utilizing all hiqh mra-lity ca-1`vTng--Ea:bMat througnout theff                                in several areas. This adaptability to human presence will signi-
             The high pr-RuRtIvity reported for the ANWR muskox population has                              fi6antly reduce the worst-case conclusions implicated in the DEIS.
             been' attributed to the availability of preferred forage during
             summer (Robus 1981) and to the tendency for herds to remain in                                 Several experimental farming programs have been successfully
             relatively restricted home ranges, thereby capitalizing on the                                 initiated in Alaska and Canada to domestically raise muskox for
             abundant forage (Jingfors 1980).      As the 1002 report points out,                           their high quality quivit, or underwool, to be used in the knitting
             .carrying capacity has apparently not been reached." Thus due to                               industry. obviously their adaptability to constant human presence
             the fact that the herd is still expanding its range, and that high                             in these situations significantly reduces concerns over occasional
             productivity rates have been tied to abundant forage, it does not                              and distant disturbances from developmental interests.              Limited
             follow that     displacement would have a negative effect on                                   observations of muskox response to oil exploration activities in
             productivity.                                                                                  Greenland indicate that muskox respond by a gradual and temporary
             M
             P e W.     paragraph 1:     "From the reports of Russell (1977) and                            avoidance to seismic activities.
              yNoifa_. and L. plan  t (1985), a 2 mile sphere of influence was                              We ask that this section of the report be re-written to pro.-erlY
             assumed in calculating the range which could be affected by full                               reflect the adaptability of muskox to human presence and thus
             leasing.'                                                                                      reduce the severity of the projected effects.
             The term 'affected' is defined in the next sentence as 'lost or
                                                                                                            f:.gme hllbf paragraph 9:   *Effects on the regional moose population
             greatly reduced.' Thus the 2-mile area is being defined as an area                                       tat loss and mortality due to oil development in the 1002
             where muskoxen are removed by 100% (lost) or decreased by an amount                            area would be minor.*
             in the range of 60-90% (greatly reduced).         The data of Reynolds
             and LaPlant (1985) show that a flight response occurred in only 7                              Due to the very low population of moose on the Coastal Plain, the
             of 31 groups (23%) encountered in the Tamayariak area (Table 1) or                             extremely low loss of habitat expected, the ability of moose to
             the Okerokovik   area (Table 3).    This flight response occurred at                           habituate to disturbance and the ability of ADF&G to regulate moose
             distances from 200 m to 3.2 km, or an average of 1.5 km.         Based on                      harvest, it is reasonable to expect a negligible, rather than a
             these data, one would have to significantly increase the stimulus,                             minor, effect.
             or shorten the 2-mile sphere of influence, or both, to reasonably
             expect a 50 to 100% displacement In muskoxen. Four of the 9 groups                             P
                                                                                                            U:?e   "'. paragraph 6: "A moderate decline of the wolf population
             (44%) displayed no response at distances less than a km.         It is not                        ng the 1002 and surrounding area could result from the cumula-
             sound scientific judgement to pick the farthest distance reported                              tive effects of direct mortality and reduced production or survival
             for a flight reaction (3.2 km) and then conclude that most or all                              of ground, caused by reduced prey availability."
             of the animals will behave in a similar manner, when the Reynolds
             and LaPlant data show that only 23% actually did. This is particu-                             As pointed out in the state references, there is indeed a relation-
             larly true since habituation is known to occur in muskoxen, as the                             ship between the abundance of wolves and the biomass of ungulate
             report states.                                                                                 prey.   However, even if one hypothesizes a 40% decline in the PCH
                                                                                                            from 180,000 to 100,000 animals, it is difficult to demonstrate
             Thus, the assumption that a 2-mile sphere of influence is appro-                               that 5 to 10 wolves would be in any way limited by a herd of such
             priate for a complete displacement of muskoxen is not supportable                              magnitude.    The cited references all deal with wolf/caribou den-
             by the data.                                                                                   sities that are orders of magnitude higher than 0.00002 to 0.0001.
                                                                                                            Further, no consideration is given to alternate prey species.

                                                                                                            The environmental effect on wolves from the proposed development
                                                                                                            should be changed to negligible.

             NS4:481/AOGA/02-04-87              -30-                                                        NS4:481/A OGA/02-04-67              -31-

                  III     column       p rpggph          This paragraph discusses
                  .r.I .?fee,.       .r.In
            PMvi                 on              .1!:                                                       Davis and Wigely's discussion of the energetic effects of
                                                                                                                                                                               distur
                                                                                                            bance is questionable because the authors assumed that disturbance
            The last sentence should be modified     to  add "however, a large body                         reaction time would subtract in equal proportions from all other
            of data indicates that there are none.'                                                         activities.    A more conservative approach would be to assume that
                                                                                                            the geese were capable of at least some compensatory increase in
                  t1O                                                                                       feeding rate.    The estimates of 20.4% reduction and 9.5% reduction
                    .,.paragraph 11: All references      to the West and Snyder-Conn
            P:-q:r     ul                                                                                   in energy reserves acquired by juvenile geese subjected to 2-hour
            R p          d be deleted for the reasons provided earlier in the
            comments on page 100, paragraph 1 and 2.                                                        interval fixed-wing and helicopter overflights, respectively, are
                                                                                                            probably overestimates       of  the   bioenergetic     impact   of    these
            Pa e  111, @ara r h 7:       Table VI-7 shows the amount of habitat                             disturbances.
            tH 4t
               a  cou   be at?ec"teU by development resulting from full leasing,
            assuming  snow geese. are displaced 1.5 and 3 miles. as observed by                             Page 122, paragraph 2:     *The average number of snow geese annually
            Gallop and Davis (1974)."                                                                       staging on the 1002 area could be reduced by almost 50 percent."

            The reactions of fall-staging snow geese to noise were studied by                               The affected habitat has been grossly overstated based on a mis-
            Gollop and Davis (1974) and Wisely (1974). -In those studies, gas                               application.of Gollop and Davis's results and the assumption that
            compressor noise simulators were placed in fall-staging areas and                               geese could not compensate for lost feeding time or habituate to
            the reactions of flying and feeding flocks were observed with and                               disturbance.    This has led to an equally gross overstatement of the
            without noise production.      Some general conclusions, which cannot                           potential effects on snow geese.
            be evaluated-quantitatively, included:
                                                                                                             a e       p:ragraph 2: Recently conducted extensive monitoring in
                       noise may decrease the number of flocks 'that land at a                                g    22trn
                  1.                                                                                        the Lisb       field provides data to reduce concerns over geese and
                       particular site:                                                                     brant displacement.     Avian monitoring has shown that a brant colony
                                                                                                            has successfully nested in this area since the 1970's with no
                  2.   noise may cause   a temporary alteration In the flight path                          decrease in productivity.       The density of geese and swans using
                       of geese flocks;                                                                     this area has not changed from pre-construction (1983-84) to
                                                                                                            post-construction (1985).      Geese broods actually cross       roads and
                  3.   geese may avoid   feeding sites where high noise levels are                          pipelines into the Lisburne area.         Brant continuously     utilize a
                       present;                                                                             marsh at the mouth of the Putuligayuk River within 400           meters of
                                                                                                            one of the busiest roads on the North Slope. Snow geese          occasion-
                  4.   feeding flocks    may react to the sudden occurrence of                              ally move into the Lisburne area to feed and rear young,         often im-
                       gas-compressor   type noise up to 3 miles away (Gollop and                           mediately next to busy roads. Also, white-fronted geese          often nest
                       Davis 1974); and                                                                     close to roads.

                  5.   feeding flocks may approach to within 300 meters of                                  We ask that this section be modified to include these important new
                       continuously-operating gas-compressor noise simulators,                              data from Murphy et al. 1986.         'Lisburne terrestrial monitoring
                       but most flocks appear to avoid the area within 800                                  program - 1985.    The effects of the Lisburne development project on
                       meters in front of such noise simulators (Wisely 1974).                              geese and swans.'

            Gollop and Davis (1974) did observe some snow geese disturbance up                              Page 123, paragraph 4:       'Recent work near Prudhoe Bay has shown
            to 3 miles, but, as with other studies cited in the 1002 report,                                that reduced numbers of shore-birds occur near roads in the oil
            this should not be given as an adequate indication that geese would                             field (Troy and other, 1983; Troy, 1984).'
            be totally displaced out to 3 miles.         In fact, Gollop and Gavis
            report in their Table 8 that the mean distance that snow geese                                  Troy's work also shows increased habitat use near roads for several
            flared under simulator tests was 365 yards, or 0.2 miles.             Thus,                     species, including Northern Pintails, Red-Necked and Red Phalaropes
            the 1.5 and 3 mile limits suggested by the report are gross overes-                             in impoundments, and Semi-palmated sandpipers in dust induced early
            timates and are not supported by the cited literature.                                          melt zones.
            P:ge 121,_ paragraph 8:       'Reduced time spent feeding and lost                              Pagene1216ig paragraph 1:   We support the conclusion that only minor
            h bitat I. which to teed would result from petroleum development,                               to    g    ible etfects on coastal fishery resources or fishery
            adversely affecting accumulation of the energy reserves essential                               habitat will occur.       Experience at Prudhoe Bay has provided a
            for migration.      Davis and Wisely (1974) estimated that staging                              significant volume of data to support this viewpoint.
            juvenile snow geese unable to adjust to aircraft disturbance
            accumulated 20.4 percent less energy reserves due to lost feeding
            time.'

            NS4:481/AOGA/02-04-87               -32-                                                        US4:481/AOGA/02-04-87               -33-

                   126, clumn          ragr-Ph 5,    We also support the conclusions                           Stipulations 5:         Prohibit off-road vehicle use within 5 miles of
                %,                       mpct. on
             pac
             If     or to =.g ig-blp, i             endangered and threatened animal                                                   all pipelines, pads, roads, and other facili-
             species such as bowhead and grey       whales and the peregrine falcon.                                                   ties, except by local residents engaged in
             We feel that the transient nature of their presence on the coastal                                                        traditional uses or if otherwise specifically
             plain and the history of developmental interaction in the Prudhoe                                                         permitted.
             Say field clearly demonstrate the lack of meaningful impacts on
             these species.                                                                                                            Comment:    Prohibiting all activities in all
                                                                                                                                       seasons is too restrictive.       This stipulation
             pag   129_ coLumn 2gleparagraph 4      :   Based on the preceding con-                                                    should be limited to summer season only and not
             clu:ion, of egng.          to minimal effects on wildlife Populations                                                     be applied to research, surveyingf seismic
             as a result of development, there remains no reason to assume that                                                        work, etc. approved by USFWS.
             major effects on subsistence uses will occur.           Therefore, we ask
             that this paragraph be deleted.                                                                   Stipulation 6:          Limit oil exploration, except surface geology
                                                                                                                                       studies, to November I-May 1 (exact dates to be
                           'umn 2'   paragraph 4-    We woul -d like to underscore the                                                 determined by Refuge Manager).       Cease explora-
             P      'lfycl           of                                                                                                tion activities and remove or store equipment
             fflihlve     qo-w value     the coastal plain as recreational habitat.
             History of use indicates that only a handful of individuals have                                                          at an approved site by May 15.         Local excep-
             actually utilized the coastal plain for recreation, either hunting,                                                       tions may be made.
             fishing or camping. It is extremely expensive to reach the area; a
             trip from the contiguous states costs thousands of dollars and                                                            Comment: Seasonal restriction might be appro-
             requires air charter flights. Wet and moist ground conditions make                                                        priate for intensive human activity such as
             hiking difficult during the 8-10 week *summer".          Extreme cold and                                                 construction but should allow activities less
             darkness    during   a   large   part   of    the  year    further    reduce                                              likely to interfere with animal behavior to
             recreational use.                                                                                                         continue. Activitiesin this category would be
                                                                                                                                       those largely confined to the drill pad and
             We ask that these perspectives be added to this section of the                                                            required support and would include drilling and
             report.                                                                                                                   testing of wells. When recognizing that such
                                                                                                                                       prohibition cannot reasonably be applied during
             Page 134t paragraph 6 and 7:          See comment above for page 112,                                                     any subsequent development activities, USFWS
             paragraph 4.                                                                                                              should allow those activities while being
                                                                                                                                       conducted as part of an approved research
             Page 140, next to last paragraph: Seismic Trails:                                                                         program to determine actual effects on wildlife
                                                                                                                                       and to develop better mitigation techniques if
             This paragraph should be modified to add 'although, seismic trails                                                        needed for development. Restriction on drill-
             can only be detected from the air after two or three years.'                                                              ing and testing could cause exploratory wells
                                                                                                                                       to take two or more years to complete, which
             Page 143, paragraph 6:       See comment above for page 6, column 2,                                                      extends environmental exposure, may compromise
             paragraph 5.                                                                                                              well safety and control, and significantly
                                                                                                                                       increases the cost of the well.
             Pages 145-147, summary of Recommended Mitigation
                                                                                                               Stipulations 8
             Stipulation 2:          Design all bridges and culverts to handle at                                9    10:              Elevate pipelines to allow free passage of
                                     least 50-year flood events.                                                                       caribou in areas without ramps or buried
                                                                                                                                       sections.
                                     Comment:   Insert 'permanent' before the word
                                     bridges.                                                                                          Place ramps over pipelines at natural cro sings
                                                                                                                                       or where development tends to funnel anim:ls.
             stipulation 3:          Use ice or gravel-foam-timber pads, where
                                     feasible, for exploration wells.                                                                  Bury pipelines where possible.

                                     Comment:   There may be limited use for ice                                                       Comment:   Stipulations 8, 9, and 10 appear to
                                     padst however, the use of pad material must                                                       prefer buried pipelines.      Surial of pipelines
                                     ensure a safe and successful completion of the                                                    is unnecessary where elevation and ramping are
                                     operations plan.                                                                                  used to accommodate movements of animals.
                                                                                                                                       Buried pipelines      are    not    environmentally

             NS4:481/AOGA/02-04-87                -34-                                                         NS4:481/AOGA/02-04-87                -35-

                                 preferred on the North slope due to permafrost                                              Comment: Subsistence trapping without firearms
                                 Moreover, burying causes more environmental                                                 should be allowed.
                                 impact   initially   and   during    abandonment.
                                 Suggest adopting the current State of Alaska                          Stipulation 23:       Define range of the candidate plant Thlaspi
                                 policy:    To minimize    impacts on caribou,                                               arcticum.    Minimize     surface  occupancy     in
                                 pipelines must be consolidated to the extent                                                immediat    vicinity of     areas  identified as
                                 feasible  and must be designed, sited and                                                   supporting  the plant. Position pads, collect-
                                 constructed to allow safe passage of caribou.                                               ing lines, and associated roads at least 1/2
                                 Adequate elevation,     ramping    or  burial   of                                          mile from candidate plant locations.
                                 pipelines will be required in areas identified
                                 by (Department of Fish and Gamel USFWS as                                                   Comment:    It appears that a feasible and
                                 important caribou movement zones.                                                           prudent effort to avoid adverse impacts to the
                                                                                                                             plant would be reasonable:       1/2 mile buffer
           Stipulation 11:       Separate roads and pipelines 400-800 feet,                                                  appears excessive and unnecessary.
                                 depending on terrain, in areas used for caribou
                                 crossing.                                                             Stipulation 24:       Construct  docks and causeways so that fish
                                                                                                                             movements are not impeded and       lagoon water
                                 Comment:  The combination of roads near pipe-                                               chemistry  is basically unchanged.
                                 lines is   considered a deterrent to caribou
                                 crossing,  primarily when there is high human                                               Comment:   Policy needs to focus    on potential
                                 use (traffic) of the road, therefore, it is                                                 Impacts:   suggest wording I ... and lagoon water
                                 unnecessary to have all roads separate from                                                 chemistry not be altered to a       degree which
                                 pipelines.   This policy conflicts with the                                                 causes significant adverse effects on marine
                                 basic desire to consolidato facilities.           A                                         populations."
                                 preferable wording of this stipulation may be
                                 *separate high use trunk roads and pipelines                          Stipulation 25:       Establish time and area closures or
                                 400-800 feet,...'                                                                           restrictions on surface activity in areas of
                                                                                                                             wildlife concentration during muskox calving,
           Stipulation 12:       Restrict surface occupancy in the zone from the                                             April 15-June 5; caribou calving, May 15-June
                                 coastline inland 3 miles to marine facilities                                               20; caribou insect harassment, June 20-August
                                 and infrastructure necessary to support activi-                                             15; snow goose staging, August 20-September 27
                                 ties outside the restricted zone.                                                           and overwintering and spawning.

                                                                                                                             Comment: This stipulation should specifically
                                 Comment:   This   restriction   could    preclude                                           exclude restrictions on activities confined to
                                 access  to   and  development    of   significant                                           an exploratory drill pad such as drilling and
                                 reserves.  Temporary exploration facilities and                                             testing being conducted in conjunction with a
                                 essential  production     facilities   should   be                                          USFWS approved research program to determine
                                 allowed on a site-specific basis.                                                           effects on evaluation (key) species.
           Stipulation 14:       Close areas within 3/4 mile of.high-water mark                        Stipulation 26:       Acquire authority to establish time and area
                                 of specified water courses to permanent facili-                                             closures and minimum aircraft altitude of 2,000
                                 ties  and   limit    transportation    crossings.                                           feet above ground level (AGL) during muskox and
                                 Gravel removal may occur on a site-specific                                                 caribou calving and caribou insect harrassment,
                                 basis.                                                                                      April 15-August 15; and snow goose staging,
                                                                                                                             August 20-September 25.     At other times the
                                 Comment:  A 3/4 mile buffer is an excessive                                                 minimum altitude generally will be 1,000 feet
                                 restriction.  Maximum effort to protect crit-                                               AGL over areas of animal concentrations.
                                 ical riparian habitat should be required;
                                 however, essential production facilities should                                             Comment:   It is unnecessary to have time and
                                 be allowed on a site-specific basis.,                                                       area closures In addition to minimum altitude
                                                                                                                             restrictions.
           Stipulation 21:       Close area within 5 miles of development and
                                 associated infrastructure to hunting, trapping
                                 and discharge of firearms.

           VS4:481/AOGA/02-04-@87            -36-                                                      tIS4:481/AOGA/02-04-87            -37-

                           Found   in the USFWS/ASRC Agreement          Stipulations                      Stipulation:     When an exploratory,well bottom hole depth,will not
                  '111031                                                                                                  exceed .10,000 feet true vertical depth, the well
            !App':n
                                                                                                                           shall be drilled from an ice pad with piling support,
                                                                                                                           for the drill rig.
            Stipulation:    Exploration activities will be supported only by ice
                            roads, winter trails, existing road systems, and air                                           Comment:   Stipulations should allow the      use of pad
                            service.                                                                                       material which will ensure a safe and         successful
                                                                                                                           completion of the overall exploratory         operations
                            Comment:    This stipulation should recognize the                                              plan. Bottom hole depth may not be the most impor-
                            need for  barges and boats for marine support.                                                 tant criteria in determining a proper pad.           This
                                                                                                                           stipulation should be reworded to read;         'When an
            Stipulation:    The operator shall not significantly alter the banks                                           exploratory well program can be safely accomplished
                            of streams, rivers, or lakes while conducting                                                  from an ice pad, it is preferred that the well be
                            exploration activities. Crossings of stream, river,                                            drilled from an ice pad with piling support for the
                            or lake banks shall utilize 'a low angle approach or,                                          drill rig ...
                            if appropriate, snow bridges.      if anow.bridges are
                            .utilized for bank protection,   they shall be free of                        Stipulation:     The Regional   Director is authorized to designate.
                            dirt and debris and shall be      removed after use or                                         within ASRC    Lands special caribou calving and,
                            prior to breakup each year, whichever occurs first.                                            post-calvin.9  special areas that will be closed to
                                                                                                                           all exploration activities for such periods from May
                            Comment:    The need for the removal of ice bridges                                            I through August 31 of each year as are designated
                            after use or before breakup is not readily apparent.                                           by the Regional Director to ensure that exploration
                            If the intent is to prevent flooding, the stipula-                                             activities do not significantly adversely affect
                            tion should so state, and allow alternatives such as                                           caribou    calving    and   post-calving     activities,
                            selective or partial removal of ice.bridges.                                                   including but not limited to, relief from insects.
                                                                                                                           The Regional Director may shorten the period of
            Stipulation:    Reserve Otte shall be rendered impermeable by a                                                closure or reduce the area closed if it is deter-
                            design of the operator's choice, other than reliance                                           mined that caribou are not using the area.
                            upon permafrost.                                                                               C.omment:   special, . area stipulat  . ions .. should be
                            Comment: For below-grade (excavated) designed pits,                                            modified to allow continued exploration drilling and
                            permafrost provides an impermeable barrier. suggest                                            testing while conducting        research     programs   to
                            deleting the words *other than reliance upon.perma-                                            determine the effects on these species (see our
                            frost.* This stipulation should defer to existing                                              comments on Stipulation 16 of the,1002h report).
                            reserve pit regulation in this matter.
                                                                                                          Stipulation.:    The Regional Director is authorized to designate
            Stipulation:    All hydrocarbons discharged into flare and relief                                              within ASRC Lands specific snow goose staging
                            pits shall be removed and properly disposed of as                                              special areas that will be closed to all exploration
                            soon as practicable during the winter but prior to                                             activities for such periods from August 20 through
                            spring breakup, except that during periods of thaw                                             September 10 of each year as are designated by the
                            such   removal shall occur within 72 hours of                                                  Regional   Director    to   ensure   that    exploration
                            discovery.                                                                                     activities do not significantly adversely affect
                                                                                                                           snow goose staging.       The Regional Director may
                            Comment:    This language from the COE AAP Special                                             shorten the period of closure or reduce the area
                            condition C is under revision by the COE to read:                                              closed if it is determined that snow geese are not
                            'Hydrocarbons discharged into relief pits, flare                                               using the area.
                            pits, or reserve pits shall be contained and pro-
                            perly disposed of as soon as practicable.         Removal                                      Comment:    Special    area. stipulations     should be
                            shall minimize waste generation and all hydrocarbons                                           modified to allow continued exploration drilling and
                            which are removed shall be disposed of in a manner                                             testing while conducting        research     programs   to
                            consistent with all pertinent regulations.'                                                    determine the effects on these species (see our
                                                                                                                           comments on Stipulation #6 of the 1002h report).

            NS4:481/AOGA/02-04-87              -38-                                                       11S4-48I/AOGA/02-04-87              -39-

          Stipulation:     The Regional Director is authorized to designate                                                          LITERATURE CITED
                           within ASRC Lands specific waterfowl nesting habitat
                           special areas that will be closed to all exploration
                           activities for such periods from May 25 through                              Bergerud, A. T., R. D. Jakimchuk and D. R. Carruthers, 1984.          The
                           August I of each year as are designated by the                                     Buffalo of the North:     Caribou (Rangifer tarangus) and Human
                           Regional Director to ensure that exploration activi-                               Developments. Arctic 37(l): 7-22.
                           ties do not significantly adversely affect waterfowl
                           nesting habitat. The Regional Director may shorten                           Colville River Fish studies, 1965, by Entrix for ARCO Alaska, Inc.
                           the period of closure or reduce the area closed if
                           it is determined that waterfowl nesting is not                               Dau and Cameron, 1986.     Responses of Barren Ground Caribou to
                           occurring within the area.                                                         Petroleum Development Near Milne Point, Alaska.          Report to
                           Comment:    Special   area   stipulations    should    be                          Conoco Inc. and ADF&G.
                           modified to allow continued exploration drilling and                         Davis et al., 1983.     Disturbance and the Delta Caribou Herd in
                           testing   while   conducting   research    programs    to                          Caribou and Human Activity, edited by A. M. Martell and D. E.
                           determine the effects on these species (see our                                    Russel, Procedures of Ist North American Caribou Workshop,
                           comments on Stipulation f6 of the 1002h report).                                   Whitehorse, Yukon 28-29, September 19B3.
          Stipulation:     Sand and gravel extraction, processing or storage                            Endicott Envi,ronmental Studies 1985.      Prepared by Envirosphere for
                           sites shall not be located within the active flood-                                the U.S. Army Corps of Engineers and Standard Alaska Produc-
                           plains of water courses as defined       in the Gravel                             tion Co.
                           Removal Guidelines Manual for Arctic and subArctic
                           Floodplains   (USFWS 1980),     unless 'there are no                         French, H. M., 1985, Surface Disposal of Waste Drilling Fluids,
                           feasible and prudent alternatives.        In the event                             Ellef   Ringnes   Island,   N.W.T.:     Short-term    observations,
                           that there,is no feasible and prudent alternative to                               Arctic, Volume 38, No. 4, pgs. 292-302.
                           sand and gravel extraction, processing or storage
                           within the active floodplain of water courses, and                           Gavin, A., 1980.    Coastal Oil Development and its Effects on
                           in the event that such sand and gravel extraction,                                 Caribou Migration and Population Patterns in the Prudhoe Bay
                           processing   or   storage otherwise     satisfies     the
                           environmental protection safeguards of these stipu-                                Region of Alaska's 11orth Slope, 1969-1979.
                           lations, sand and gravel extraction, processing or                           Jingfors, K. T., 1980.     Habitat Relationships and Activity Patterns
                           storage in active floodplains shall be undertaken in                               of a Reintroduced 14uskox Population.       M. S. Thesis, Univer-
                           accordance   with   the  provisions    of  the    above-                           sity of Alaska, Fairbanks.     115 pgs.
                           referenced Guidelines, to the extent practicable.
                                                                                                        Keith, L. B., 1981. Population      Dynamics of Wolves in Wolves in
                           Comment:   Suggest language consistent with 1002                                   Canada and Alaska, edited    by L. N. Carbyn, Caii-adian Wildlife
                           Report Stipulation 7 which limits the application of                               Service Report #45.
                           the prohibition to major fish-bearing rivers.
                                                                                                        Nuera Reclamation, 1986. Final      Wellsite Cleanup on National
                                                                                                              Petroleum Reserve - Alaska, Volumes I-III, under U.S. Geolo-
                                                                                                              gical Survey Contract #14-08-001-21787.

                                                                                                        Prudhoe Say Waterflood Environmental Monitoring Program, 1981-1984
                                                                                                              by variou's authors for U.S. Army Corps of Engineers..

                                                                                                        Robus, M. A., 1981. Muskox Habitat Patterns in Northeastern
                                                                                                              Alaska.   M. S. Thesis, University of Alaska, Fairbanks.          116
                                                                                                              p9s.

                                                                                                        Shank, C. C.,   1979. Human-related Behavioral Disturbance to
                                                                                                              Northern  Large Mammals: A bibliography and Review. Foothills
                                                                                                              Pipe Lines (South Yukon) Ltd., Calgary. 246 pgs.

         NS4:481/AOGA/02-04-87               -40-                                                       NS4:481/AOGA/02-04@87               -41-

    	Shideler, R. T., 1986 impacts of human Developments and land use
    on caribou: A Literature Review. Volume II. Impacts of oil
    and gase development on the central Arctic herd, Technical
    report no. 86-) ADFAG.

    Skoog, R, O., 1986. Ecology of the caribou (Rangifer tatandus
    Granti) in Alaska. Ph. D. bissertation university of
    California, Berkeley. 669 pgs.

    U.S. Fish and Wildlife service, 1982. Initial Report, Baseline
    study of the fish, wildlife, and their habitats, section
    1002 (c) of the Alaska National Interest Lands Conservation
    Act: Anchorage, U.S. Fish and wildlife service, Region 7.
    507 pgs.

    White, R. G., D. R. Thomas, T. Skogland, S. J. Person D.E.
    Russell, D. F. Holelman, and J.R. Luick. 1975 Ecology of
    caribou at Prudhoe Bay, Alaska. Pages 151-197 in J. Brown,
    ed. Ecological investigations of the tundih Bione in the
    Prudhoe bay region, Alaska. Univ, Alaska Biol. Papers, spec.
    rept. No. 2, Fairbanks.

    Ns4:481\AOGA\02-04-87    -42-

    	CHAPTER VII-oil and Gas--
    National need for domestic Sources and the 1002 Area's
    	Potential contribution

    comment 1- The 1002 Area's Potential contribution to U.S. needs

    We agree that the 1002 area has very significant potential. All
    of the geologic factors faborable for significant oil and gas
    discoveries exist in the 1002 area, including source rocks that
    generate oil and gas, thick sequences of reservoir rocks, large
    structures to trap petroleum and a favorable geologic history.
    The location of the 1002 area between major petroleum provinces,
    i.e., Prudhoe Bay and Mackenzie Delta, and the basin's extension
    of know productive trends maek the area especially prospective.
    of all untested onshore areas of the United States, the 1002 area
    is th emost promising area for discoveries of major oil and gas
    fields.

    comment 2- Constribution to Domestic oil demand and supply

    There is a rapidly growing gap between domestic consumption and
    production capability of U.S. engergy supplies. As stated on page
    163, paragraph 1, *oil reserves decreased over 27 percent, about
    11 billion barrels from 1970 to 1985 and declined annually during
    14 of these 15 years despite extensive exploration and active
    field exploitation programs. The trend of declining domestic
    reserves and production is accelerating. In 1985 domestic crude-
    oil production was 6.9 million barrels per day average. The
    drastic drop in oil prices in 1986, to approximately one -half 1985
    levels, resulted in a dramtic reductin in exploration and
    production activity and a concomitatn increase in U.S. consump-
    tion. In 1986 the shutting-in of striper wells and marginal
    fields has resulted in a decrease in domestic crude-oil production
    to a current rate of approximately 8.5 million barrels per day.
    If prices prevail at abotu $15 per barrel, domestic production
    coudl average 6.2 million barrels per day by 1991. Unless signi-
    ficatn new reserves are foudn and developed by the year 2000,
    domestic production may decline as low as 4 million barrels per
    day and our nation could be dependent on foreign resources for
    60-75% of its demand, almost double the present level of depen-
    dency, within 10-15 years.

    	Future level of oil prices ultimately affects how well the U.S.
    replaces its production. However, the most important factor in the
    future decline of domestic production in due to the steep, natural
    production drop from north America's tow largest producing fields,
    prudhoe Bay and Kuparuk River. Alaska North Slope production
    currently contributes 20 percent of U.S. oil production. This
    production is expected to peak at about 1.9 million barrels per
    day in 1987, then decline to about 500,000 barrels per day by
    2000. The united states must turn to those areas with highest
    potential for undicovered oil and gas to reverse the trend
    towards increasing U.S. reliance on oil imports. Because it takes
    10-15 years to explore, develop, and bring Arctic oil and gas

    NS4: 481/AOGA/02-04-87             -43-

                                                                                                                                                        ATTACHMENT B
                                                                                                  Renewable Resources Inc.
          resources into production, the opening of the ANWR 1002 area for
          exploration   and development    is  now of    timely and     critical                  ENVIRONMENTALCONSULTANTS                 8211A. MMESTURDAVE.. ANCHORAGE. AIANKA 'Pill I.)
          importance.
                                                                                                                                                       13 January 19dl
          Comment 3 - Contribution to National Objectives

          We agree that production of oil from the 1002 area can help
          achieve this nation's national economic and security objectives.                            Mr. William W. Hopkins
          As demonstrated since 1973, the United States is vulnerable to                              Executive Director
          serious supply disruptions and price escalation because of its                              Alaska Oil and Gas ABsociation
          dependence on foreign sources of oil. The Free World's sources of                           121 W. Fireweed Lane, Suite 207
          petroleum are heavily concentrated in the Middle East where                                 ANCHORAGE, Alaska 99503-2035
          two-thirds of the proven reserves are located. Saudi Arabia alone                           U.S.A.
          possesses one-fourth of the world's reserves.       Increased future
          dependency on politically unstable Middle East nations is highly
          undesirable from a national interest standpoint.
                                                                                                      Dear Mr. Hopkinso
          As domestic production continues to deline, and imports continue
          to rise, U.S. vulnerability to supply disruption will increase. A                                            Res Review of Draft EIS      ANWR
          reliable domestic energy supply is a key factor in maintaining a
          viable and flexible      foreign policy,    and reducing potential                                     I as pleased to enclose two copies of a review and
          security threats.                                                                           comments of the Draft EIS. with particular attention to
                                                                                                      Chapters 11 and VI. This review was carried      out by myself and
          Economic benefits of further North Slope development to the nation                          Lennart Sopuck.
          are very significant. In addition to the direct benefits to state
          and federal governments from bonus payments, rentals, royalties,                                       The review consists of a narrative    discussing major
          and taxes, the discovery of large new reserves and reduction of                             issues pertaining to ANWR and how these have     been addressed in
          oil imports would significantly reduce the national trade deficit                           the EIS, followed by an Appendix of specific     comments keyed to
          by bringing a more favorable trade balance.       Nearly half of the                        the LIS.   Appendix il in our rbview of a key    paper by Lau and
     OD   U.S. trade deficit today results from imported oil.                                         Cameron (1986), referenced by the EIS, which     provides a
                                                                                                      rationale for differences between the EIS and our own
          Oil development on the North Slope of Alaska has provided hundreds                          interpretations of potential impacts on caribou.       heferesice
          of billions of dollars to the U.S. economy, representing a benefit                          numbers for Appendix I are shown on a copy of Chapters II and
          to all of the 50 states.     Development of petroleum resources in                          VI of the Els tnat I have enclosed.
          the 1002 area would have a positive impact on the gross national
          produce and thousands of direct and indirect jobs would be created                                     I have also enclosed a copy of a draft paper I
          as demand for goods and services increase.      The positive impacts                        prepared for the Caribou workshop at Alyeska Resort in October
          would be felt well beyond the petroleum industry.                                           1986. That paper witich was preoared with the tinancial support
                                                                                                      of Alyeska Pipeline bervicis Company provided the most detailed
          It is clearly in the national interest to open      the 1002 area of                        examination of and rebuttal to the conclusions of Whitten and
          ANWR to leasing and development.                                                            Cameron (1985) pertaining to the issue of displacement of
                                                                                                      calving in the Prudhoe Bay area. The evidence and arguments I
                                                                                                      presented In that paper form the basis for criticizing the
                                                                                                      reliance of tne LIS an the conclusions reached by Whitten and
                                                                                                      Cameron (198S).

                                                                                                                ANWR has an unusually detailed.baseline data base
                                                                                                      available which was aerived over a long period. Those data
                                                                                                      cover a wide range of wildlife species and ecological
                                                                                                      relationships. For example, systematic surveys of caribou and
                                                                                                      other wildlife species In ANWR have been conducted since 1972.
                                                                                                      In addition, the data base.available for wildlife/pettoleum
                                                                                                      Interactions in the Frudhoe Day area and along the Trans-Alaska
                                                                                                      Pipeline, also covers the long term (over 15 years). The
                                                                                                      foregoing studies provide detailed analyses of topics which

                                                                                                                                                        Conc'd./...
          NS4:481/AOGA/02-04-87             -44-

                                                 2

               Mr. William W. hopkins
               Alaska Oil and Gas Association
               ANCHORAGE, Ak.                                January 1987 U.S.A.

               range from population dynamics, seasonal distribution, behavior
               and responses to mitigation. The combination and scope of
               studies and experience available to unprecedented as a sound
               basis for an environmental impact analysis, assessment and
               prediction. Our review finds that selective use of those data
               and studies and omission of relevant references has resulted in
               over-emphasis of potential negative effects of proposed
               development on wildlife populations and under-emphasized areas
               of compatibility or effective mitigation. In particular, the
               predictions of caribou population declines are not supported by
               all available evidence.

                        The prediction of impacts in always a complex task,
               usually made more difficult by major cata deficiencies. The
               latter, however. does not apply in the present case. Since out
               review has identitied those areas where omissions of relevant
               information or selectivity of literature have created a
               significant bias in impact interpretations, we have concluded
               that the projected impacts on mammalian wildlife populations in
               the ElS are more severe than would be the case under an actual
               development which included appropriate mitigative measures.
                          I would be pleased to provide any clarification of
               th enclosed material that you may require, and hope that.you
               find our comments to be useful.
                                         Sincerely Yours.

                                        R.D. Jakigchuk
                                        President.

               RDJ/st
    		Inc:

    	A REVIEW OF THE REPORT ON THE ARCTIC NATIONAL
    	WILDLIFE REFUGE COASTAL PLAIN RESOUCES ASSESSMENT

    			prepared by

    		R.D. Jakimchuk and L.G. Sopuck

    			of
    		Renewable Resources, inc.

    			for the

    	Alaska Oil and Gas association

    			January 1987

                                                                                                       1.0 INTRODUCTION

                                    TABLE OF CONTENTS                                                           The purpose of this report is to review the

                                                                        Page                           terrestrial wildlife portions of the U.S. Secretary of the

                                                                                                       Interior's 1002(h) report concerning oil development in the

            1.0 INTRODUCTION  .......................................     I                            Arctic National Wildlife Refuge (ANWR) in northeastern Alaska.

            2.0 ADEQUACY OF THE DATA BASE    ..........................   I                            Our approach was to assess the adequacy of the data base used

            3.0 MAJOR ISSUES FOR THE PORCUPINE AND CENTRAL ARCTIC                                      to describe resource values and to predict impacts. We then

                  HERDS ..............................................    5                            determined whether the data base was used in an objective and
              3.1 The Displacement Issue    ...........................   6                            scientifically-sound manner to predict impacts and recommend
              3.2 The Insect Relief Habitat Issue    ........% ......... 11                            appropriate mitigative measures. Following sections provide
              3.3 Mitigation  .......................................    12                            periodic reference to Appendix I which is a list of specific
            4.0 OTHER SPECIES   ......................................   15                            comments keyed to Chapters Il and VI of the 1002 report.
            APPENDICES ..............................................    19                            Appendix I should be consulted for additional and more specific
            LITERATURE CITED  ........................................   32                            comments.

                                                                                                       2.0 ADEQUACY OF THE DATA BASE

                                                                                                                The wildlife resource  and impact assessment sections

                                                                                                       of the 1002 report often contain unreliable statistics and

                                                                                                       poorly referenced and unqualified statements. Conclusions are

                                                                                                       often based on uncritical acceptance of one or two studies or

                                                                                                       on unreliable data bases. In some cases, speculative

                                                                                                       statements are not distinguished from those which are well-

                                                                                                       documented and hence are misleading.

                                               2                                                                                      3
                        There are several examples In the report  of where the                        aLte-specific movement and distribution data for the PCH. The
               reliability of population date are not addressed. For example,                         report states that caribou use riparian areas during spring and
               the estimate of 160,000 animals  for the Porcupin*,caribou Iherd                       summer but does not cite a recent study by Carruthers at &I.
                                                                                                      (1984a) that shows that females with calves usually avoid
               (PCH) in 1986 is crude because the herd has not been properly
               censused since 1983 when an estimate of 135,000 animals  .was                          riparian habitats. In addition, the mo@ements and distribution
               obtained.(Whitten. 1986). However. the unc  Iertainty of the 1986                      of CAH caribou within the 1002 area are described in detail in
               estimate was not addressed in the report. The report also                              the report, yet the movements have been very poorly documented
               states that there is a major concentration of Central Arctic                           to date. If recent unpublished data were used they should have
                                                                                                      been referenced in the report.
               herd (CAH) caribou calving on the Canning River Delta. This

               was based on very limited survey information. In contrast,
               more extensive calving ground surveys conducted by Renewable                                    The definition of the 'core calving area' for the PCH
                                                                                                      was derived using information obtained from 1972-85. This
               Resources Consulting Services Ltd. (RRCS) from 1981-86 show
               that the Canning kiver Delta is not a major ca Iving area, but                         report refers to this period as the "14-year study". In fact,
        9      that there tends to be a continuum of calving along the coast                          the data were obtained from several Individual studies and
        (0
         L     with concentrations between major river valleys (Carruthers at                         surveys. During some years (e.g., 1973, 1974, 1980) very
                                                                                                      Aimited information was obtainell on the calving distribution of
               a;., 1984; Carruthers and Jakimchuk, 1985; Sopuck and
                                                                                                      the PCH, and even more limited estimates of density. Yet it
               Jakimchuk, 1986). Theme studies were not referenced in the
                                                                                                      appears in the report that the "core calving area" was defined
               text.
                                                                                                      based on a solid, 14-year data bass.

                        The available data base on the distribution and
                                                                                                               In the impact section of the report, the indirect loss
               movements of the PCH and CAH is vastly under-utilized in   the
                                                                                                      of habitat an a result of behavioral avoidance is quantified
               report. The calving distribution of the PCH was studied by RRCS
                                                                                                      using.a worst-case scenario. However, based on the studies
               from 1972 to 1977 but these studies are not cited directly In
                                                                                                      conducted to date,  it is extremely speculative to predict a
               the report (Jakimchuk at al.j 1974t Roseneau at &1., 1974;
                                                                                                      .zone of total displacement* around a particular development.
               Roseneau and Curatolo, 1975, 1976; Curatolo and Roseneau.
                                                                                                      These speculations are based primarily on one quantitative
               1977; Bents 1977). However, these reports contain important

                                                 4                                                                                             5
               study, Dau and Cameron (1986). This study shows short-term                                    herd is exposed to TAPS only twice each year, but crosses It
                                                                                                             successfully. In the assessment of the impacts of aircraft
               partial displacement by maternal groups around an active road
                                                                                                             overflights on caribou, the report ignores the work by Davis
               system, but also shown that caribou responses can be highly
              variable.    in addition. no quantitative information on how                                   at Al. (L985). The 1.002 report appears to cite references
                                                                                                             selectively rather than presenting a more balanced viewpoint.
              caribou may habituate to these disturbances is available.
                                                                                                             Davis at al ). show that caribou populations can continue to grow
              Habituation over the long term may significantly reduce tbJs
                                                                                                             despite sometimes severe harassment from aircraft and other
              .Zone of displacement'.
                                                                                                             military activities including bombing and strafing within

                                                                                                             traditional calving ranges.
                        The report presents several statements as fact rather

              than speculation. For example. it is assumed that Increased
              energy demands on individual ca    .ribou during the insect relief                                       In summary, .the 1002 report does not adequately
              period will lead to reduced survival and productivity of the                                   qualify or reference its conclusions and hence presents an
              herd.   however, there are no studies on North American                                        unbalanced assessment of impacts.      In many cause, the worst
              populations of caribou thathave established this link.           Also,                         case scenario for impacts to unjustified.

              the report makes the implicit assumption that caribou are a

              "food-limited' species. However. there are no studies that
                                                                                                             3.0 MAJOR ISSUES FOR THE PORCUPINE AND CENTRAL ARCTIC HERDS
              show that mainland populations of caribou in North America are

              food-limited. European references are not appropriate because
                                                                                                                      Although a worst case scenario to a valid approach to
              reindeer herds are maintained at artificially high stocking
                                                                                                             environmental analysis, for significant resources such as the
              levels in largely predator free systems.
                                                                                                             PCH it should incorporate the followings
                        The report states that the PCH way havedifficulty                                    1. Assumptions should be realistic and properly qualified.
              accommodating to developments such as pipelines because they
                                                                                                             2. The factual basis for analysis should be supported and well
              will interact with them for short period& during the year.
                                                                                                                 documented.
              However, the report fails to discuss RRCS studies of       the
                                                                                                             3. impact criteria should be well defined and supported.
              Nelchina herd (Carruthers at al., 1984b) which shows       that this

                                                6                                                                                       7

                4. Use of the scientific literature should be objective rather                          critical appraisal of those data and the conclusions of Whitten

                    than selective.                                                                     and Cameron. The evidence supports tas notion that the Prudhoe

                                                                                                        area is similar to other deltas in having a low calving density
                                                                                                        which existed pre-development and that conclusions that calving
                3.1 The Displacement Issue                                                              has been displaced from the PBC are unsupportable.

                         The impact assessment on the PCH is largely based on                                    Because of the contentious and inconclusive nature of
                two studies: Whitten and Cameron (1985) who concluded that                              the Prudhoe Say scenario, the report of Whitten and Cameron
                calving of the CAR has been displaced from the Prudhoe Bay area                         (1985) is not a sufficiently strong basis to rely on for the
                since the onset of petroleum development, and Dau and Cameron                           PCH scenario analysis.

                (1986) who reported local displacement of maternal caribou
                along the Milne Point Road.   Whitten and Cameron (1985) present                                 Dau and Cameron (1986) present a far better study
                conclusions based on anecdotal data which are largely                                   design and basis for assessing the implications of sensory
                                                                                                        distiirbance to the distribution of calving caribou. Because of
         :A)    correlations after the fact.   Jakimchuk (1986) presents a
                detailed rebuttal to the principal conclusion that calving of                           its importance as the basis for the impact analysis we have
                the CAh has been displaced from Prudhoe Bay. Their own pap   Ier                        reviewed that study (Appendix 11) for its relevance and
                recognizes the possibility of other factors such as flooaing                            validity.  Several points have emerged from that review which
                which may account for the lower calving density in the Prudhoe                          are important to the analysis for the PCh.

                Bay Complex (PBC). Jakimchuk (1986) reviews evidence that
                indicates that the POC was not an important calving area even                           1.  The Dau and Cameron study, although a better design than
                before development and that the correlations made by Whitten                                previous studies, is not definitive.   it documents a
                and Cameron reflect a calving distribution in response to                                   partial avoidance by maternal cows over a period of high
                natural influences.   However, neither viewpoint can be termed                              disturbance.' However its limitations include lack of a
                conclusive because of the post facto correlations which are                                 control, and no discussion of conflicting results with West
                made and the limitations of pre-development data and possible                               Sak Road studies which show no avoidance by calving groups
                comparisons. Jakimchuk (1986) does, hcwever, present a                                      along the West Sak Road. Their comments on lack of
                                                                                                            habituation by caribou to disturbance are unsupportable.

                                                                                                                                       9

                        Although Dau and Cameron document reduced habitat use                          reference is not even cited in the EIS. The analysis of air-
               (i.e., lower densities) by maternal groups near the road, they                          craft disturbance ignores at least a dozen aircraft disturbance
               did not in fact document displacement which may be defined as                           studies, many of which are more quantitative or relevant than
               an active process of dislocation of caribou from a previously                           those cited. The gratuitous editorial comment on Bergerud et
               used area in response to a stimulus.   Further, they do not                             al. (1984) (ref. 41, p. 110, App. 1) as a paper that iNs "widely
               comment on the significance of the fact that numbers of calving                         disputed" indicates a biased approach to dissenting viewpoints.
               caribou in their study area almost doubled between the pre- and                         We consider that such an arbitrary dismissal of a major,
               post-development study period&.                                                         refereed, published paper is unethical.

                        The most significant error of the scenario analysis                                     Previous sections of this review and Appendix I
               for the PCH is the assumption that what is termed "behavioural                          identify omissions of specific papers relevant to an objective
               displacement" wouldbe total for a 2-mile zone adjacent to                               analysis of impacts.   Another example is omission of Carruthers
               roads using Dau and Cameron (1986) as a basis for that                                  et al. (1984b) on crossing success of TAPS by the helchina
               analysis.   A total displacement was not found by  Dau and                              herd, which his a direct relevance to   the question of effects
               Cameron and there is no basis for the assumption of a zone of                           on caribou which only periodically contact a pipeline (ref. 36.
               habitat loss of that magnitude. Moreover, the analysis                                  p. 109, App. 1).   Thisreport is not listed in the bibliography
               unjustifiably fails to discuss the potential for habituation                            of the EIS.

               and is highly selective in use of relevant'references. It
               specifically ignores those references which may temper                                           The assumption that displacement from the PCH core
               conclusions pertaining to the adverse effects of disturbance                            calving area would be complete is not justified on the basis of
               and displacement on caribou demography.                                                 known examples.   The further link to population decline is even
                                                                                                       more speculative. There is inadequate treatment of alternative
                         For example, Davis et al. (1985) report no short term                         habitat use and the potential mitigating effects of
               demogr6phic effects on the Delta herd from displacement from                            habituation. The net result of the foregoing omissions is to
               their core calving area and nc, adverse demographic eifects or.                         greatly exaygerate the worst case beyond what can be supported
               the herd from severe disturbances on the calving qrounds- Tnis                          on scientific evidence.

                                              10                                                                                     11

                        Although the qualifiers "could be", and "maybe" are,                                   We have given little  attention to the impact
               frequently yeed in the impact predictions they are not defined.                        assessment of the CAH in this  summary and refer the reader to
               The assessm ent would be enhanced considerably by an objective                         specific notes and comments in Appendix I.   In general,
               risk or probability analysis in order to place predictions in                          projected impacts on the CAH are highly 6verstated since 1002
               context with their likelihood of occurrence.                                           developments would impinge on a smaller portion of the herd
                                                                                                      than do existing petroleum developments in the Central Arctic
                        The analysis of comparative calving densities for                             region.

               va rious herds has been linked to the vulnerability of the PCH

              ,to population decline if displacement occurs because of its
               higher calving densities. That analysis. however, depends                              3.2 The Insect Relief Habitat Issue

               entirely on undocumented assumptions that:
               a) There is a relationship between calving density and herd                                     Although there Is considerable theoretical concern
                  productivity.                                                                       for. and discussion of, the importance of Insect relief habitat
               b) That alternative calving areas are incapable of sustaining                          to the PCH and CAH, there is very little documentation of its
                  the PCH at current levels.                                                          role or significance to the herds. The overall requirements
               c) That displacement would be complete..                                               for insect relief and its relationship to hard health and
               d) That the growth of the CAH is partially    result of its low                        energetics requires additional study and assessment.   As a*
                  calving density.                                                                    migratory herd the PCH has insect relief habitat options both
                                                                                                      north and south of the study area and has utilized both coastal
               The arguments presented in the EIS regarding assumed relation-                         and montane habitats for that purpose.   Overall, insect relief
               ships between calving density and herd productivity are both                           habitats are neither scarce nor inaccessible. maintenance of
               speculative and hypothetical.   There is no supporting data to                         movement patterns as specified in the mitigation measures and
               warrant th e conclusions made. Therefore, the severity of the                          as experienced by the CAH Iwould ensure access to insect relief
               impacts predicted are overstated and subJect to question.                              habitats both along the coast and inland.   In addition,
                                                                                                      elevated areas of gravel pads will increase availability of

                                                                                                      insect relief sites inland albeit to a.minor extent compared tu

                                                                                                      natural areas.

                                              12                                                                                       13

                       At present, there Is no   basis to concludet that access                         15 July the majority of caribou have left the   1002 area on
              to insect relief habitat will be   impaired Iby the development                           their mid-summer migration intoCanada.

              scenario provided that mitigation   measures proposed are

              Implemented.                                                                                       There is also scope to add to and i-pprove the

                                                                                                        mitigation measures to further reduce impacts on the PCh.

                                                                                                        These include site-specific scheduling to minimize activity
              3.3 Mitigation                                                                            during sensitive periods.

                       In general, we agree with the mitigation analysis.                                        A major unknown is how large concentrations of caribou
              The major exception is the recommendations for ramps to                                   (100,000 or more in post-calving aggregations) would respond to
              facilitate caribou passage. Recent studies show that ramps are                            and negotiate oil development infrastructure. There is reason
              not necessary to ensure caribou pass&  Igo across pipeline                                to believe that large groups are Dore susceptible to influences
              corridors provided adequate pipe clearance is available.                                  such an deflection because of the impetus of their numbers and
              Further, the construction of ramps has biological costs                                   the dynamics of group leadership. Because of these unknowns it
              associated with gravel removal and transport and habitat                                  would be prudent to establish facilities such as,roade and
              alteration at source locations and ramp locations.                                        pipelines in areas of minimal potential conflict with large
                                                                                                        aggregations of caribou.

                       Although we are in agreement that air traffic should
              be controlled to minimize disturbance the mitigation analysis                                      Despite evidence that caribou cross  .under pipelines
              presents a one-sided scenario by omitting references to caribou                           with clearances as low as 5 ft, we have previously recommended
              populations exposed to aircraft disturbance which have not                                a higher clearance where interaction with large aggregations
                                                                                                        are anticipated. We feel that a minimum of 7 ft ground/pipe
              suffered demographic effects (Sergerud at al., 1984; Davis at
              al., 1985). The restrictions proposed for aircraft appear to                              clearance within the range of the Porcupine caribou hard would
              be overly conservative. For example 2,000 ft-ceilings on                                  be a highly significant improvement as a mitigation measure.
              overflights are proposed from 20 May to 15 August. However, by                            The major rationale for increasing the clearance is to provide
                                                                                                        a larger margin for tacilitating passage of large

                                              14                                                                                       Is

               concentrations of caribou and  because of the aforementioned                            4.0 OTHER SPECIES
               impetus of large groups which  can govern dire  Ictional movements
               during post-calving and aid-summer migration. A. higher                                           Appendix I provides specific annotations for other
               clearance would facilitate passage of mature antlered bulls and                         species. A major deficiency in the analysis is incomplete use
               would maintain a physical opening between passing animals and                           of available literature and data sources.    As a result,
               the overhead pipe which would be visible to those animals in                            potential negative impacts tend to be over-emphasized, e.g.,
               the rearguard of large herds.                                                           the status of Polar Bear donning Is accorded considerable

                                                                                                       attention. However, denning in the 1002 area Is an extremely

                        The existing scenario shows a proposed pipeline                                minor component of denning adjacent to ANWR which in turn is a

               location traversing the known post-calving aggregation area for                         minor component of denning overall for the Beaufort Sea polar

               the PCII south of Camden bay.  Additional study is recommended                          bear population.

               to improve that location, possibly%by moving it further north
        Q      to avoiA the area of massive aggregation without precluding                                      We are in agreement with the projected impacts and
         4     access to insect relief habitat.                                                        description on grizzly bears. The exponential growth rate of

                                                                                                       muskoxen may be limited by nabitat availability in future.

                        The foregoing and other measures such as scheduling or                         Effects of disturbance on this growth rate are speculative at
               convoying traffic during periods of major caribou movements                             the present time. The history of the transplant and growth
               would serve to greatly minimize adverse impacts on the herd and                         have established the capability of muskoxen to pioneer a new
               reduce the magnitude of predicted impacts considerably.                                 environment and is evidence that they are responsive to
                                                                                                       opportunities provided by mitigation. In the absence of
                        in view of the foregoing we disagree with the                                  controls or management, muskoxen would be forage regulated at
               statement (ref. 43, p. 111, App. 1) that mitigation is not                              some future point and might compote with caribou in a
               possible in Resource Category I lands and feel that there are                           conflicting way.

               significa nt mitigative opportunities and P,easures to reduce the

               adverse effects of development activities on t  hose lands.

                                              16                                                                                          17
                                          APPENDIX I.                                                          Reference
                                                                                                         Page      No.                           Comments
                        Detailed review comments on the ANWR impact                                       28         6       It is important to distinguish between post-
                                                                                                                             calving movement and aggregation and the mid-
                               assessment report, Pp. 27-170.                                                                summer.migration (see Jakimchuk and McCourt,
                                                                                                                             1975). summer movements (midsummer
                                                                                                                             migration) are the most consistent movements
             A) Chapter 11, Existing Environment, pp. 27-45.                                                                 of the year. Post--c-a-5-ing movementsare also
                    Reference                                                                                                quite predictable.
             Page      No.                           Comments                                             28         7       There is no attempt to define the phrase
               28      1-2       The *core calving area". as defined, has                                                    "critical life stages".
                                 caribou densities of So animals/mi2 or more                              29         a       to productivity the basis for determining
                                 during five of 14 years. Caribou use of                                                     'impact' or is habitat? Unless the direct
                                 their calving grounds is very dynamic with                                                  link implied in documented for caribou both
                                 site-specific densities varying greatly                                                     definitions should not be used
                                 within the calving period.                                                                  simultaneously.
                                 Core calving area is not necessarily                                     29         9       More documentation of August numbers is
                                 "traditionally" favored and the words "strong                                               needed to determine the frequency of August
                                 fidelity" are misleading. It is in fact an                                                  occupation of the 1002 area (e.g., are
                                 area where high density of calving has                                                      numbers closer to 15,000 or to lower end of
                                 occurred frequently, i.e., yearly overlap                                                   range?).
                                 within the overall calving range.                                        29       11        This paragraph requires references. The
       0:)     28       3        This paragraph lacks references and is mis-                                                 movements of Central Arctic herd in the lU02
                                 leading. The generalization that caribou use                                                area have not been adequately documented to
                                 riparian areas as travel routes and important                                               date.
                                 feeding areas is not fully supported by the
                                 available literature (see Jakinchuk and                                  29       L2        Again no references are provided. The most
                                 McCourt, 19751 LeResche and Linderman,                                                      detailed information on calving distribution
                                 1975).                                                                                      of the Central Arctic herd is available from'
                                                                                                                             Sopuck and Jakimchuk (1986),,Carruthers and
               28       4        References or qualifications are required on                                                Jakimchuk (1985) and Carruthers et al,
                                 types of disturbances which may affect                                                      (1984a). The presence of 1,000 females and
                                 bonding and increase in mortality. We need a                                                calves on Canning Delta in most years
                                 more realistic impact prediction on the                                                     contradicts data which show more of a calving
                                 effects of disturbance on calf mortality.                                                   continuum along the coast with concentrations
                                                                                                                             between major river valleys. Also, the
               28       5        Uplands are in southern part of calving                                                     calving situation at Prudhoe Bay oilfield is
                                 grounds, not th'i -northern part. Also, use of                                              misleading. The results of Whitten and
                                 uplands by most calving cows contradicts                                                    Cameron (1985) were rebutted by Jakimchuk
                                 previous statement (see #3) that calving                                                    (1996) who reviewed evidence that the Prudhoe
                                 .caribou* use vegetated riparian habitats                                                   Bay area was never an important calving area
                                 (see Jakimchuk et al., in press). There are                                                 for the Central Arctic herd.
                                 no citations of work done by Renewable
                                 Fesources Consulting Services Ltd. on calving                            29       13        use of riparian areas as travel corridors
                                 distribution of the Porcupine caribou herd                                                  and feeding areas by the Central Arctic herd
                                 during the 197us.                                                                           by cows and calves is not supported by the
                                                                                                                             literature (see Carruthers et al., 1984a;
                                                                                                                             Jakimchuk et al., in press).

                                                                                                                                        19
                     Reference                                                                                 Reference
              Page_ __!Lo.                            Comments                                          Pa e      No.                          Comments

                                 This paragraph ignores the Central Arctic                               33       25        This paragraph contains very vague and mis-
                                 herd an a whole and only discusses the 1002                                                leading statements.   It leaves the impression
                                 area and is therefore, incomplete. Since                                                   that a high percentage of the 2,000 bears in
                                 most of the herd occurs outside the 1002                                                   the Beaufort population use ANWR. This is
                                 area, this paragraph gives a misleading view                                               not the case. One to two dens in each of
                                 of importance of the area to the Central                                                   four out of five years does not indicate high
                                 Arctic herd.                                                                               use of the area by denning bears. See Noure
                                                                                                                            and Quimby (1974) for earlier studies on
               29@      is       In the presentation of Central Arctic herd                                                 polar bear denning locations (bioloSical
                                 distribution and abundance there are no                                                    Report Series, Vol. 32, Ch. 2) which also
                                 comments on.productivity. This omission                                                    found a low frequency of donning in ANWR.
                                 downplays the tripling of herd size which has
                                 occurred since the Prudhoe Say development                                                 The 15 dens found between 1951-1985 is
                                 started.                                                                                   cumulative and does not represent actual
                                                                                                                            numbers in any one year.
               30       16       Additional data on moose obtained in the
                                 1970s are available from the Arctic Gas                                 34       30        Additional information on ringed seals
                                 Biological Report Series, Vol. 6. Ch. 1.                                                   adjacent to ANWR can be found in Moore
                                                                                                                            (1976)Biol. kept. Series, Vol. 36, Ch. 2.
               20       17       Data onthe Sadlerochit Mountains sheep herd                                                This reference was not cited.
                                 ,are available in an earlier reference (see
                                 Arctic Gas biological Report Series, Vol. 6.                            37       31        Studies conducted by McCort et al. (HioL.
                                 Ch. 1).                                                                                    Rept. Series) on fisheries resources in the
                                                                                                                            ANWR area are noc cited.
                 31      19      More detailed.information than available in
                                 Chesemore (1967) an Arctic fox distribution                            4-5       32        The impacts of oil development on the Wilder-
                                 in the 1002 area is available from Quimby                                                  nose resources of the 1002 area will be a key
                                 and Snarski (1974). Arctic Gas Biological                                                  issue.
                                 Report Series, Vol. 6. Ch. 2.

               32       20       Additional information on wolverines in the
                                 1002 area is available from Quimby and
                                 Snarski (1974), Arctic Gas Biological Report
                                 Series, Vol. 6. Ch. 2).                                                8) Chapter Vt. Environmental Consequences, pp. 95-119.

               32       21       Again. earlier work on   bears in the IU02 area
                                 by Quimby and Sharski (1974) is ignored.                               96          1       These definitions of impacts do not attempt
                                                                                                                            -to 4uantify the changes in abundance in wild-
               33       24       This paragraph lacks references which are                                                  life populations from the natural state that
                                 especially required since conculsions                                                      corresponds to each level of impact.
                                 presented are controversial.                                                               Also there is no allowance for accommodation
                                                                                                                            or habituation by species to modifying
               33       24       Numbers of polar bears In the ANWR part of                                                 Influences.
                                 the Beaufort should be indicated; the Beau-                             98         2       We agree that the PCH concentrated calving
                                 fort sea estimate of 2,000 includes Canadian                                               area is considered unique and irreplaceable.
                                 waters. "Influx of females" implies large
                                 numbers moving into the 1002 area. This is                              98         3       The remainder of the 1002 area cannot be
                                 not so    References for the population                                                    considered scarce habitats, nationally vs.
                                 estix.a4 are not given.                                                                    regionally, and should be category 3-4 for
                                                                                                                            most species.

                     Reference                 20                                                               Reference                 21
               Page     No.                           Comments                                            Page     No.                           Comments
               105        5       Although up to 82 percent of calving for the                                                 important calving area.
                                  Porcupine caribou herd has occurred in the                                                 - Whitten and Cameron (1985) do not show an
                                  1002 area. In some years almost no calving                                                   absence of calving for the entire perioa-
                                  has occurred there.    However, use of the area                                              but co-incidentally with delayed snowmelt.
                                  is more consistent during the late June/early                                              - Whitten and Cameron also discuss other
                                  July insect relief period.                                                                   possibilities for low pre- and post-calving
                                                                                                                               densities.
                                  The statement that the insect relief period                                                - Other Central Arctic caribou herd calving
                                  is highly stressful is based largely on                                                      areas show similar pre- and post-develop-
                                  theoretical considerations - insect relief                                                   ment low calving distributions.
                                  habitats are widespread north and south of
                                  the 1002 area. An inland pipeline may inter-                                               This section superficially covers a very
                                  fere with movements to the coast and post-                                                 important topic and uncritically accepts
                                  calving aggregationsl however, a coastal                                                   selected findings of one study (i.e., Whitten
                                  pipeline would not.                                                                        and Cameron, 1985).

               105        6       This statement should be qualified as to                                106        9       inappropriate secondary reference to a
                                  extent of displacement and should indicate                                                 review paper when other references, e.g.,
                                  that only a minor component of the Central                                                 Carruthers et al. (1984a), are original
                                  Arctic caribou herd is involved.                                                           sources of systematic data with wider
                                                                                                                             coverage than any other.
               106        7       These statements are hypothetical and too
                                  generalized becauses                                                    106      10        Long term data collected from 1981-86 by
                                  1) Density is only an important consideration                                              Renewable Resources Inc. indicates that the
                                     it proposed activities have effects on                                                  Canning River Delta in not a major calving
                                     populations.                                                                            area for the Central Arctic herd. however,
                                  2) it is debatable if the interaction would                                                it receives greater use during the post-
                                     be greater than at Prudhoe bay. The                                                     calving period.
                                     Porcupine caribou herd does not always
                                     calve In core area and not all of the core                           106      111       Table VI-4 shows progressive increase in
                                     area will be affected.                                                                  calving numbers in the oilfield from 1972    7
                                  3) Nonetheless. calving and post-calving                                                   L974. A detailed critique of these data is
                                     densities and numbers do differ signifi-                                                available in Jakimchuk (1986).
                                     cantly from the Central Arctic caribou
                                     herd and differing implications may occur.                                              Also, population estimates for the Central
                                     If an adverse effect occurs it would                                                    Arctic herd for 1981-1986 are available from
                                     certainly affect a greater proportion of                                                various RRCS studies.
                                     the population especially during post-
                                     calving aggregation.                                                 106      12        The amount of the "core calving areas"
                                                                                                                             within the 1002 area depends on the
                                  We agree also that the Porcupine caribou                                                   definition of core calving ground used. The
                                  herd will form larger groups than the Central                                              criteria of 3,50 caribou/km2 in at least 5
                                  Arctic caribou herd during post-calving and                                                of 14 years resulting in 80 percent within
                                  that predator populations also differ                                                      the 1002 area may be too conservative (i.e.,
                                  between the two areas.                                                                     the major calving grounds are actually much
                                                                                                                             larger).
               106        6       This paragraph is of major importance    and is
                                  highly misleading (see Jakimchuk, 1986;                                 106      12        There are no recently published population
                                  Caribou workshop paper) becauses                                                           estimates for the Porcupine caribou herd
                                    the Frudhoe bay oil field was never an                                                   since 1983. The 1983 photocensus estimate

                                                 22                                                                                          23
                       Reference                                                                                   Reference
                Page      No.                           Comments                                             Page      No.                           Comments

                                    since 1983. The 1983 photoceneus estimate                                                   Bergerud et al. (1984). Citation is used
                                    was 135,000. Therefore recent estimates of                                                  inappropriately here.
                                    165,000 in 1985 and 181,000 in 1986 are
                                    guesses rather than actual censuses as                                   107       19       This statement is grossly misleading since
                                    implied.                                                                                    there is no evidence available to support
                                                                                                                                it. The following sentence can also apply to
                 106      13        Year-round use of the   1002 area by 4,000                                                  many other areas within the range of the CAM.
                                    Central Arctic caribou is undocumented.                                                     Both the statement and cited study are
                                                                                                                                misleading (Whitten and Cameron, 1985) and
                106       14        Core-calving and concentrated calving areas                                                 have been separately criticized by Jakimchuk
                                    are defined using the density of !50 caribou/                                               (1986) and Carruthers et al. (1984a).
                                    m12 yet there is no indication of how these
                                    estimates of density were made. Also, a                                                     The extent of displacement in the Prudhoe
                                    better indication of the use of the 1002 area                                               Say area caused by development is difficult
                                    for calving would be data on the percentage                                                 to quantify since the area was never an
                                    of the herd that calved there each year.                                                    important calving area and because
                                                                                                                                pre-development data are not sufficiently
                107       16        Indirect habitat losses as a result of                                                      quantitative.
                                    behavioral avoidance are difficult to
                                    quantify. Studies to date show that the                                  107       20       The Study by Dau and Cameron (1986) shows
                                    degree of avoidance by caribou is variable                                                  reduced habitat use by caribou.     However, the
                                    and that caribou may habituate to these                                                     extent of reduced habitat use shows
         9                          disturbances over the long term.      Indirect                                              considerable variation.    Habituation of
                                                                                                                                    I
                                                                                                                                Caribou may reduce this effect in the long
                                    habitat losses due to physical barriers may                                                 term.
          L                         be more signficant depending on the success
                                    of mitigation measures employed.
                                    Insufficient pipe heights or over-reliance on                            108       21       If displacement does occur, adjacent areas
                                    ramps in combination with disturbance way                                                   may not be undesirable since they are
                                    impede free movements of caribou. This                                                      frequently used with no short term adverse
                                    problem may be significant for very large                                                   effects on productivity. Long term studies
                                    aggregations of Porcupine.herd caribou during                                               on effects on productivity of displacement
                                    the post-calving (insect relief) period.                                                    would be required to determine the signifi-
                                    Data on the responses of very large groups of                                               cance of displacement from a high density
                                    caribou to physical barriers are presently                                                  calving area.
                                    unavailable.                                                                                Although displacement of the Porcupine
                107       17        Present studies of behavioral avoidance by                                                  caribou herd from a "core calving area" may
                                                                                                                                be deleterious, studies of the Central Arctic
                                    caribou of roads do not prove that                                                          herd show that caribou numbers can increase
                                    disturbance is a major source of habitat                                                    despite development within their calving
                                    lose. we need to know how many caribou show                                                 areas. We agree. however. that caution
                                    the displacement response and whetner                                                       should be used in extrapolating Central
                                    habituation will occur in the long term.                                                    Arctic caribou herd results to the Porcupine
                107       Is        The statement in not true, and not                                                          caribou herd since the Porcupine caribou herd
                                    definitive.   Dau and Cameron (19b6) show                                                   occurs at much higher densities on their
                                    local response to roads consisting of reduced                                               calving grounds and because predators are
                                    densities of maternal caribou not dis-                                                      more abundant adjacent to the Porcupine
                                    placement from calving grounds.                                                             caribou herd calving areas.     In addition,
                                                                                                                                caution should be used in the assumption     that
                                                 and statements by Car-eron and                                                 displacement of the Porcupine caribou herd
                                    Whitten t1979) tave 'E.eer. ce.Ellenc:ez 'r%

                                                 24                                                                                           25
                      Reference                                                                                     Reference
               Page       No                            Comments                                             Page      No.                            Comments

                                   from a "core calving area" would occur      in                                                establish the likelihood of conditions which
                                   total as implied. The probability of.this is                                                  constitute interference or pruvide better
                                   low based on evidence from the CAU.                                                           qualifications of statements made.

               108        22       This statement presupposes a food limiting                                109       31        Agree - valid concern.    1 have previously
                                   habitat and a complete lose - the references                                                  recommended 7' ground to pipe clearance
                                   used deal with non-caribou apparently since                                                   rather than the 5' levei cited in this and
                                   caribou are not a food limited species ano                                                    the workshop report.
                                   comparable references are not available for
                                   mainland herds of Barren-ground caribou in                                109       31        We agree that the effect of potential
                                   North America.                                                                                barriers are greater during post-calving than
                                                                                                                                 during calving because of the very large size
                          25       There is no basis for "unlikely" conclusion.                                                  of post-calving aggregations and the sudden,
                                   This is speculation only based on inference      of                                           erratic movements between inland areas and
                                   higher density. Also presupposes a "massive"                                                  coastal insect-relief habitats. There to
                                   displacement rather than a local displacement.                                                insufficient evidence. however, to indicate
                                   This is an example where the CAH experience                                                   that survival or productivity of caribou may
                                   is downplayed despite the existence of data                                                   be reduced as a result of a disruption In
                                   on compatibility with development.       "...no                                               movements during this period. We recommend
                                   recognizable... long term effect... has been                                                  that the location of a main east-west pipe-
                                   demonstrated to date (emphasis ours).                                                         line be studied further and that pipe heights
                                                                                                                                 should be raised from the minimum of 5' cited
                          26       However, all.participants of the FWS workshop                                                 in the EIS to 7' within the range of the PCH.
                                   did not agree to the extent or significance
                                   of that displacement.                                                     109       32        The European references used are not
                                                                                                                                 appropriate - carrying capacity and
               108      27-28      Dau and Cameron (1986) indicate that reduced                                                  nutritional limitations are greater for
                                   density of maternal caribou which they term                                                   European populations.
                                   displacement may occur within 2 miles from                                109       34        This statement in based on one example and
                                   active roads. however, the percentage of
                                   caribou affected is uncertain. A                                                              hence is not objective.
                                   significant number of caribou within 2 miles
                                   may be unaffected by disturbance.       Therefore,                        109       35        There is no evidence that ramps will
                                   development would not result in the complete                                                  significantly increase crossing success -
                                   lose of 32 percent of the Porcupine caribou                                                   rather pipe heights and the presence of
                                   herd core calving area as calculated.                                                         vehicular traffic are more important.
               108        28       It is erroneous and misleading to     imply a                             109       36        It is appropriate to discuss RRCS studies of
                                   "total displacement" two miles wide. The                                                      the Nelchina herd (Carruthers et al., 1984b)
                                   term  p             lation decline is                                                         here and reference it. This herd is exposed
                                   unsubs!Oabnt'i!:ePdOpVe., displacement is linked                                              to TAPS only twice a year, but crosses it
                                   to decline, but such an effect nas never been                                                 successfully.
                                   demonstrated or documented.     Tne assumption
                                   of massive displacement is unwarranted nasea                              109       37        This worst case to unjustified on the basis
                                   on the Central krctic c&rib@)u her@_                                                          of known responses of caribou. It to
                                   experience.                                                                                   unrealistic and ignores experience to date.
               108        29       Several studies show that pipelines such as                                                   Also should not assume 2-mile sphere of
                                   7AFS and Kunaruk do not create a r,;@rr;er-                                                   influence even without mitigation.

                                                 26                                                                                       27
                       Reference                                                                                 Reference
                P e       No.                           Comments                                          Page      No.                           Comments

                110       38        Disturbance and hprassment are significantly                                             measures could also be listed, to further
                                    different. There is no evidence that                                                     ameliorate impacts.
                                    disturbance will result in direct or indirect
                                    mortality as a result of trampling-or                                 112       48       Environmental description map in Chapter 11
                                    increased energy loss.                                                                   shows extent of alternative habitats.
                                                                                                                             Whether these could sustain a growing
                110       39        This paragraph ignores  several other studies                                            population assuming lose of all core calving
                                    some of which are more  quantitative.                                                    area (although unlikely) is unknown.
                110       40        Davis et al. (1985) report no demographic                             112       49       Insect relief habitats need to be more
                                    effects or calving ground displacement on                                                accurately described. We need to know how
                                    the Delta caribou herd*from severe aircraft                                              much space to necessary to give relief to the
                                    disturbance and other disturbance associated                                             Porcupine caribou herd.
                                    with military activity. This is an example
                                    where significant conclusions of a recent                             112       50       There to a major step between potential
                                    peer review paper (Davis et al., 1985) are                                               undocumented effects and a population
                                    ignored in favour of an outdated non-peer                                                decline. however this paragraph seems to be
                                    review reference.                                                                        properly qualified.
                110       41        The editorial comment "widely disputed view"                          112       51       Is it a decline or distribution change or
                                    is an inappropriate and unsubstantiated                                                  both? There is no basis for predicting
                                    comment on a peer-review published paper.                                                either a 5-10 percent decline or distribution
                                                                                                                             change. The opposite, a three=fold
                                                                                                                             population increase in the CAh accompanied
                111       43        We disagree with this conclusion since                                                   the Pruahoe Say development which interacted
                                    Category I habitats would not suffer an                                                  with a much larger proportion of the CAH than
                                    inevitable "lose". Mitigation of Category I                                              would be the case for the IU02 area. The
                                    habitat is possible because:                                                             prediction of a decline and distribution
                                    1) A 2-mT-le avoidance zone is not a valid                                               change for the CAH throughout its range based
                                       assumption (see previous co;m-ents).                                                  on the 1002 interaction totally ignores the
                                    2) hany mitigation options are available                                                 well-documented facts of the actual effects
                                       includingt                                                                            of development. This paragraph is unfounded.
                                       - Traffic control
                                       - Reduced human activity during calving                            113       52       There is no basis given for extrapolating
                                       - Reduced aircraft overflights                                                        effects on individuals to population
                                       - Speed limits on traffic, etc.                                                       effects.
                ill       44        Ramps are over-emphasized and not    justified.                       113       54       A major unjustified assumption here is that
                                    Elevation of pipelines to 7' above ground                                                disturbance will result in absolute lose of
                                    (because of large groups) should be a                                                    habitat value.
                                    priority over ramps.
                ill       46        Davis et al. (1985) do not indicate a                                                    Also an exponentially expanding population
                                                                                                                             suggests that in the near term it is below
                                    problem. Restrictions could be lifted after                                              carrying capacity.
                                    15 July because most PCH animals are gone on
                                    9,ir..-er r,3%,e.-,ents by that date. We agree                        L14       55       Evidence is opposite, these sub-groups all
                                    witr. a rinirum altitude of 2,000' May 2U                                                originated from two transplants, one mag-eon
                                    through July 15th.                                                                       Barter Island (1969) and the other at Kavik
                ill       47        W e t;;t s i.cally agree with all mitication                                             Camp (13 muskox transplanted in 1970).
                                    7      S     Ew    r     S

                                             28                                                                                   29
                    Reference
              Pag@__    No.                         Comments                                                                  APPENDIX II
              116       56       These conclusions are entirely speculative
                                 and there is no possibility of subsequent
                                 determination it they are correct or
                                 incorrect.
                                                                                                         Review of Dau and Cameron (19bb) Report entitled "Effects
              117       57       Agree with this section in general.                                     of a road system on caribou distribution during calving*.
                                                                                                         "Rangifer", Special Issue No. 1:95-101.-
              lie       59       This paragraph is misleading because 12-13
                                 percent of the Beaufort be& Population do NOT
                                 den on land.
                                                                                                             Dau and Cameron have demonstrated a local, short-term
              119       60       This paragraph should be qualified with a
                                 more objective review of likelihood of                             reduced density of maternal caribou groups adjacent to an
                                 effects on productivity of bears.
                                                                                                    active road system which they refer to as partial displacement.

                                                                                                    However, several qualifications to their results need to be

                                                                                                    made that were absent in the report. The authors admit that it

                                                                                                    is speculative to extrapolate the local effects on maternal

                                                                                                    caribou to the population as a whole. Yet they imply that

                                                                                                    displacement will result in widespread, long-term loss of

                                                                                                    traditionally-used habitat. We argue that such conclusions are

                                                                                                    unwarranted at this time.

                                                                                                             The experimental design of Dau and Cameron,although

                                                                                                    more rigorous than previous work, did not include adequate

                                                                                                    controls. The design requires a control area containing a

                                                                                                    hypothetical road alignment and located In an area of similar
                                                                                                    habitat and calving density, well away from human activity.
                                                                                                    monitoring of a control area during an equivalent study period
                                                                                                    (1978-85) would indicate whether changes in caribou

                                                                                                    distribution similar to the experimental area can occur in the

                                                                                                    absence of development.

                                             30                                                                                      3L
                       in addition, Dau and Cameron fail to note that:                                         It is noteworthy that Dau and Cameron showed that non-
                                                                                                      maternal caribou were  not displaced by the road development.
              1) despite partial displacement and increasing development                              Also, the response by  maternal groups was partial displacement
                  activity, caribou densities increased in t  heir study area                         within a zone of 0-3 km (0-1.9 mi).   In'the ANWR report it is
                  from 1978-85;                                                                       implied that _aIL caribou show a -total. displacement within 2
                                                                                                      miles. This scenario is not supported by the Dau and Cameron
              2) most of the displacement was observed in the middle                                  report.

                  sections of the road, the north and south ends of the road

                  alignment supported lower densities of caribou before and

                  after the development;

              3)  non-maternal groups, which included up to 25 percent

                  calves, occurred at higher densities (although n  ot

                  significantly higher) near the road alignment than away

                  from the alignment during the post-deveLopment period;

              4) habituation was not evident up to 1985 because the

                  .intensity of human activity was also increasing

                  dramatically at this time.

                       The Dau and Cameron study showed statistically

              significant differences in caribou density vs. distance but

              also indicate that annualvariability was high. In fact, the

              annual variability within each 4-year peziod was alwast

              significant (p - 0.053) for calves. This suggests that the

              disrlacerent response varied considerably frow year to year.

    		32

    	LITERATURE CITED

    Bente, P.J. 1977. Summary report of investigations of the
    Porcupone caribou herd in northeastern Alaska and the
    Yukon Territory, 1977. Renewable Resources consulting
    Services Ltd. Unpubl. Rep. 19 pp.

    Berbgerud, A.T., R.D. Jakimchuk and D.R. Carruthers. 1984. The
    Buffalo of the North-Caribou (Rangifer tarandus) and
    human devlopment. Arctic 37,7-22.

    Cameron, R.D. and K.R. Whitten. 1979. Seasonal movements and
    sexual segregation fo caribou determined by serial
    surveys. J. Wildl. Hgst. 43:626-633.

    Carruthers, D.r., R.D. Jakischuk and S. Ferguson. 1984. The
    relationship between the Central Arctic caribou herd and
    the Trans-Alaska pipeline. Prep. by renewable Resources
    consulting Services Ltd. for alyeska pipeline services
    company, Anchorage. 207 pp.

    carruther, D.A., R.D. Jakischuk and C. Linkswiler. 1984b.
    Spring and fall movements of Nelchina caribou in relation
    to the Trans-Alaska pipeline. Prep by renewable
    resources consulting Services Ltd. for Alyeska pipeline
    Service company, Anchorage. 101 pp.

    Carruthers, D.R. and R.D. Jakimchuk. 1985. The distribution
    and numbers of caribou in the Central Arctic region of
    Alaska, 1984-85. Prep. by Renewable Resources Consulting
    Services Ltd. for Alyska pipeline service company, ARCO
    Alaska, Inc., Chevron U.S.A. inc., Comoco Inc., Exxon
    company U.S.A., and sohio Alaska petroleum company.
    47 pp.

    Curatolo, J.A. and D.G. Roseneau. 1977. The distribution and
    movements of the porcupine caribou herd in northeastern
    Alaska and the Yukon Territory, 1976. Renewable Resources
    consulting services Ltd. Unpubl. Rep. Submitted to
    Northern Engineering Services Ltd. 59 pp.

    Dau, J.R. and R.D. cameron. 1986. Effects of a road system on
    caribou distribution during calving. Rangifer, special
    issue no. 1, 1986195-101.

    Davis, J.L., P. Valkenburg and K.D. Boertje. 1985.
    Distrubance and the Delta caribou herd. pp 2-6 in A.N.
    Kartell and D.E. Ressell (eds.). caribou and human
    activity. Proc 1st North am. Caribou Workshop, White-
    horse, Yukon. 28-29 Sept. 1963. Canadian Wildl. Serv.
    Spec. Publ., Ottawa.

    		33
    Jakischuk, R.D. 1986. The relationship of caribou summer
    distributions and the Trans-Alaska pipeline: Does absence
    mean displacement? Prep. by renewable Resources
    Consulting Services Ltd. for Joint Industry-Alaska dep.
    Fish and Game caribou Workshop, 28-30 October 1986.
    Nchorage. 23 pp.

    Jakimchuk. R.D., S.H. Ferguson and L.G. Sopuck. in press.
    Differential habitat use and sexual segregation in the
    Central Arctic caribou herd. Accepted by can. J. 2001.,
    sept. 1986.

    Jakimchuk, R.D., E.A. De Hock, R.J. Russell and G. P. Semenchuk.
    1974. A study of the porcupine caribou herd. 1971.
    Arctic Gas biol. Rep. Ser., ch. 1, vol, 4, 111 pp.

    Jakimchuk, R.D. and K. H. Mccourt. 1975. Distribution and
    movements of the porcupine caribou herd in the northern
    Yukon. Ins Proc. First int. reindeer and caribou symp.,
    Biol. papers univ. Alaska, special Rep. No. 1:140-154.

    LeReache, R.E. and S.A. Linderman, 1975. Caribou trail
    sytems in NOrthern Alaska. Arctic 23(1):54-61.

    Moore, G.D. 1976. A survey of ringed seal (phoca hispida)
    along the northeast Alaska and Yukon Territory coasts,
    1975. Arctic Gas biol. Rep. Ser., Vol. 36, ch. II.
    27 PP.

    Moore, G.D. and R. Quimby. 1974. Environmental considerations
    for the Polar bear (Ursus Maritimus, Phipps) of the
    Beaufort sea. Arctic Gas Biol. Rep. Ser. Vol. 32, ch. ii.
    57 pp.

    Quimby, R. and D.J. snarski. 1974. a study of fur-bearing
    mammals associated with gas pipeline routes in Alaska.
    Arctic Gas Biol. Rep. Ser. Vol. 6, ch. 11. 100pp.

    Roseneau, D.G., P. Stern and C. Warbelow. 1974. Distribution
    and movements of the porcupine caribou herd in north-
    eastern Alaska. in: K.H. Mccourt and L.P. Horstman
    (eds.). Studies of large mammal populations in northern
    Alaska, Yukon, and Northwest Territories, 1973. Arctic
    Gas Biol. Rep. Ser., Vol 22, Chapt. 4 197 pp.

    Roseneau D.G. and J.A. Curatolo. 1975. A comparison of the
    movements and distribution fo the porcupine Caribou herd,
    1971-74. paper presented at annual meeting Northwest
    Section Wildl. Society, April 3, 1975.

    		Draft-27 october 1986

    		34
    Roseneau, D.G. and J.A. Curatolo. 1976. The distribution and
    movements of the porcupine caribou herd in northeastern
    Alaska and the Yukon Territory. 1975. In: R.D.
    Jakimchuk (ed.). Sudies of mammals along the proposed
    Pickentie Valley gas pipeline route, 1975. Arctic Gas
    Biol. Rep. Ser. Vol. 36, chapt, 1. 82 pp.

    Sopuck, L.G. and R.D. Jakimchuk. 1986. Caribou monitoring
    studies in the central Arctic Region of Alaska. Final
    Report, Prep. by Renewable Resources Consulting Services
    Ltd. for Alyeska pipeline Service Company, ARCO Alaska
    Inc., Exxon Company U.S.A., Standard Alaska Production
    Company and Bp Alaska Exploration Inc.

    Whitten, K.R. DN R.D. Cameron. 1985. Distribution of caribou
    calving in relation to the prudhoe Bay oil fields.
    p. 35-39 in A. Martell and D. Russell (eds.) Proceedings
    First North As. Caribou workshop, whitehorse, 1983.
    Canadian Wildl. Serv. Spec. Publ., Ottawa. 68 pp.

    Whitten, K.R. 1986 Denography of the porcupine caribou herd,
    1978-1986. Presented at the Joint Industry-Alaska Dept.
    Fish and Game caribou workshop, 28-30 october 1986.
    Anchorage.

    	THE RELATIONSHIP OF
    CARIBOU SUMMER DISTRIBUTIONS
    	AND THE TRANS-ALASKA
    PIPELINE: DOES ASSENCE MEAN DISPLACEMENT?

    	BY
    R.D. Jakimchuk

    	For
    Joint Industry-Alaska Department of Fish & Game
    	Caribou Workshop
    	28-30 October 1986

                                                                                                                                    2

                                                                                                                         oil as test (exposure) areas both before
                                                                                                     between controls as w
                                                                                                     and after development. Finally, the study design would
              INTRODUCTION                                                                           encourage identification and measurement of exogenous
                                                                                                     environmental influences such an snow characteristics, plant
                                                                                                     phenology or seasonal flooding which may, independently of the
                       'The ideal experimental design to test whether calving                        previously mentioned variables, affect the distribution of and
              and post-calving cow/calf groups avoid TAPS and are displaced                          habitat use by caribou between two apparently similar areas.
              by oil developments in the Prudhoe Bay area is not available to
                                                                                                     Such measurements would help account for variations in use or
              us. Such a design would have as Its basic elements comparable
                                                                                                     density which might occur even where exhaustive attempts were
              pre-develOpment baseline data for control areas and areas which
                                                                                                     made to standardize the experiment based on the criteria I have
              would subsequently be perturbed. Comparable techniques would                           previously mentioned.
              be used to measure changes of various ecological variables in
              control and exposure areas before and following perturbation.                                   The lack of many of the foregoing elements has
              The experimental design would be careful to ensure that                                contributed to differing interpretations on the relationship
              comparisons are valid and would eliminate biases owing to                              between caribou distributions and North Slope petroleum
              either environmental variables or to the changing seasonal                             developments, especially an it pertains to calving
              behaviors and distributions of caribou. The designs would                              distributions and the percentage calves associated with the
              endeavor to eliminate biases associated with the highly clumped                        TAPS corridor. These differing interpretations, in turn, have
              or non-homogeneous distributions of caribou which characterize                         generated controversy which has often obscured rather than
              the species by recognizing the implications of differing                               clarified issues. However. despite deficiencies in many of the
              densities, grouping behaviour., sexual segregation, and                                data requirements I have described, there are numerous bodies
              differential habIltat use to the analysis. Surveys would be                            of evidence which can objectively focus on questions of caribou
              conducted during comparable time and life cycle periods to                             interaction with the TAPS corridor and the implication of that
              reduce the foregoing Potential biases. The foregoing would                             interaction. These data, accumulated over a period of the past
              ensure that data were comparable for the test and control areas                        16 years, provide a basis for interpreting the relative role of
              within years, so that between-year comparisons could be made                           ecological factors and disturbance in governing the

                                             3
                                                                                                                                   4
             distribution, movements and habitat use of Central Arctic                             the conclusions pertaining to the oilfteld presented by Smith
             caribou. In this paper I can only develop and substantiate                            and Cameron (1983) and Whitten and Cameron (1985). Figure I
             some important principiess I Ido not intend to review and                             shows the study area and the TAPS corridor.
             debate the minutiae of IS years of survey data but to point out
             some of the most significant findings which encompass the                                       The major conclusions of Ca meron and Whitten (1980_)
             period prior to and following development of the TAPS corridor.
                                                                                                   and Cameron at al. (1979) are that cowlealf groups avoid the
                                                                                                   TAPS corridor during calving and the summer period based on a
                       specific data for the area are available for the                            comparison of calf percentages along the corridor versus
             perio.d before extensive oilfield development, the construction                       regionally. The major conclusion of Smith and Cameron (1983)
             of the Dalton Highway in 1974. or the pipeline Ibetween 1975 and                      and Whitten and Cameron (1985) in that calving caribou have
             1977. The main sources of pre-development data are studies by                         been displaced from the Prudhoe Say Oilfield. This conclusion'
             Angus Gavin from 1969 to 1978 (Gavin 19771 Gavin and                                  in based on low densities of calving caribou in the field and a
             Chamberlain 1979), White et.al. (1975). and Child (1973).                             lower calf p.*rcentage of total caribou in the field versus the
      L      Post-devel.opment data are derived from a wide range of ADF&G                         regional percentage.
             and industry sponsored studies from 1975 to the present.

                                                                                                             The problem of comparability of data is  a major
                                                                                                   limitation to the conclusions drawn by Cameron and Whitten
             METHODOLOGICAL PROBLEMSt UNEQUAL COMPARISONS                                          (1980J. Cameron at al. (1979, 1985). In the latter final
                                                                                                   report, comparisons of calf percentages between regional and
                       One of the major difficulties in any analysis of                            corridor values during the calving period (June) are available
             Central Arctic caribou and development interactions in                                for only two years (1975-76) Of the seven-year study (197S-
             separating out the relative influence on caribou of the                               1982). Other seasonal periods were compared but they combined
             pipeline, the Dalton Highway and the oilfield development.                            periods In which seasonal distributions are known to vary
             Although this paper deals with the TAPS corridor, it cannot                           considerably and frequently in response to environmental
             ignore pre-construction calving distributions as they relate to                       factors. Thus, comparisons of short yearling percentages In
             Prudhoe Bay and TAPS.  Therefore I must comment, in part, on                          April/May between the TAPS corridor and regional values does

    		6

    not take into account sexual segregation (Figure 2) and
    differential habitat use by the sexes at that tiem (Figure 3),
    whitel comparisons for the July-August period are confounded by
    the extreme flux in movements in response to insects which can
    affect calf percentages in a specific area dramtically even on
    a given day (White et al. 1978). Even so, calf percentages
    along the corridor and regionally were the same in two of five
    years for the July-August period (Cameron et al. 1985),
    suggesting that factors other than the TAPS corridor influenced
    those percentages.

    	Although cameron et al. (1985) attempt to reduce
    previous biases in survey coverage of non-riparian habitats
    regionally by deleting road surveys south of Region 4 and
    coastal transects from serial surveys, regional surveys still
    appear to oversample non-riparian habitats. The published
    nethodology(Cameron and Whitten 1979) states a deliberate
    effort to sample non-riparian habitats on regional surveys for
    at least 3 km on either side of riparian habitats. Thus, many
    high density non-riparian calving areas are sampled in the
    regional surveys (Figure 4) and compared to the 1 km wide
    surveys on either side of the Dalton Highway which is closely
    associated with riparian habitat of the Sagavanirktok River
    (Figure 5). The route of TAPS does not transect such calving
    concentrations and traverses approximately three times the
    regional percentage of riparian habitat(Carruthers et al.
    1984).

                                                          7

                                                                                                                                                                          cgs

                               ISO-                                                                                                               Is.

                                                                                                                                                                                                         218

                                                                                                                                                                                                                    44      440
                               100
                             0                                                                                                                                                              - - - - - - - - - - - - - -     fly

                                                                                                                                                                                                           4
                                                                                                                                            0

                                                                                                                                            U
                             W                                                                                                              z

                             z  50-

                                                   0
                                                                                                                                            z
                                                                                                                                            df

                                                                                                                                                                                     $Is                 as
                                                                                                                                                                  110
                                                                                                                                                                                     4 7
                                             T         CALVING
                                          Li                          OtSUPTURVAL        RUT                                                           - - - - - -
                                        WINTIBER                   1                                                                                                                                                      221
                                                                 POST             -RUT
                                                SPRING                        PRE
                                                               CALVING                                                                                              sot                                           39

                                                                                                                                                                  SPRING POST-GAwme on-"?                $Palvs
                                                                                                                                                                                     TO                    to
                                    no $90        332     577     1065   1043 809        1164                                                                    CA To    ..S&T      out                 ALVING             a"
                                                                                                                                                                   "'IN*

                                     nz 251        90     529     $06    422     445     842

               Ficure 2. Seasonal variation in average distance to coast for
                               male and female caribou croups within the study area                                                                                                                        ce to riparian
                               ,(1981@4923).                                                                                              Figure 3.       Seasonal variation in median distan
                                                                                                                                                          habitat (km) of male and female caribou for four
                                                                                                                                                          subregions Of the study area (1981-1983)-
                                                                                                                                                          "Asterisk denotes that median distance is signifi-
                                                                                                                                                           cantly different than expected based on a random
                                                                                                                                                           distribution.
                                                                   0

                                                                                                                                                                      10

                                                                                                                                      0     20     40km                                             STUDY
                                                       9                                                                                                                                            AREA
                                                                                                                                             TRANS-ALASKA                                           ASKA
                                                                                                                                              PIPELINE
                                   SAY              BEAUFORT             SEA
                      .It          mint                                                                                                                                   PRUDHOE
                                                                                                                                                                             AY

                                                                                                     SAY

                                                              If
                                                                                                                                                        gig
                                                                                                                                                          !:,g

                        UWAT
                                                                                                                                                           no I
                                                                                                                                       R11
                                                                                                                                                                   0,

                                                                                                                                                                                         "INN.

                       0      20   40 his
                                                                                    OY-5

                               ABOVE GROUND Pipe
                                                                CONSIMUTLY-111111110
                               sUAIRD pipe                        CALVING AREA'                                                                                                         SEDGE-MEADOW
                                                                OUT 101                                                                 W
                                                                   9 BOUNDARY OF                                                                                                        TUSSOCK-MEADOW
                               DALTON 141CHWAY                  ALL CONCENTRATION
                                                                                                                                                                                  EM MAT-CUSHION
                               11URVffT AREA BOUNDARY           AREAS

                   Figure 4.       Location of calving concentration areas, 1981-1986.
                                   lArea of concentrated calving in 4 of 6 years from
                                   1981-1986 (between Canning and Colville Rivers) and
                                   in 2 of 3 years from 1984-1966 (west of Colville                                              Figure   5. Generalized habitat types within the study area.
                                   and east of Cannino River only).
                                   :-t.ls r,@,jnt&ry enccrpt!ses ell corcentr          atior. area--
                                   recorded frclr. 19EI-29EE.
                                                                                                                                                                                                r@T ny

                                                                                                                                   C

    			11
    	I do not disagree that calf percentages are lower
    along the TAPS corridor than for the region as a whole but with
    the interpretation of why they are lower. There is
    considerable eveidence that:

    	1. The prudhoe Bay area was not an important calving area even
    prior to development (Table 1; white et al. 1975; gavin
    1977; Gavin and CHamberlain 1979) (Figure 6).

    	2. There is well documented evidence that sexual segregation
    (cameron and Whitten 1979; Carruthers et al. 1984) and
    differential habitat use result in different distributions
    of cow/calf and bull groups in riparian versus non-riperian
    habitats (Jakinchuk et al., in press; curatolo 1985).
    Indeed, Curatolo found that this differential habitat use
    occurred even within intensively developed areas and that
    calf percentages were consistently lower in riparian
    habitat. Jakinchuk et al. ( in press) show that differing
    distance relationships to riparian habitats between bulls
    and cows are consistent regional distributional trend.

    	3. Finally, along the west Sak Road, where habitats noramlly
    used by cows and calves have been traversed by a road
    corridor, thus eliminating the habitat bias to a large
    degree, summer calf percentages have been the same or

    	Figure 6. Major calving areas of central Arctic caribou in 2
    of 4 years (1981-1983 inclusive _______ line
    dentes calving in at least one of four years (____
    Gavin 1977).

    				14
    Virtually the same as regional values in five of seven
    years following the development of the corridor (Table 2)

    	NOtwighstanding Table 2, which eliminates a major
    habitat bias, calf percentages alone are a poor measure of
    impact along the Taps corridor when one considers seasonal
    variations in caribou distribution in response to environmental
    influences such as snow cover, insect harassment, and
    differentail habitat use by teh sexes.

    	The major evidence presented that calving has been
    displaced from the prudhoe Bay area are the low calf
    percentages recorded, the low number of calving groups found
    there during summer and the higher incidence of calving south
    of prudhoe Bay (Whitten and cameron 1983; Smith and cameron
    1983). However, comparison of pre- and post-development
    calving distributions shows a similar distribution to that
    foudn in recent years (sopuck and Jakimchuk 1986), with more
    calving south of prudhoe Bay then in the Prudhoe Bay oilfield
    area even prior to extensive development (Figures 4 and 6).
    The apparent reason for this is the frequent, extensive
    flooding associated with sedge meadows in the Prudhoe Bay area.
    Late snow melt and flooding of lowland habitats in the coastal
    zone at calving has occured in 7 of the past 13 years where
    data are available (Table 3). In years of delayed snow melt,
    calving farther inland has been consistently reported. This

                                                                                                                                                 16
                                                   15
                                                                                                               Table 3.    Pheonology of snowmelt and calving distributions in
                Tabl* 2. A comparison of regional calf percentages and calf                                                the central Arctic region, 1970-1986.
                           percentages observed along the West Sak (Spine) Road
                           duting summer 1978-1984.
                                                                                                                      Snowmelt                Comments on
                                                                                                                      Phenglogy               Calving
                                                                                                               Year   During Calving          Distribution            Source
                          Spine Road          Regional
                           (West Sak)     Calf Percentages                                                     1970   No data                  Usual distribution*    Gavin 1977
                Year    Percent Calves     Percent Calves          source                                                                     (see Fig. 6)@
                                                                                                               1971   Deep #now coastal       Calving In foothills    Gavin 1977
                                                                                                                      plain
                                                                                                               1972,  Heavy snow              Low use of Coastal      Gavin 1977
                1978          26                 25         Cameron    Whitten  1979b                                                         Zone & Prudhoe Say
                                                                                                               1973   Dry year                Some inland calving     Gavin 1977
                1979          25.0               is         Cameron    Whitten  1980b                          1974   No data                 "Usual distribution"    Gavin 1977
                                                                                                                                              (Fig. 6)
                1980          20.0               21         Cameron at  al. 1981                                      No data                 Scattered calving, no
                                                                                                                                              concentration areas
                1981          18.0ab             27         Cameron et  al. 1983                               1976   Heavy snow              @"Usual distribution"   Gavin.1977
                                                                                                                                              (Fig. 6)
                1982          16.0           No  Data       Smith at al. 1964                                  1977                           "Usual distribution"   Gavin 1977
                                                                                                                                              (Fig. 6)
                1983          17.5               21         Smith et. al. 1984                                 1978   Late anowmelt,
                                                                                                                      flooding
                                                                                                               1979   Dry   relatively        go data                 Cameron  at al.
                1984          22.3               23.2       Smith at al. 1984
                                                                                                                      snow-free                                       1981
                a Represents 14.966 total caribou     seen  from the road in   1981                            1980   Late Snowmelt, -        More inland caribou     Whitten
                  versus 4,552 seen in 1960.                                                                          extensive flooding                              Cameron  1985
                                                                                                               1981   Dry, snow-free          Little inland           Cameron  at al.
                b*Of caribou observed crossing West     Sak road and Kuparuk                                          calving                                         1983
                  pipeline in 1981. calves were 251     of total  caribou.                                     1@82   Late enowmelt -         More calving            Whitten
                                                                                                                      extensive flooding      inland                  Cameron  198S
                                                                                                               1983   Relatively dry          usual (seerFig. 6)
                                                                                                               1984   Relatively dry          Usual (Fig. 6)          Sopuck a
                                                                                                                                                                      Jakischuk 1986
                                                                                                               1985   Relatively dry          Usual                   Sopuck
                                                                                                                                                                      Jakimchuk 1986
                                                                                                               1986   Late anowmelt           Majority inland         Sopuck
                                                                                                                                              calving east of         Jakimchuk 1986
                                                                                                                                              Sag River.

                                                  17

               seems to be a reasonable explanation for the consistent calving
                                                                                                                                                                     ATTACHMENT E
               associated with the Franklin Bluffs area south of Prudhoe Bay                                                             TESTIMONY ON THE
                                                                                                                        DRAFT LEGISLATIVE ENVIRONMENTAL IMPACT STATEMENT
               which was documented prior to extensive oilfield development at                                               'ARCTIC NATIONAL WILDLIFE REFUGE, ALASKA,
                                                                                                                                COASTAL PLAIN RESOURCE ASSESSMENT'
               Prudhoe Bay.                                                                                                               Anchorage, Alaska
                                                                                                                     Presented by the Alaska Oil and Gas Association (AOGA)
                                                                                                                                          'January 5, 1987
                           Tf we look at factors affecting pre- and post-                                    I am Tom Cook, Alaska Exploration Representative for Che4ron
                                                                                                             U.S.A. Inc.    Today I am appearing before you on behalf of the
               calving distributions we find strong well-documented ecological                               Alaska Oil and Gas Association.      AOGA is a trade association whose
                                                                                                             member companies account for the majority of oil and gas. explora-
               reasons to explain observed distributions.        When we test these                          tion, production and transportation activities in Alaska.          Let me
                                                                                                             say at the outset that AOGA strongly supports the Department of
               hypotheses by looking at known calving and post-calving areas                                 interior's proposed recommendation that the entire *1002" area,
                                                                                                             also known as the Coastal Plain, be authorized for oil and gas
               where development has occurred, such as the West Sak Road area                                exploration and production.     We have restricted our comments today
                                                                                                             to three aspects of the '1002(h) report*, but will submit detailed
               and Prudhoe Bay, we find that the hypotheses pertaining to                                    written comments on the entire report before the January 23, 1987
                                                                                                             deadline specified in the Federal Register Notice.
               habitatluse and their effects on distribution hold (Curatolo                                  Mr.  Mike Bradshaw of Conoco will first address the national
       9       1985:  Jakimchuk et al., in press:       this pap -er).  The                                  interest   in developing     the petroleum resources discussed          in
        L                                                                                                    Chapter VII, then Mr. Mark McDermott of ARCO will comment on the
                                                                                                             biological content of Chapters 11 and VI.          I will conclude our
               explanations for apparent discrepancies between what occurs
                                                                                                             statement with comments on the recommended stipulations applicable
                                                                                                             to the area, together with an endorsement of the proposed full
               alony the TAPS corridor and recionally are in response to                                     leasing @lternative A selected for recommendation by the Assistant
               e@ological factors.    This explains the apparent contradiction                               Secretary for Fish and Wildlife and Parks, William P. Horn.
               of avoidance of TAPS but no avoidance of the Spine Road during                                       Comments on National Need for Oil and Gas (Chapter VII)
                                                                                                             Thank you.     For the record, I am Mike Bradshaw, Operations
               summer by the same caribou on the same summer range.                                          Director-Alaska for Conoco Inc.       There are many factors that are
                                                                                                             relevant in determining why opening the ANWR Coastal Plain to oil
                                                                                                             and gas leasing, exploration and production io          in the national
                                                                                                             interest,
                          1 have concluded that absence does not equal
                                                                                                                  The U.S. is rapidly depleting its domestic         reserves of oil
               displacement. I do not think that cow/calf groups avoid TAPS                                       and gas.

               but the major river valley associated with TAPS - a                                                Domestic crude oil production from existing        fields is fore-
                                                                                                                  cast to decline from the 8.9 million barrels       per day average
               relati.:,r.ship which also holds regionally for other comparable                                   in 1965 to 6.2 million barrels per day by          1991, if prices
                                                                                                                  remain at $15 per barrel.       Current domestic production has
               maior rivers such :s the canning and Colville.        Similarly, I                                 already fallen to about 8.5 million barrels        per day.     Dome-
                                                                                                                  stic production is forecast to fall as low as 4 million
               think. the evidence 4s strong that the Prudhoe Bay conplex prior                                   barrels per day by the year 2000.
               to developrent was not an important calving area.        Its present                               Currently Alaska supplies our nation with approximately 20%
                                                                                                                  of the total U.S. production.

                                                                                                             NS3:317/AOGA FINAL/01-05-87         -I-

                    Barring   new   domestic    discoveries    to   replace    depleted                      illustrates very well the significance of such a reserve if it is
                    reservear and assuming the demand for petroleum does not                                 discovered and produced from the Coastal Plain.        A few months is
                    increase, the U.S. may need to import 12 million barrels per                             Indeed significant when compared on the same terms with the 18
                    day by the year 2000.      Thus, without significant new dis-                            month supply . in the largest oilfield ever discovered in North
                    coveries, our nation could be dependent upon foreign sources                             America -, Prudhoe Bay.    out, the statement is misleading for two
                    for 60-751 of its demand, within the next 10-15 years, almost                            very important reasons.    First, no oil field can be fully produced
                    double the present level of dependency.                                                  in a few months.     Prudhoe Bay, for example, may produce oil and
                                                                                                             gas for at least 30 years.         Second, the statement assumes a
               Currently the U.S. consumes more than 25 percent of          i worldwide                      reserve.estimate which would offset total daily consumption rather
               petroleum production even though it has less than 4 percent of                                than an offset to imports during the life of the field.           From a
               proven worldwide reserves.     Policy decisions which slow or pro-                            national security perspective,       offsetting imports     Is a more
               hibit replenishment of domestic reserves        only exacerbate this                          important comparison. - Prudhoe Bay, on average, could offset
               .problem.  Opportunities to explore for and develop.new reserves                              approximately 13% of foreign oil imports for 30 years (assuming 10
               must be forthcoming.                                                                          billion barrels recoverable reserves and 7 million barrels per day
                                                                                                             imports)..
               .As we have seen in recent years, the.U.S. is    vulnerable to serious
               supply disruptions because of its dependence on foreign- oil.                                 The report estimates a 191 chance of finding economically -recov-
               Foreign sources of petroleum are concentrated largely in the                                  erable oil on the Coastal Plain.         This promising outlook for
               Middle East where two-thirds of the proven reserves of the non-                               success helps explain industry's high interest in exploring the
               communist world exist.     Saudi Arabia alone possesses. over one-                            Coastal Plain because it is a ten-fold increase over the statis-
               @fourth.of the free world's reserves.     increased future dependency                         tical indust'ry success rate in Alaska.      Historically only one out
               on these politically unstable Middle Eastern areas is highly un-                              of fifty, or 2%, of the exploratory wells drilled. in Alaska has
               desirable from a national interest viewpoint.                                                 ever resulted in a commercial discovery
               As domestic production continues to decline,      and imports continue                        Economic benefits of f  urther North Slope development to the notion
               to rise, U.S. vulner'abilit"y to supply disruption will increase. A                           are e-t.remely significant. . In addition' to the direct-benefits to
               relia"e domestic energy soppl'Y is a k-ey factor in maintaining a                             the State and Federal governments from bonus payments, rentals,
               viable"f,reign policy.                                                                        royalties, and taxes, the discovery of large new reserves would
                                                                                                             significantly reduceoil imports and the associated national trade
               it is in the national security and economic interest to encourage                             deficit. Nearly half of the U.S. trade deficit today results from
               exploration for new domestic reserves wherever the potential                                  imported oil.
               exists, on the Coastal Plain of ANWR and     ' other promising areas.
               Any decision to delay that search to a step toward Increased                                  Oil development on the North Slope of Alaska has provided hundreds
               dependency on foreign supply.       Lead times to develop frontier                            of billions of dollars to the U.S. economy, representing a benefit
               Alaska oilfields are very long, typically 10 to 15 years from                                 to all of the 50 states.       Therefore, petroleum development from
               .discovery to first production. If a major discovery were made on                             the Coastal Plain, especially on the order of magnitude of Kuparuk
               the Coastal Plain today, first production would not be likely                                 or Prudhoe Bay, would promote economic development not only within
               before the year 2000.                                                                         Alaska, but also throughout the United States.           Jobs would be
                                                                                                             created as the demand for goods and services incr4ase and the
               Increasing consumption, decreasing domestic production, and rising                            Positive impacts would be felt well beyond the petroleum industry.
               imports, coupled with delay in oppning promising new areas to
               exploration and development are all factors which collectively                                If highly prospective areas such as the Coastal Plain are placed
               will contribute to the likelihood of a future energy crisis.        1986                      off limits to petroleum exploration, the nation may experience a
               was a year of drastic change throughout the oil and gas industry,                             future energy crisis which will make the 1973 embargo and the
               Exploration is currently at a near standstill, marginal and                                   1-9?9-1980 price escalation seem mild by comparison.
               uneconomic fields are being shut-in, and research and development
               have been drastically reduced.       Continuity of exploration and                            in sumfrary., we believe it is clearly in the national interest to
               development are necessary to replace depleted reserves.       Delays in                       open the Coastal Plain of ANWR to leasing and development.
               the exploration process today will cause greatly reduced future
               production.                                                                                   1 will now turn the microphone to Mark McDermott with ARCO who
               Those who oppose oil resource development argue that the reserve                              will comment on the biological aspects of the draft report.
               potential of the Coastal Plain mAy represent only a few months
               supply of oil to the nation.      This statement, though mii1eading,

                                                                                                              -@Z_0.
               11S3:3@7/AOCA FIIIAL/01-05-87       -2-                                                       [IS3,377/A.OCA rINAIL/01-05-87      -3-

                                     Biological Review Comments                                              occur' assessment of impacts.       The standard for the "most likely
                                                                                                             to occur" case exists in the experience from other North Slope
              fly name is mark McDermott and I am a Senior Environmental                                     oillields. Many of' these specific points will be detailed in our
              Coordinator for ARCO Alaska, Inc.      Following a detailed review of                          written comments.
              the LEIS Chapter 11 - Existing Environment and Chapter VI -
              Environmental Consequences, the Alaska Oil and Gas Association                                 Caribou
              strongly endorses the DOI recommendation to lease the entire
              *1002' Coastal Plain area for oil and gas exploration, development                             We agree that caribou, both from a standpoint of numbers and
              and production based on the following points and conclusions:                                  distribution, is the specie most likely to encounter developmental
                                                                                                             activities in the 01002" area. The LEIS quote from page 6 states
              Prudhoe Say Region/TAPS                                                                        that "Changes could include displacement and reduction in the size
                                                                                                             of the Porcupine Caribou Herd.       The amount of reduction and its
              Often the National Environmental Policy Act 01EPA) -mandated EIS                               long-term significance for herd viability is h hly s eculative'
                                                                              of new                                                                              ig   quflfi
              process -tries    to predict    environmental    consequences                                  (emphasis added).     We ask that these acknowledged               cations
              developments with little or no previous field experience to guide                              be presented throughout the environmental consequences section to
              the predictions.    Clearly, for the ANWR Coastal Plain, test cases                            ensure that all readers of the document are fully aware of the
              have already been run at Prudhoe Day, Kuparuk, Milne Point,                                    highly speculative nature of some of the hypothesized impacts.
              Lisburne, and Endicott,      and with the Trans Alaska Pipeline.
              Collectively,   the experience of the regulatory agencies and                                  Carrying Capacity
              -industry is summarized in the LEIS on page 2:           'The evidence
              generated during the 18 years of exploration and development at                                In the management of wildlife populations, the concept of habitat
              Prudhoe Bay indicates minimal impact on wildlife              resources.                       carrying capacity is key to defining management goals.          It is an
              Hence, it is reasonable to assume that development can proceed on                              established fact that the Porcupine Herd does not approach the
              the Coastal Plain and generate similar minimal effects.'                                       carrying capacity of its range.      Indeed, former Alaska Fish'& Game
       9                                                                                                     Commissioner, R. Skoog, in his Doctoral dissertatio@ (1968) stated
              Furthermore, we support the statement, also on page-2 of      the LEIS,                        that *It seems likely that the Alaskan caribou population has
              that 'Most adverse effects would be minimized or. eliminated
       OD     through carefully applied mitigation, using the lessons learned                                remained far below range carrying capacity and -that the total
                                                                                                             habitat has never been fully occupied.            In reality,      caribou
              and technology acquired from development at other North Slope                                  populations seem to have maintained densities much lower than the
              oilfields and from the construction and operation of the Trans-                                maximum dictated by food alone, and hence the reduction in total
              Alaska Pipeline System (TAPS)'.                                                                range becomes less    meaningful.* Thus, we agree with the conclu-
              Indeed, we would like to point out that all of the dire predic-                                sions that habitat    is not currently limiting the growth of the
              tions of environmental degradation ma4e 15 years ago, prior to the                             Porcupine Herd and    that the small loss of habitat represented by
                                                                                                             likely development    in the '1002' area will not impact growth or
              construction of TAPS, have subsequently been proven to be un-                                  productivity of caribou.        Consequently, we disagree with the
              founded.  The predicted demise of major caribou herds, deteriora-                              speculation that a reduction of caribou population is likely to
              tion in water quality and major losses of habitat simply have not                              occur as a result of small reductions in habitat availability and
              occurred.   Instead, the development of Prudhoe Bay and the TAPS                               value.
              have allowed Alaskans to enjoy economic prosperity in harmony with
              a high quality environment and thriving wildlife populations.                                  'Core Calvina Area" Concept
              National Environmental Policy Act                                                              @Significant year-to-year variability in ca!ving distribution has
                                                                                                             been recorded for the Porcupine Herd all across the Arctic coast
              We understand that the draft document is a legislative EIS largely                             from east into Canada and west to the Canning River.         Concentrated
              following the requirements of the National Environmental Policy                                calving has been observed across the entire so-called core calving
              Act.  We would like to point out that many of the environmental                                area during only 5 of the past 14 years.             Therefore, calving
              consequences predicted to occur for the 5 alternatives appear to                               habitat is more appropriately represented as a true continuum
              be based on 'worst case* evaluations.      In April 1986 the 11EPA-EIS                         across the Coastal Plain including portions of the Arctic coast
              guidelines were changed from requiring a 'worst case" assessment                               outside the '1002* study area.        The Porcupine Caribou Herd has
              to one of *most likely to occur.' vie feel that many of the major                              demonstrated numerous times in the past, including this past year,
              conclusions of significant effects carry the earlier *worst case"                              that it can and will successfully calve miles from the (quote)
              assessment to an extrene and thus we ask that the authors re-                                  *core calving area' (unquote).      Thus, the "unique and irreplace-
              consider many of their conclusions in light of the "most likely to                             able" nature required for designation as Resource Category 1 does
                                                                                                             not apply.

            .NS3:377/AOGA FINAL/01-05-87          -4-                                                        NS3:377/AOGA FINAL/01-05-87         -5-

               While AOGA embraces the responsible use of mitigation procedures
               in the Arctic, it is inappropriate to emphasize habitat loss alone                            the contiguous states costs thousands of dollars and requires an
               without consideration of actual effects or lack of          effects on                        air charter flight to reach the Coastal Plain.            Wet and moist
               wildlife populations from development.                                                        ground conditions make hiking difficult during the 8-10 week
                                                                                                              summer.' Extreme cold and darkness during most of the year
               Muskox                                                                                        further reduce recreational use of the Coastal Plain.        For most of
                                                                                                             the year this is an extremely harsh and hostile environment.
               We feel that the conclusioni regarding potential impacts of                                   While there is no reason to believe that leasing and development
               development on muskox are unnecessarily severe and unfounded.                                 would lead to a permanent loss of aesthetic values, over 30 miles
               While it is true that very few data characterizing muskox res-
               ponses to oil field development are available, it is also true                                of Coastal Plain from the '1002' area east to the Canadian border
               that the muskox have shown ready adaptability to human presence                               are already    classified as wilderness, thus preserving theL com-
               and have even been semi-domesticated in several areas.              This                      plete spectrum of arctic ecosystems represented in the Arctic
               adaptability to human presence will significantly reduce the                                  Refuge.
               *worst-case" conclusions stated in the LEIS.                                                  Summary
               Mammalian Species                                                                             Before I ask Mr. Cook to conclude our statement, I would like to
               We feel that it is important to point out that the remaining                                  acknowledge the 5 years of extensive field investigations, data
               mammalian species  including moose, dall sheep, wolves, arctic fox,                           collections and analyses by over 50 trained professional scien-
               wolverines and brown bears are present on the Coastal Plain in                                tists,   including wildlife and fishery biologists,            botanists,
               relatively   low population densities or        'for relatively short                         zoologists, chemists, geologists and resource specialists who
             .periods during the year.       Thus, we support the conclusions of                             contributed to this draft report. we consider the factual basis-
               minimal or negligible impacts on these species.                                               for the scientific -analysis to be adequate and the conclusions to
                                                                                                             be reasoned.    However, we cannot support some of the speculation
               Fishery Populatinna                                                                           on environmental consequences found in the report which result in
                                                                                                             an over estimation of potential impacts.
               We support the conclusion that only minor to negligible effects        on
               coastal fishery resources or fishery habitat will occur.         Experi-                      Concluding Remarks
               ence at Prudhoe Say and Endicott has provided a significant volume
               of data to support this judgment.                                                             As previously stated AOGA supports the full leasing of the ANWR
                                                                                                             Coastal Plain under reasonable measures for environmental pro-
               Threatened and Endangered Species                                                             tection.    Except for a few provisions, the proposed stipulations
                                                                                                             found in the report and the land use stipulations found in the
               We also support the conclusions of minor to negligible impacts on                             Agreement Between the Arctic Slope Regional Corporation and the
               endangered and threatened animal species such as bowhead and grey                             United Stptes of America (incorporated into the report by refer-
               whales and the peregrine falcon.        We   feel that the trAnsient                          ence), appear reasonable.       The proposed mitigation measures are
               nature of their presence on the Coastal      Plain and the history.of                         generally consistent with current and proven industry practices
               developmental interaction in the Prudhoe Bay field clearly demon-                             for the protection of wildlife and the environment.         The applica-
               strate the lack of meaningful impacts on     these species.    Regarding                      tion of reasonable mitigation can ensure that development is
               the plant, Thlaspi arcticum, we feel that conclusions and set-back                            conducted in a manner compatible with the purposes of the Refuge
               stipulations based on the presence of this specie are overly                                  and ensure that no unnecessary adverse environmental impacts
               restrictive because the plant has not been determined to be                                   occur.   Our written comments will address in detail, those mea-
               threatened or endangered.                                                                     sures that we believe are unduly restrictive.
               Recreation                                                                                    AOGA strongly endoraes Alternative A, full leasing of the '1002'
                                                                                                             study area, as the most acceptable alternative consistent with the
               We would like to underscore the extraordinarily low use of the                                national interest.     Alternative B, partial leasing, is based on a
               Coastal Plain as a recreational area.     History indicates that only                         speculative premise that a traditional core calving area exists
               a small number of individuals have actually utilized the Coastal                              !nd is necessary for the maintenance of a healthy caribou herd.
               Plain for recreation in the form of hunting, fishing, camping or                              This has not been demonstrated in the scientific literature and
               hikina.  it is extremely expensive to reach the area; a trip from                             there is a large body of data which indicates otherwise.            Alter-
                                                                                                             native C maker no positive contribution.          Surface and regional
                                                                                                             geologic information already confirm that the area has oil poten-
                                                                                                             tial.   The amount can only be verified by on-structure drilling.

               tIS3;3?7/AOGA FIIIAL/01-05-87       -6-                                                       fIS3:377/ACGA FINAL/01-05-87         -7-

             stratigraphic type drilling is an unnecessary duplication a    n'd 'it
                                                                                I                                                    TESTIMONY ON THE
             surface impact would be in addition to that eventually required                                        DRAFT LEGISLATION ENVIRONMENTAL IMPACT STATEMENT
             for on-structure wells.   Also, Alternative C would just be another                                        *ARCTIC NATIONAL WILDLIFE REFUGE, ALASKA,
             delay in the eventual production from the area.      Neither Alterna-                                         COASTAL PLAIN RESOURCE ASSESSMENT'
             tives D, no action, nor E, wilderness designation, would determine                                                      Washington, D.C.
             whether or not substantial petroleum reserves exist in the *1002'                                   Presented by the Alaska Oil and Gas Association (AOGA)
             study area.   Alternatives D and E preclude reasoned planning and
             would deny the nation the positive benefits that could come from                                                         January 9, 1987
             oil and gas production on the Coastal Plain.                                                I am Wayne Smith, District Manager of Amoco Production Company and
             We fully support the proposed recommendation on page 169 which                              President of the Alaska Oil and Gas Association (AOGA).            I am
                                                                                                         appearing before   you today on beh-alf of AOGA which is a trade
             contains the following statement:       even though the billions of                         association whose  member companies account for the majority of oil
             barrels of oil reserves have been brought on line and the infra-                            and gas exploration, production and transportation activities in
             structure developed to bring that oil to U.S. markets, the fish                             Alaska.   AOGA strongly supports the Department of the Interior's
             and wildlife resources of the Prudhoe Bay area remain extremely                             proposed recommendation that the entire '1002' area, also known as
             healthy.   The Central Arctic Caribou Herd has increased substan-                           the Coastal Plain of the Arctic National Wildlife Refuge (ANWR),
             tially during the period that development has occurred within the                           be authorized for oil and gas leasing, ex-ploration and production.
             heart of its range.   Estimated at about 3,000 animals in 1972, the
             herd now numbers more than 13,000.    Similarly, important waterfowl                        Currently, Alaska supplies our nation with approximately 20% of
             species continjue to successfully nest and rear their brood within                          its total domestic production.      Lead times are long in frontier
             the developed area.   Although circumstances within the '1002* area                         Alaska regions--at least 10 years from discovery to first pro-
             may be somewhat different, the evidence derived from the Prudhoe                            duction, but more likely to extend as long as 15 years in the case
             Bay experience leads one to be quite optimistic about the ability                           of the ANWR Coastal Plain.     Without significant new discoveries,
             to explore for and develop the hydrocarbon potential of the '1002"                          our nation could be dependent upon foreign sources for 60-75% of
             area without significant deleteriou-s effects on the unit's wild-                           its petroleum needs within the next 10-15 years, almost double the
             life resources.'                                                                            present level of dependency.
             Thank you for this opportunity to comment.                                                  Production   from existing Arctic Alaska oil        fields which are
                                                                                                         presently being produced at about 1.8 million barrels per day will
                                                                                                         begin a precipitous decline by 1988.      it is a matter of technical
                                                                                                         certainty that the present level of production from Alaska's North
                                                                                                         Slope will decline to about 500,000 barrels per day by the year
                                                                                                         2000, earliest date by which new production from the AVVIR Coastal
                                                                                                         Plain would likely be available.
                                                                                                         If highly prospective areas such' as the Coastal Plain are placed
                                                                                                         off limits to petroleum exploration, the nation mall experience a
                                                                                                         future energy crisis which will make the 1973 embargo and the
                                                                                                         1979-1980 price escalation seem mild by comparison.

                                                                                                         Increasing con  Sumption and rising imports along with decreasing
                                                                                                         domestic reserves and production, coupled with delay in opening
                                                                                                         promising new areas to exploration and development, are all
                                                                                                         factors which collectively will contribute to the likelihood of a
                                                                                                         future energy crisis.

                                                                                                         The resource assessment contained in the draft LEIS for the
                                                                                                         Coastal Plain supports our view that the area may contain
                                                                                                         significant reserves.    The Coastal Plain has great potential for
                                                                                                         making a substantial contribution to our domestic energy supply.

                                                                                                         Even the most optimistic production scenario will physically
                                                                                                         utiiize only a very small area of the Coastal Plain.          The very
                                                                                                         small area which would be affected by discovery and development of

                                                                                                         IIS-4:365/AOGA FINAL/01-09/87      -1-
             NS3-377/AOGA FINAL/01-05-87        -8-

                1 or 2 giant oil fields should be balanced against the very strong
                contribution to the national interest that such discoveries could                                 that no unnecessary adverse environmental impacts occur.                  Our
                represent.                                                                                        written comments will address in detail, those measures that we
                                                                                                                  believe are unduly restrictive.
                Our industry has demonstrated its compatibility to explore for,
                develop, and produce oil in the Alaska.Arctic without significant                                 A06A strongly endorses Alternative A, full leasing of the "10021
                adverse impact on wildlife and the environment.          The dire predic-                         study area, as the most acceptable alternative consistent with the
                tions of environmental degradation and harm to wildlife made 15                                   national interest.      Alternative B, partial leasing, is based on a
                years ago, prior to the development of the giant Prudhoe Bay field                                speculative premise that a traditional core calving area exists
                and the construction of the Trans-Alaska Pipeline have proven to                                  and is necessary for the maintenance of a healthy caribou herd.
                be unfounded.     The predicted demise of major caribou herds,                                    This has not been demonstrated in the scientific literature and
                deterioration in water quality and major losses of habitat simply                                 there is a large body of data which indicates otherwise.               Alter-
                have not occurred.                                                                                native C makes no positive contribution.            Surface and regional
                                                                                                                  geologic information already confirm that the area, has oil poten-
                Instead, the development of Prudhoe Bay and the Trans-Alaska                                      tial.    The amount can only be verified by on-structure drilling.
                Pipeline have permitted the production of 5 billion barrels of                                    Stratigraphic type drilling is an unnecessary duplication ans] its
                much needed oil with minimal environmental impact.          During the 15                         surface impact would be in addition to that eventually required
                year period of development wildlife have thrived in the midst of                                  for on-structurewells.       Also, Alternative C would just be another
                oil field development and evidenced by the fact that the Central                                  delay in the eventual production from the area.           Neither Alterna-
                Arctic Caribou Herd has grown from about 3,000 to a population now                                tives D, no action, nor E, wilderness designation, would determine
                estimated at over 13,000 animals.                                                                 whether or not substantial petroleum reserves exist in the '1002*
                                                                                                                  study area.     Alternatives D and E preclude reasoned planning and
                with regard to the issue of protecting the Porcupine Caribou Herd                                 would deny the nation the positive benefits @hat could come from
                which uses the Coastal Plain on a seasonal basis, there has been a                                oil and gas production on the Coastal Plain.
                development s  ,nce the issuance of the draft report which I would
                like to mention.      On December 3, 1986, the United States and                                  AOGA's. expresses     its full support of the Department of               the
                Canada have devised an agreement for the management and conserva-                                 Interior's    proposed    *recommendation    to Congress     which     states
                tion of the Porcupine Caribou Herd.          This agreement which also                            I ... even though the millions of barrels of oil resources have been
                involved the native subsistence users of both the Canadian and                                    brought on line and the infrastructure developed to bring that oil
                American Arctic assures that appropriate steps will be taken to                                   to U.S. markets,' the fish and wildlife resources of the Prudhoe
                guarantee the well-being and preservation of the Porcupine Caribou                                Bay area remain extremely healthy.           The Central Arctic Caribou
                Herd.   in view of this development, the final report to be sub-                                  Herd has increased substantially during the period that develop-
                mitted to the Congress should be revised to reflect this new                                      ment has occurred within the heart of its range.              Estimated at
                measure of protection afforded the Porcupine Caribou Herd.                                        about 3,000 animals in 1972, the herd now numbers more than
                                                                                                                  13,000.     Similarly,    important    waterfowl    species    continue    to
                I would like to acknowledge the 5 years of extensive field                                        successfully nest and rear their brood within the developed area.
                investigations, data collections and analyses by over 50 trained                                  Although circumstances within the 11002" area may be somewhat
                professional scientists, including wildlife and fishery biolo-                                    different, the evidence derived from the Prudhoe Bay experience
                gists, botanists, zoologists, chemists, geologists and resource                                   leads one to be quite optimistic about the ability to explore for
                specialists who contributed to this draft report. We consider the                                 and develop the hydrocarbon potential of the "1002* area without
                factual basis for    the scientific analysis to be adequate and the                               significant deleterious effects on the unit's wildlife resources'.
                conclusions to be reasoned.       However, we cannot support some of
                the speculation on environmental consequences found in the report                                 Thank you for the opportunity to present this statement.
                which result in an   over estimation of potential impacts.

                Except for a few provisions, the proposed stipulations found in
                the report and the land use stipulations found in the Agreement
                Between the Arctic Slope Regional Corporation and the United
                States of America (incorporated into the report by reference),
                appear reasonable. The proposed mitigation measures are generally
                consistent with current and prover. industry practices for the
                protection of wildlife and the environment.          The application of
                reasonable mitigation can ensure that development is conducted in
                a manner compatible with the purposes of the Refuge and Prisure

                tIS3:365/AOGA FINAL/01-09/87         -2-
                                                                                                                  NS3:365/AOGA FINA11/01-09/8-          -3-

                 W YOU VMff M MAKE PURLIC CDMWS?
                                                                  61

                                                                                                                                                          TESTIMONY ON THE
                 If you would like to speak at the hearing today, pleaselill, to the blanks                                           DRAFT LEGISLATIVE ENVIRONMENTAL IMPACT STATEMENT
                 ;slaw, and turn It in to one of the Fish and Wildlife Staff members present.                                              "ARCTIC NATIONAL WILDLIFE REFUGE# ALASKA,
                 You need not complete this shoat to submit wrLtten:cosments. Thank you.                                                       COASTAL PLAIN RESOURCE ASSESSMENT"
                                                                                                                                                           Anchorage, Alaska
                                                                                                                                  Presented    by the Alaska Oil and Gas Association MGM
                 Please print                                                                                                                               January 5, 1967
                                                                                                                          I am Tom Cook, Alaska Exploration Representative for Chevron
                                                                                                                          U.S.A. Inc.      Today I am appearing before you on*behalf of the
                                                  r                                                                       Alaska oil and Gas Association. AOGA is a trade association whose
                 MallinA Address-           @@o    -1-f,--J1 -E                                                           member companies account for the majority of oil and gas explora-
                                            d,      e     f;                                                              tion, production and transportation activities in Alaska. Let me
                                                                                                                          say ht the outset that AOGA strongly supports the Department of
                                                                                                                          interior's proposed recommendation that the entire "1002" area,
                 Check appropriate box belows                                                                             also known as the Coastal Plain, be authorized for oil and gas
                                                                                                                          exploration and production. We have restricted our comments today
                  C3 I an here to offer my own views.                                                                     to-three aspects of the "1002(h) report*, but will submit detailed
                                  --or-                                                                                   written comments on the entire report before the January 23, 1987
                       I am speaking for                    0                       C_     61,@@.                         deadline specified in the Federal Register Notice.
                                          (please enter seem Of organization you represent)                               Mr. Mike Bradshaw of Conoco will first address the national
                                                                                                                          interest in developing the petroleum resources discussed in
                                                                                                                          Chapter VII, then Mr. Mark McDermott of ARCO will comment on the
                                                                                                                          biological content of Chapters II and VI.                 I will conclude our
                                                                                                                          statement with comments on the recommended stipulations applicable
                                                                                                                          to the area, together with an endorsement of the proposed full
                                                                                                                          leasing Alternative A selected for recommendation by the Assistant
                                                                                                                          Secretary for Fish and Wildlife and Parks, William P. Horn.

                                                                                                                                  Comments on National Need for Oil and Gas (Chapter VII)

                                                                                                                          Thank you.       For the record, I am Mike Bradshaw, Operations
                                                                                                                          Director-Alaska for Conoco Inc. There are many factors that are
                                                                                                                          relevant in determining why opening the ANWR Coastal Plain to oil
                                                                                                                          and gas leasing, exploration and production is                  in the national
                                                                                                                          interest.

                                                                                                                          o     The U.S. is rapidly depleting its domestic                reserves of oil
                                                                                                                                and gas.

                                                                                                                                Domestic crude oil production from existing               fields is fore-
                                                                                                                                cast to decline from the 8.9 million barrels              per day average
                                                                                                                                in 1985 to 6.2 million barrels per day by                 1991, if prices
                                                                                                                                remain at $15 per barrel.           Current domestic production has
                                                                                                                                already fallen to about 8.5 million barrels               per day.      Dome-
                                                                                                                                stic production is forecast to fall as low as 4 million
                                                                                                                                barrels per day by the year 2000.

                                                                                                                                Currently Alaska supplies our nation with approximately 20%
                                                                                                                                of the total U.S. production.

                                                                                                                                Barring     new    domestic discoveries          to    replace      depleted
                                                                                                                                reserves, and assuming the demand for petroleum does not

                  increase, the U.S.. may need to import 12 million barrels per                           indeed significant when compared on the same terms with the 18
                  day by the year 2000.       Thus, without significant new dis-                          month supply in the largest oilfield ever discovered in North
                  coveries, our nation could be dependent upon foreign sources                            America - Prudhoe Bay. But, the statement is misleading for two
                  for 60-75% of its demand, within the next 1.0-15 years, almost                          very important reasons. First, no oil field can be fully produced
                  double the present level of dependency.                                                 in a few months.     Prudhoe Day, for example, may produce oil and
                                                                                                          gas for at least 30 years.          Second, the statement assumes a
             Currently the U.S. consumes more than 25         percent of worldwide                        reserve estimate which would offset total daily consumption rather
             petroleum production even though it has less than 4 percent of                               than an offset to imports during the life of the field. From a
             proven worldwide reserves.      Policy decisions which slow or pro-                          national security perspective, offsetting imports is a more
             hibit replenishment of domestic reserves only exacerbate this                                important comparison.       Prudhoe Bay, on average, could offset
             problem.   Opportunities to explore for and develop new reserves                             approximately 13% of foreign oil imports for 30 years (assuming 10
             must be forthcoming.                                                                         billion barrels recoverable reserves and 7 million barrels per day
                                                                                                          imports).
             As we* have seen in recent years, the U.S. is vulnerable to serious
             supply disruptions because of its dependence on foreign oil.                                 The  report estimates a 19% chance of finding economically recov-
             Foreign sources of petroleum are concentrated largely in the                                 erable oil on the Coastal Plain.          This promising outlook for
             Middle East where two-thirds of the proven reserves of the non-                              success helps explain industry's high interest in exploring the
             communist world exist.      Saudi Arabia alone possesses over one-                           Coastal Plain because it is a ten-fold increase over the statis-
             ..'ourth of the free world's reserves. Increased future dependency                           tical industry success -ate in Alaska. Historically only one out
             on these politically unstable Middle Eastern areas is highly un-                             of fifty, or 2%, of the exploratory wells drilled in Alaska has
             desirable from a national interest viewpoint.                                                ever resulted in a commercial discovery

             As domestic production continues to decline, and imports continue                            Economic benefits of further North Slope development to the nation
             to rise, U.S. vulnerability to supply disruption will increase. A                            are extremely significant.     In addition to the direct benefits to
             r!liableodomestic energy supply is a key factor in maintaining a                             the State and Federal governments from bonus payments, rentals,
             viable f reign policy.                                                                       royalties, and taxes, the discovery of large new reserves would
                                                                                                                                 Oill -imports and the associate' nat'onall trade
             It is in the national security and economic interest to encourage                             eficit. Nearly half of the U.S. trade deficit today results from
             exploration for new domestic reserves wherever the potential                                 imported oil.
             exists, on the Coastal Plain of ANWR and other promising areas.
             Any decision to ddlay that search is a step toward increased                                 Oil development on the North Slope of Alaska has provided hundreds
             dependency on foreign supply.       Lead times to develop frontier                           of billions of dollars to the U.S. economy, representing a benefit
             Alaska oilfields are very long, typically 10 to 15 years from                                to all of the 50 states.       Therefore, petroleum development from
             discovery to first production. If a major discovery were made an                             the Coastal Plain, especially on the order of magnitude of Kuparuk
             the Coastal Plain today, first production would not be likely                                or Prudhoe Bay, would promote economic development not only within
             before the year 2000.                                                                        Alaska, but also throughout the United States.           Jobs would be
                                                                                                          created as the demand for goods and services increase and the
             increasing consumption, decreasing domestic production, and rising                           positive impacts would be felt well beyond the petroleum industry.
             imports, coupled with delay in opening promising new areas to
             exploration and development are all factors which collectively                               If highly prospective areas such as the Coastal Plain are placed
             will contribute to the likelihood of a future energy crisis.         1966                    off limits to petroleum exploration, the nation may experience a
             was a year of drastic change throughout the oil and gas industry.                            future energy crisis which will make the 1973 embargo and the
             Exploration is currently at a near standstill, marginal and                                  1979-1980 price escalation seem mild by comparison.
             uneconomic fields are being shut-in, and research and development
             have been drastically reduced.        Continuity of exploration and                          In summary, we believe it is clearly in the national interest to
             development are necessary to replace depleted reserves. Delays in                            open the Coastal Plain of ANWR to leasing and development.
             the exploration process today will cause greatly reduced future
             production.                                                                                  I will now turn the microphone to Mark McDermott with ARCO who
                                                                                                          will comment 'on the biological aspects of the draft report.
             Those who oppose oil resource development argue that the reserve
             potential of the Coastal Plain may represent only 'a few months
             supply of oil to the nation. This statement, though misleading,
             illustrates very well the significance of such a reserve if it is
             discovered and produced from the Coastal Plain. A few months is

                                                 -2-                                                                                          -3-

                                 Biological Review Comments                                         occur* assessment of impacts. The standard for the "most likely
                                                                                                    to occur* case exists in the experience from other North Slope
           My name is Mark McDermott and I am a senior Environmental                                oilfields. Many of these specific points will be detailed in our
           Coordinator for ARCO Alaska, Inc. Following a detailed review of                         written comments.
           the LEIS Chapter II - Existing Environment and Chapter VI -
           Environmental Consequences, the Alaska Oil and Gas Association                           Caribou
           strongly endorses the Dor recommendation to lease the entire
           *1002" Coastal Plain area for oil and gas exploration, development                       We agree that caribou, both from a standpoint of numbers and
           and production based on the following points and conclusions:                            distribution, is the specie most likely to encounter developmental
                                                                                                    activities in the "1002" area. The LEIS quote from page 6 states
           Prudhoe Bay Region/TAPS                                                                  that *Changes could include displacement and reduction in the size
                                                                                                    of the Porcupfn-eCaribou Herd.     The amount of reduction and its
           often the National Environmental Policy Act (NEPA)-mandated EIS                          long-term significance for herd viability is hi h               lative"
                                                                                                    (empfiasis added).   We ask that these acknowle   9   ly-
           process tries to predict environmental consequences of new                                                                                d H quffMcations
           developments with little or no previous field experience to guide                        be presented throughout the environmental consequences section to
           the predictions. Clearly, for the ANWR Coastal Plain, test cases                         ensure that all readers of the document are fully aware of the
           have already been run at Prudhoe Day, Kuparuk, Milne Point,                              highly speculative nature of some of the hypothesized impacts.
           Lisburne, and Endicott, and with the Trans Alaska Pipeline.
           Collectively, the experience of the regulatory agencies and                              Carrying Capacity
           industry is summarized in the LEIS on page 2s          "The evidence
           generated during the 18 years of exploration and development at                          In the management of wildlife populations, the concept of habitat
           Prudhoe Bay indicates minimal impact on wildlife resources.                              carrying capacity is key to defining management goals.       It is an
           Hence, it is reasonable to assume that development can proceed on                        established fact that the Porcupine Herd does not approach the
           the Coastal Plain and generate similar minimal effects."                                 carrying capacity of its range. Indeed, former Alaska Fish & Game
                                                                                                    Commissioner, R. Skoog, in his Doctoral dissertation 11968) stated
           Furthermore, we support the statement, also on page 2 of    the LEIS,                    that *It seems likely that the Alaskan caribou population has
           that "Most adverse effects would be minimized or eliminated                              remained far below range carrying capacity and that the total
           through carefully applied mitigation, using the lessons learned                          habitat has never been fully occupied.          In reality, caribou
           and technology acquired from development at other North Slope                            populations seem to have maintained densities much lower than the
           oilfields and from the construction and operation of the Trans-                          maximum dictated by food alone, and hence the reduction in total
           Alaska Pipeline System (TAPS)'.                                                          range becomes less' meaningful." Thus, we agree with the conclu-
                                                                                                    sions that habitat is not currently limiting- the growth of the
           Indeed, we would like to point out that all of the dire predic-                          Porcupine Herd and that the small loss of habitat i represented by
           tions of environmental degradation made 15 years ago, prior to the                       likely development in the "1002" area will not impact growth or
           construction of TAPS, have subsequently been proven to be un-                            productivity of caribou.      Consequently, we disagree with the
           founded. The predicted demise of major caribou herds, deteriora-                         speculation that a reduction of caribou population is likely to
           tion in water quality and major losses of habitat simply have not                        occur as a result of small reductions in habitat availability and
           occurred.   instead, the development of Prudhoe Say and the TAPS                         value.
           have allowed Alaskans to enjoy economic prosperity in harmony with
           a high quality environment and thriving wildlife populations.                            "Core Calving Area* Concept

           National Environmental Policy Act                                                        Significant year-to-year variability in calving distribution has
                                                                                                    been recorded for the Porcupine Herd all across the Arctic coast
           We understand that the draft document is a legislative EIS largely                       from east into Canada and west to the Canning River. Concentrated
           following the requirements of the National Environmental Policy                          calving has been observed across the entire so-called core calving
           Act. We would like to point out that many of the environmental                           area during only 5 of the past 14 years.          Therefore, calving
           consequences predicted to occur for the 5 alternatives appear to                         habitat is more appropriately represented an a true continuum
           be based on "worst case" evaluations. in April 1986 the NEPA-EIS                         across the Coastal Plain. including portions of the Arctic coast
           guidelines were changed from requiring a "worst case" assessment                         outside the "2002' study area.      The Porcupine Caribou Herd has
           to one of "most likely to occur.' We feel that many of the major                         demonstrated numerous times in the past, including this past year,
           conclusions of significant effects carry the earlierl"worst case*                        that it can and will successfully calve miles from the (quote)
           assessment to an extreme and thus we ask that the authors re-                            *core calving area' (unquote).     Thus, the "unique and irreplace-
           consider many of their conclusions in light of the "most likely to                       able' nature required for designation an Resource Category 1 does
                                                                                                    not apply.

            While AOGA embraces the responsible use of mitigation procedures                                the Contiguous states costs thousands of dollars and requires an
            in the Arctic, it is inappropriate to emphasize habitat loss alone                              air charter flight to reach the Coastal Plain.           Wet and moist
            without consideration of actual effects or lack of effects on                                   ground conditions make hiking difficult during the 8-10 week
            wildlife populations from development.                                                           summer." Extreme cold and darkness during most of the year
                                                                                                            further reduce recreational use of the Coastal Plain. For most of
            Muskox                                                                                          the year this is an extremely harsh and     hostile environment.
            we feel that the conclusions regarding potential impacts of                                     While there is no reason to believe thit leasing and development
            development on muskox are unnecessarily severe and unfounded.                                   would lead to a permanent 1099 of aesthetic values,       over 30 miles
            While it is true that very few data characterizing muskox res-                                  of Coastal Plain from the "1002* area east to the Canadian border
            ponses to oil field development are available, it is also true                                  pare already classified as wilderness, thus preserving the com-
            that the muskox have shown ready adaptability to human presence                                  lete spectrum of arctic ecosystems represented in the Arctic
            and have even been semi-domesticated in several areas.               This                       Refuge.
            adaptability to human presence will significantly reduce the                                    Summary
            "worst-case" conclusions stated in the LEIS.
            Mammalian Species                                                                               Before I ask Mr. Cook to conclude our statement, I would like to
                                                                                                            acknowledge the 5 years of extensive field investigations, data
            We feel that it     is important to point out that the remaining                                collections and analyses by over 50 trained professional scien-
            mammalian species   including moose, dell sheep, wolves, arctic fox,                            tists, including wildlife and fishery biologists, botanists,
            wolverines and brown bears are present on the Coastal Plain in                                  zoologists, chemists, geologists and resource specialists who
            relatively low population densities or for relatively short                                     contributed to this draft report. We consider the factual basis
            periods during the year.       Thus, we support the conclusions of                              for the scientific analysis to be adequate and the conclusions to
            minimal or negligible impacts on these species.                                                 be reasoned.   However, we cannot support some of the speculation
                                                                                                            on environmental consequences found in the report which result in
            Fishery Populations                                                                             an over estimation of potential impacts.
            We support the conclusion that only minor to negligible effects on                              Concluding Remarks
            coastal fishery resources or fishery habitat will occur. Experi-
            ence at Prudhoe Say and Endicott has provided a significant volume                              As. previously stated AOGA supports the full leasing of the ANWR
            of data to support this judgment.                                                               Coastal Plain under reasonable measures for environmental pro-
                                                                                                            tection.  Except for a few provisions, the proposed stipulations
            Threatened and Endangered Species                                                               found in the report and the land use stipulations found in the
                                                                                                            Agreement Between the Arctic Slope Regional Corporation and the
            We also support the conclusions of minor to negligible impacts on                               United States of America (incorporated into the report by refer-
            endangered and threatened animal species such as bowhead and grey                               ence), appear reasonable.     The proposed mitigation measures       are
            whales and the peregrine falcon.         We  feel that the transient                            generally consistent with current and proven industry practices
            nature of their presence on the Coastal      Plain and the,history of                           for the protection of wildlife and the environment. The applica-
            developmental interaction in the Prudhoe Bay field clearly demon-                               tion of reasonable mitigation can ensure that development is
            strate the lack of meaningful impacts on     these species. Regarding                           conducted in a manner compatible with the burposes of the Refuge
            the plant Thlaspi arcticum, we feel that conclusions and set-back                               and ensure that no unnecessary adverse environmental impacts
                      I                                                        overly                       occur. Our written comments will address in detail, those mea-
            stipulations based on the presence of this specie are                                           sures that we believe are unduly restrictive.
            restrictive because the plant has not been determined             to be
            threatened or endangered.                                                                       AOGA strongly endorses Alternative A, full leasing of thei:10:2:
                                                                                                            study area, as the most acceptable alternative consistent v h h
            Recreation                                                                                      national interest. Alternative B, partial leasing, is'based on a
            we would like to underscore the extraordinarily low use of the                                  speculative premise that a traditional core calving area exists
            Coastal Plain as a recreational area. History indicates that only                               and is necessary for the maintenance of a healthy caribou herd.
            a small number of individuals have actually utilized the Coastal                                This has not been demonstrated in the scientific literature and
            Plain for recreation in the form of hunting, fishing. camping or                                there is a large body of data which indicates otherwise. Alter-
            hiking.   It is extremely expensive to reach the area; a trip from                              native C makes no positive contribution.        Surface and regional
                                                                                                            geologic information already confirm that the area has oil poten-
                                                                                                            tial. The amount can only be verified by on-structure drilling.

                                                                                                                                               -7-

            Stratigraphic type drilling is an unnecessary duplication and its
            surface impact would be in addition to that eventually required
            for on-structure wells. Also, Alternative C would just be another
            delay in the eventual production from the area. Neither Alterna-
            tives D, no action, nor E, wilderness designation, would determine
            whether or not substantial petroleum reserves exist in the "1002,
            study area.   Alternatives D and E preclude reasoned planning and
            would deny the nation the positive benefits that could come from
            oil and gas production on the Coastal Plain.

            We fully support the proposed recommendation on page 169 which
            contains the following statement:      "even though the billions of
            barrels of oil reserves have been brought on line and the infra-
            structure developed to bring that oil to U.S. markets, the fish
            and wildlife resources of the Prudhoe Bay area remain extremely
            healthy.  The Central Arctic Caribou Herd has increased substan-
            tially during the period that development has occurred within the
            heart of its range. Estimated at about 3,000 animals in 1972, the
            herd now numbers more than 13,000. Similarly, important waterfowl
            species continue to successfully nest and rear their brood within
            the developed area. Although circumstances within the "1002" area
            may be somewhat different, the evidence derived from the Prudhoe
            Bay experience leads one to be quite optimistic about the ability
           -to explore for and develop the hydrocarbon potential of the "1002"
            area without significant deleterious effects on the unit's wild-
            life resources.*

            Thank you for this opportunity to comment.

            NS3:377

                                          TESTIMONY ON THE
                        DRAFT LEGISLATION ENVIRONMENTAL IMPACT STATEMENT                                     PRODUCTION FROM EXISTING ARCTIC ALASKA OIL FIELDS WHICH ARE
                             "ARCTIC NATIONAL WILDLIFF REF  .UGE, ALASKA,                                    PRESENTLY BEING PRODUCED AT ABOUT 1.8 MILLION BARRELS PER DAY WILL
                                COASTAL PLAIN RESOURCE ASSESSMENT"                                           BEGIN A PRECIPITOUS DECLINE BY 1988.      IT 'IS A MATTER OF TECHNICAL
                                          WASHINGTON, D.C.                                                   CERTAINTY THAT THE PRESENT LEVEL OF PRODUCTION FROM ALASKA's NORTH
                     PRESENTED BY THE ALASKA OIL AND GAS ASSOCIATION (AOGA)                                  SLOPE'WILL DECLINE TO ABOUT 500,000 BARRELS PER DAY BY THE YEAR
                                           JANUARY 9, 1987                                                   2000, EARLIEST DATE BY WHICH NEW PRODUCTION FROM THE ANWR COASTAL
                                                                                                             PLAIN WOULD LIKELY BE AVAILABLE.

             I AM WAYNE SMITH, DISTRICT MANAGER OF Amoco PRODUCTION COMPANY AND
             PRESIDENT OF THE ALASKA OIL AND GAS ASSOCIATION (AOGA).             I AM                        IF 'HIGHLY PROSPECTIVE AREAS SUCH AS THE     COASTAL PLAIN ARE PLACED
                                                                                                                                                         %"NATION MAY EXPERIENCE A
             APPEARING BEFORE YOU TODAY ON BEHALF OF AOGA WHICH IS A TRADE                                   OFF LIMITS TO PETROLEUM EXPLORATION, THE
             ASSOCIATION WHOSE MEMBER COMPANIES ACCOUNT FOR THE MAJORITY OF OIL                              FUTURE E14ERGY CRISIS WHICH WILL MAKE THE 1973 EMBARGO AND THE
             AND GAS EXPLORATION, VRODUCTION AND TRANSPORTATION ACTIVITIES IN                                1979-1980 PRICE ESCALATION SEEM MILD BY COMPARISON.

             ALASKA.   AOGA STRONGLY SUPPORTS THE DEPARTMENT OF THE !NTERIOROS
             PROPOSED RECOMMENDATION   .THAT THE ENTIRE 01002" AREA, ALSO KNOWN AS                           INCREASING CONSUMPTION AND RISING IMPORTS ALONG WITH DECREASING
             THE COASTAL PLAIN OF THE ARCTIC NATIONAL WILDLIFE REFUGE (A        .NWR),                       DOMESTIC RESERVES AND PRODUCTIONo COUPLED WITH DELAY IN OPENING
                                                                                                             PROMISING NEW AREAS TO EXPLORATION AND DEVELOPMENT# ARE ALL
             BE AUTHORIZED FOR OIL AND GAS LEASING, EXPLORATION AND PRODUCTION.
                                                                                                             FACTORS WHICH COLLECTIVELY WILL CONTRIBUTE TO THE LIKELIHOOD OF A
             CURRENTLY, ALASKA SUPPLIES OUR NATION WITH APPROXIMATELY 20% OF                                 FIUTURE ENERGY CRISIS.

             ITS TOTAL DOMESTIC PRODUCTION.      LEAD TIMES ARE LONG IN FRONTIER
             ALASKA REGIONS--AT LEAST 10 YEARS FROM DISCOVERY TO FIRST PRO-                                  THE RESOURCE ASSESSMENT CONTAINED IN THE DRAFT LEIS FOR THE
             DUCTIONj BUT MORE LIKELY TO EXTEND AS LONG AS 15 YEARS IN THE CASE                              COASTAL PLAIN SUPPORTS OUR VIEW THAT         ITHE AREA MAY C014TAIN
             OF THE ANWR COASTAL PLAIN.      WITHOUT SIGNIFICANT NEW DISCOVERIES,                            SIGNIFICANT RESERVES.    THE COASTAL PLAIN HAS GREAT POTENTIAL FOR
                                                                                                             MAK!NG A SUBSTANTIAL CONTRIBUTION TO OUR DOMESTIC ENERGY SUPPLY.
             OUR NATION COULD BE DEPENDENT UPON FOREIGN SOURCES FOR 60-75% OF

             ITS PETROLEUM NEEDS WITHIN THE NEXT 10-15 YEARS, ALMOST DOUBLE THE

             PRESENT LEVEL OF DEPENDENCY.

                                                                                                                                                -2-

            EVEN THE MOST     OPTIMISTIC PRODUCTION SCENARIO WILL PHYSICALLY                               WITH REGARD TO THE ISSUE OF PROTECTING THE PORCUPINE CARIBOU HERD
            UTILIZE ONLY A    VERY SMALL AREA OF THE COASTAL PLAIN.         THE VERY                       WHICH USES THE COASTAL PLAIN ON A SEASONAL BASIS, THERE HAS BEEN A
            SMALL AREA WHICH WOULD BE AFFECTED BY DISCOVERY AND DEVELOPMENT OF                             DEVELOPMENT SINCE THE ISSUANCE OF THE DRAFT REPORT WHICH I WOULD
            I OR 2 GIANT OIL FIELDS SHOULD BE BALANCED AGAINST THE VERY STRONG                             LIKE TO MENTION.      ON DECEMBER 3, 1986, THE UNITED STATES AND
            CONTRIBUTION TO THE NATIONAL INTEREST THAT SUCH DISCOVERIES COULD                              CANADA HAVE DEVISED AN AGREEMENT FOR THE MANAGEMENT AND CONSERVA-
            REPRESENT.                                                                                     TION OF THE PORCUPINE CARIBOU HERD.         THIS AGREEMENT WHICH ALSO

                                                                                                           INVOLVED THE NATIVE SUBSISTENCE USERS OF BOTH THE CANADIAN AND
            OUR INDUSTRY HAS DEMONSTRATED ITS COMPATIBILITY TO EXPLORE            FORs                     AMERICAN ARCTIC ASSURES THAT APPROPRIATE STEPS WILL BE TAKEN TO
            DEVELOP, AND PRODUCE OIL IN THE ALASKA ARCTIC WITHOUT SIGNIFICANT                              GUARANTEE THE WELL-BEING AND PRESERVATION OF THE PORCUPINE CARIBOU
            ADVERSE IMPACT ON WILDLIFE AND THE ENVIRONMENT.        THE DIRE PREDIC-                        HERD.   IN VIEW OF THIS DEVELOPMENT, THE FINAL REPORT TO BE SUB-
            TIONS OF ENVIRONMENTAL DEGRADATION AND HARM TO WILDLIFE MADE 15                                MITTED TO THE CON    GRESS SHOULD BE REVISED TO REFLECT THIS NEW
            YEARS AGO, PRIOR TO THE DEVELOPMENT OF THE GIANT PRUDHOE BAY FIELD                             MEASURE OF PROTECTION AFFORDED THE PORCUPINE CARIBOU HERD.
            AND THE CONSTRUCTION OF THE TRANS-ALASKA PIPELINE HAVE PROVEN TO
            BE UNFOUNDED.     THE PREDICTED DEMISE OF MAJOR CARIBOU HERDS,                                 I WOULD LIKE TO ACKNOWLEDGE THE 5 YEARS OF EXTENSIVE FIELD
            DETERIORATION IN WATER QUALITY AND MAJOR LOSSES OF HABITAT SIMPLY                              INVESTIGATIONSo DATA COLLECTIONS AND ANALYSES BY OVER 50 TRAINED
            HAVE NOT OCCURRED.                                                                             PROFESSIONAL SCIENTISTS, INCLUDING WILDLIFE AND FISHERY BIOLO-

                                                                                                           GISTS, BOTANISTSo ZOOLOGISTS, CHEMISTSo GEOLOGISTS AND RESOURCE
            INSTEAD, THE DEVELOPMENT OF PRUDHOE BAY AND THE TRANs-ALASKA                                   SPECiALIST .S WHO CONTRIBUTED TO THIS DRAFT REPORT. WE CONSIDER THE
            PIPELINE HAVE PERMITTED THE PRODUCTION OF 5 BILLION BARRELS OF                                 FACTUAL BASIS FOR THE SCIENTIFIC ANALYSIS TO BE ADEQUATE AND THE
            MUCH NEEDED OIL WITH MINIMAL ENVIRONMENTAL IMPACT,         DURING THE 15                       CONCLUSIONS TO BE REASONED.       HOWEVER, WE CANNOT SUPPORT SOME OF
            YEAR PERIOD OF DEVELOPMENT WILDLIFE HAVE THRIVED IN THE MIDST OF                               THE SPECULATION ON ENVIRONMENTAL CONSEQUENCES FOUND IN THE REPORT
            OIL FIELD DEVELOPMENT AND EVIDENCED BY THE FACT THAT THE CENTRAL                               WHICH RESULT IN AN OVER ESTIMATION OF POTENTIAL IMPACTS.
            ARCTIC CARIBOU HERD HAS GROWN FROM ABOUT 3,000 TO A POPULATION NOW
            ESTIMATED AT OVER 13.000 ANIMALS.                                                              EXCEPT FOR A FEW PROVISIONSo THE PROPOSED STIPULATIONS FOUND IN

                                                                                                           THE REPORT AND THE LAND USE STIPULATIONS FOUND IN THE AGREEMENT

                                                                                                           BETWEEN THE ARCTIC SLOPE REGIONAL CORPORATION AND THE UNITED

                                                                                                           STATES OF AMERICA (INCORPORATED INTO THE REPORT BY REFERENCE),

                                                 -3-                                                                                            -4-

              APPEAR REASONABLE. THE PROPOSED MITIGATION MEASURES ARE GENERALLY

              CONSISTENT WITH CURRENT AND PROVEN INDUSTRY PRACTICES FOR THE                                 AOGA'S EXPRESSES     ITS FULL SUPPORT OF THE DEPARTMENT OF THE
              'PROTECTION OF WILDLIFE AND THE ENVIRONMENT.        THE APPLICATION OF                        INTERIOR'S   PROPOSED    RECOMMENDATION    TO  CQNGRESS    WHICH    STATES
              REASONABLE MITIGATION CAN ENSURE THAT DEVELOPMENT IS CONDUCTED IN                             "...EVEN THOUGH THE MILLIONS OF BARRELS OF OIL RESOURCES HAVE BEEN
              A MANNER COMPATIBLE WITH THE PURPOSES OF THE REFUGE AND ENSURE                                BROUGHT ON LINE AND THE INFRASTRUCTURE DEVELOPED TO BRING THAT OIL
              THAT NO UNNECESSARY ADVERSE ENVIRONMENTAL IMPACTS OCCUR.              OUR                     TO U.S. MARKETS, THE FISH AND WILDLIFE RESOURCES OF THE PRUDHOE
              WRITTEN COMMENTS WILL ADDRESS IN DETAIL, THOSE MEASURES THAT WE                               BAY AREA REMAIN EXTREMELY HEALTHY.         THE CE14TRAL ARCTIC CARIBOU
              BELIEVE ARE UNDULY RESTRICTIVE.                                                               HERD 14AS INCREASED SUBSTANTIALLY DURING THE PERIOD THAT DEVELOP-

                                                                                                            MENT HAS OCCURRED WITHIN THE HEART OF ITS RANGE.            ESTIMATED AT
              AOGA STRONGLY ENDORSES ALTERNATIVE A, FULL LEASING OF THE 11100211                            ABOUT 3,000 ANIMALS IN 1972, THE HERD NOW NUMBERS MORE THAN
              STUDY AREA, AS THE MOST ACCEPTABLE ALTERNATIVE CO"S.ISTENT WITH THE                           13,000.    SIMILARLY,    IMPORTANT WATERFOWL      SPECIES   CONTINUE    TO
              NATIONAL INTEREST.  f ALTERNATIVE B, PARTIAL LEASINGs     IS BASED ON A                       SUCCESSFULLY NEST AND REAR THEIR BROOD WITHIN THE DEVELOPED AREA.
        9     SPECULATIVE PREMIS  E THAT A TRADITIONAL CORE CALVING AREA EXISTS
                                                                                                            ALTHOUGH CIRCUMSTANCES WITHIN THE "1002" AREA MAY BE SOMEWHAT
              AND IS NECESSAR  IY FOR THE MAINTENANCE OF. A HEALTHY CARIBOU HERD.                           DIFFERENT, THE EVIDENCE DERIVED FROM THE, PRUDHOE BAY EXPERIENCE'
              THIS HAS NOT BEEN DEMONSTRATED IN THE SCIENTI       FIC LITERATURE AND                        LEADS ONE TO BE QUITE OPTIMISTIC ABOUT THE ABILITY TO EXPLORE FOR
              THERE IS A LARGE BODY OF DATA WHICH INDICATES OTHERWISE.           ALTER-                     AND DEVELOP THE HYDROCARBON POTENTIAL OF THE "1002" AREA WITHOUT
              NATIVE C MAKES NO POSITIVE CONTRIBUTION.         SURFACE AND REGIONAL                         SIGNIFICANT DELETER-1 OU_S- EFFECTS ON THE UNIT'S WILDLIFE RESOURCES".

              GEOLOGIC INFORMATION ALREADY CONFIRM THAT THE AREA HAS OIL POTEN-
              TIAL.  THEAMOUNT CAN ONLY BE VERIFIED BY ON-STRUCTURE DRILLING.                               THANK YOU FOR THE OPPORTUNITY TO PRESENT THIS STATEMENT.
              STRATIGRAPHIC TYPE DRILLING IS AN UNNECESSARY DUPLICATION AND ITS

              SURFACE IMPACT WOULD BE IN ADDITION TO THAT EVENTUALLY REQUIRED                               NS3:366
              FOR ON-STRUCTURE WELLS. ALSO, ALTERNATIVE C WOULD JUST BE ANOTHER

              DELAY IN THE EVENTUAL PRODUCTION FROM THE AREA.       NEITHER ALTERNA-

              TIVES D, NO ACTION, NOR E, WILDERNESS DESIGNATION, WOULD DETERMINE

              WHETHER OR NOT SUBSTANTIAL PETROLEUM RESERVES EXIST IN THE 010020

              STUDY AREA.   ALTERNATIVES D AND E PRECLUDE REASONED PLANNING AND

              WOULD DENY THE NATION THE POSITIVE BENEFITS THAT COULD COME FROM
              OIL AND GAS PRODUCTION ON THE COASTAL PLAIN.
                                                  -5-                                                                                            -6-

    		White PAPTER REPORT
    		TO THE SECRETARY OF
    	THE U.S. DEPARTMENT OF THE INTERIOR
    		ON THE
    	ARCTIC NATIONAL WILDLIFE REFUGE

    	(16 U.S.C.3142)

    	Submitted by

    	Alaska State District
    	Council of Laborers

    		WHITE PAPER REPORT

    At the request of the U.S. Senate Committee on Energy and Natural
    Resources, the Department of Interior has commenced a resource analysis and
    assessment for the Arctic National Wildlife Refuge in northeast Alaska.
    Upon full compilation of the information available on the impact proposed
    oil activity will have on Alaska's many resources, the Department of
    Interior will then, in turn, report to Congress and, ultimately, the nation
    on the interest at stake. It is the purpose of this White paper to assure
    full attention to the Alaskan human resources of affected Alaskan workers
    as a vital interest to be judiciously considered.

    To date, the U.S. Department of interior's course of study has largely
    consisted of its assessment of geophysical, environmental, and geological
    surveys undertaken by teh Fish and Wildlife Service and U.S. Geological
    Survey. study of the human resource component should be expanded to fully
    meet the assessment mandated by congress. The interests of Alaskan workers
    must be recongnized and considered in this natioanl debate.

    A growing trend has resulted in Alaskan workers being bypassed by the oil
    industry currently operating in the state of Alaska. Studies indicate that
    significant unemployment results in Alaska as its workers are displaced by
    a nonresident work force in the industry. And as indicated by the below
    data, unemployment levels in Alaska are among the highest in the nation.

    	WHITE PAPER REPORT
    	PAGE 2

    		TABLE I
    	1984 ALASKA UNEMPLOYMENT RATE
       	TOTAL		CONSTRUCTION	MANUFACTURING
    ALASKA  12.4%	23.8%				16.9%
    (Rank natinaly 2nd 1st				1st

    Displacemnt of Alaskan workers in the oil industry by foreign
    natinales., and nonresidents.2 is a particulalry troublesome social
    problem in ALasaka. This stems, no doubt, from the related effects of
    unempolyment on the Alaskan communities.3 but also on the loss of "benefit"
    while bearing the "cost" of the industry's activities. Accordingly, any
    cost benefit analysis should astutely acount for this shortcoming.

    Operations by teh petroleum industry in the Arctic National Wildlife Refuge
    pose similar and substancial displacement of Alaskan workers. A balanced
    assessment of the critical question of opening this wilderness refuge to
    oil industry activities must recognize.4 the significant failure of the
    industry in Alaska to promote the "human resource" the interstate of Alaskan
    workers-- posed by undertaking this project at this time.

    	*1. See memorandum Investigation of steelhead project, State of Alaska,
    1986, regarding employment of foreign national workers. Also Beaufort
    Sea operations performed by predominantly Candian work force in
    Alaskan oil fields.

     	*2 See 67% nonresident 17% Alaskan resident employment ratio. as
    attached, for haliburton corporation, a large North Slope oil industry
    employer.

    	*3 SEE a special study to measure the Economic Impact of nonresidents on
    Alaska's Economy. (DOL 1984), Governor B. Sheffield; and attached news
    articles for graphic insight.

    	*4 Due recognition of local employment concerns is contemolated by

               A
               5otA*,Nnmber of E@nployees:
               Number o?      Residents:       19                        Nuzber   of Ron-Reside
                                                                                                   nts:    67"'
               Total Wages paid to      Resid  'ents:S725,b2C.72*        Total Wagej3    paid to   lion-Residents: $2.556,7@
               Relationship -.Residents, 22                              Ran 78-                                                                    MUTE PAPER PEPORT
                                                                                                                                                    Page 3
               N=ber*K&le Workers:                          Z
                                                            :-             Number.of. FL=ale       Vorkers,
                      Residents:              17                                         ..,Reqideats:_'   2
                      Non-Residents:        _6T                                          Non-Residents:    -0-                                      The Alaska State District Council of                  Laborers has represented Alaskan
               Classifications    use d-.               Wa  e Pate                       -Vork Beheduie-                                            workers for decades before Alaska statehood or the entry of the oil
               Specialist-    (1)                           FlOthour
                                                        f,                                         I onr3 v@eks oif
               SDeci&list     -(2)                                                                                                                  industry to the state of Alaska. Adequate resolution of potential conflict
               .Specialist    (1)                       $11.53/hour                                                                                 by the oil industry with the people of the state of Alaska                   must be resol ved
               steciaiist     (1)                           1-2-. - @7 -1b o u r
               SiDecialist    @5)
                                                        T13-31/bour'                                                                                RniLr   to any activity being permitted.                        y
               'Sueciplist                              $2@4@.jhaur                      varies                                                                                                         It is onl with this assurance that
               Sueciali3t     (1)                                                        varies                                                     Alaska'l human resource interests vjill be effectively protected.
                                                        $IV-907h-our
               Specialist     -- (I                                                                     --ek..ff
               Sueciali3t                               $10.00/hour                                on/3 veeks off
               snecialist     (3).                      *12-Wbour                        T
               soecialist     (1)                       $13-17/bour
               sDecialist     (1)                       $19.24/bour.                     varies
               .Specialist    (1)                       $ITX6Thour                       varies
               sDecialist     (1)                       MMOTb_our                        3 vee     ! on/3 veeks OfT
                         _S___(                                                          varies
               SDeciali t     -1)                       $1 .1 /hour
               soeciali                                 .512.18/hour                     @vetk'on_TTveeks off
               '5oeciali:; --M                          f1l.74/buf_-
               stecialist                                                                2 veeks        've.). -off
                                                            24.03/houiTi
                                                        $12                              @ @veekz'@on/3 vee@iso
               Stecialist UY                            $29.02/ho-ur'                    vp-ries   -7.
          CA)                                                                                      -0-- T3 -veaks ff
               SDecialist     (1                        $12.22/box=                      3 vW;is_
               svecialist     (1)                       323. 0- -1- r                    2 veek      T2 -ve
                                                               6 hou                                       eks j-.
               sDeciplist     (1)                       $15-50/hour                                --F3 -.eks oif
               sDeciplist     (1)
               sDecialist     (1)                       *16.117h-our
               so-cialist     -(l)                      $10.2 /hour
               Specialist     1)                        .410-5TFbour
                                                               i fho,
               S oeclali st,                            311T.12f urr-
                                                            12                                     --------- 7-7
               Speci&list     (1)                       Z@&R? boui                                 77
               SDecialist                           ;-'-.'-'M.59fhour
               speciells      11                        TLl.V3-/hour
               smcialiBt      1                                                                    __7-7-77 --- 777-
                                                        _=12
                                                        31                               varie;s
                                                            2 5T b r
                                                                                         3 veeks-_
                                                            12.T3/hour                             on73 veek3 off
                                                                                   -i.5 vee-k3
               Specialist:.   1                             2 .03 hq-                              --72 -eeks off"
                                                        $
                                                            b_.Z_37h_o,
                                                            13. 3 hour                   3 veeks   -./3 _vek. off
                                                                  hour
               sDecialist"..- I                             b..JoThour q.;.':
               :,5pecialistV,
                                                            M_q87h_,, r
               S eci li3t@-   I
               Peci&list@,,   1     ... ...
               5                                            13 9 KoUr@!- ,'?
               Speci&list,@L  I
                                                            10. 3 hour!--.
                                                            _2_O_._T_T7h_
                                                                   our             _4
               ..S ecialist;4                    j"
                                                                                                        --,.ek. rf't"
                  cialis                                    3.1 5 houi7,:V@4@Qr           77e
                              t %r;
      :t;X@Pjs cialis
                                                                                                                     z4l.
                                                        11-0.9T/hOui
               Specia ist
                 eciali3Vi..                                   9                  Ai
                                                        T

                                                        $    6 7

                       STATE OF ALASKA
                                                          ss.
                       THIRD JUDICIAL DISTRICT

                                                 AFFIDAVIT OF A. GWENDOLYN JOINER

                                 A. Gwendolyn Joiner, upon being duly sworn, deposes and states:

                                 1. 1 was employed by VECO, Inc. from January 24, 1986 until May 6.

                       1986.

                                 2. .1 was the timekeeper in charge of payroll duties on the night

                       shift.    This work involved payroll duties for 375 to 400 employees including
                       personnel changes in the computer system (names, addresses, dates of birth,

                       emergency phone numbers and other data).

                                 3. At approximately the end of February, 1986, or the first of March,

                       1986, 1 was instructed by my supervisor, Nancy Green, to enter a change of

                       address for certain VECO, Inc. employees who were working on the Kapurak
                       Pipeline Pro@ect.    This group of employees totaled more than 100 and had
                       previous addresses outside of Alaska, primarily in Texas and Louisiana.         In

                       making tne addrass changes, however, the emergency phone nLnbers at the

                       outside of Alaska address were left intact.

                                 4. 1 asked my supervisor, Nancy Green, for the reason "or making the
                       changes.   Nancy Green stated, "The order came from the top." She also

                       directed me to make the changes as soon as possible.       The majority of the

                       addresses were changed to the VECO, Inc. mail pouch number. The remainder
                       were' changed to the Anchorage addresses at that time on record for other VECO,

                       Inc. employees.

                                 Further, affiant sayeth naught.

                                 DATED this /10-day    of August, 1986.

                                                        A. Gwendolyn Uol

                                 SUBSCRIBED AND SWORN to before me this            day of August. 1986.

                                         THE ALASKA WILDLIFE ALLIANCE

                                                     ro. sox 190M
                                                 AN000RAGIL ALMA M19
                                                       907-1774M            January 20, 1987                                         on ice near the 1002 area (1951-85). Another five dens have been located on
                                                                                                                                     ice near the 1002 area. Three locations in the 1002 area have been delineated
                                                                                                                                     as confirmed denning areas. that is areas in which polar bear dens and dennihg
                                                                                                                                     activity have been observed in more than one winter."

                                                                                                                                     The draft study goes on to say. "Polar bears are protected under the provisions
             U.S. Fish and Wildlife Service                                                                                          of the Marine Mammal Protection Act of 1972. An international agreement for
             Attn: Division of Refuge Management                                                                                     the conservation of polar bears was ratified in 1976 by the governments of Canada,
             2343 Main Interior Bldg.                                                                                                Denmark. Norway. The Union of Soviet Socialist Republics, and the United States
             Washington D.C. 20240                                                                                                   of America. Article 11 requires that appropriate actions be taken to protect
                                                                                                                                     ecosystems of which polar bears are a part, especially denning and feeding sites."
             Dear Sir:                                                                                                               We have all heard of the dangers to the Porcupine Caribou herd that development
             I am Ginny De Vries, Staff Representative of the Alaska Wildlife Alliance and                                           poses.   If excluded from their calving area. many caribou may be forced to use
             the following is our testimony.       To begin with. we would like to protest the                                       less suitable areas where they would have difficulty avoiding insects and
             facts that hearings were not held in Fairbanks. (the location of the refuge's                                           predators. Also the porcupine Caribou could use up precious fat reserves which
             administrative headquarters) Arctic Village, and Venitie; and that most working                                         are extremely important for winter survival due to fright reaction and disruption
             people other than oil executives were excluded by the hours of the hearings and                                         caused by development.
             because advance sign up was not offered. We have read the three volume baseline
             study and the draft on the arctic National Wildlife Refuge, Coastal Plain Resource                                      In making the decision on whether to lease this area. it is important to remember
             Assessment and we recommend that the Department of Interior forbid the exploration                                      that of the 1.100 miles of arctic coastline in Alaska. the Arctic National
             and development of oil and gas in the area. The northernmost unit of the National                                       Wildlife Refuge Coastal Plain is the only section of the entire NOrth Slope
             Wildlife refuge System was established to protect a fraction of Alaska's unique                                         currently closed to oil and gas development.         The U.S. Fish and Wildlife Service
             arctic environment. The region encompasses an outstanding arctic and subarctic                                          has 6 higher responsibility to conserve the natural diversity of species on the
             ecosystem harboring all thrge species of North American bears (polar, brown.                                            refuge for all wildlife interest. As the report itself states:              "Long-term
             and black). caribou, wolves. wolverines, Dail's sheep. raptors and abundant                                             losses in fish and wildlife resources, subsistence uses, and wilderness values
             fish life including arctic char and grayling.          Thei:rcteic..re      is the only                                 would be the inevitable consequences of a long term commitment to oil and gas
                               tem In North America. and perhaps           t6     rjge  that p-                                      development. production and transportation."
             conservation   s                                                                   roTe-cEs
             sucK a wide spesc  tum of   the various arctic and subarctic ecosystems in an
             undisturbed condition.                                                                                                  To summarize, the Alaska Wildlife Alliance is opposed to any oil and gas
                                                                                                                                     exploration and development on the Coastal Plain, and supports the designation
             In the few minutes alloted. I would like to point out the effects of development                                        of the Coastal Plain as wilderness.        Thank you for your time.
             on wolf. polar bear. caribou. and whale populations.
             Of wolves, the draft study states (p. 31), "Wolves are found throughout Alaska's                                                                                                        Sincerely,
             North Slope. On the 1002 Area. the population density is lower than in areas                                                                                                                    11 1 _@ 44 illy-f-/
             farther south. "Development in the area would mean roads which would give hunters
             and other user groups access to an already low population.                                                                                                                              Ginny De Vries
             Should development occur. caribou would be adverscly affected which in turn                                                                                                             Staff Representative
             would adversely affect the wolf population. Page 24 of the-baseline study states.
             "Distribution showed that wolves used the ANWR Coastal Plain East of the Aichilik
             River extensively. and this used coincided with the presence of caribou.
             (information is lacking on the use of the Coastal Plain by wolves in late may
             to June.) Minimum population estimates for the study area were 27 adults and
             seven pups in late summer. 1984, not including five known and three suspected
             mortalities." This information suggests that wolves are being removed in the
             1002 area faster than they are reproducing without the presence of roads. Roads,
             increased human population, and additional human activity would drastically add
             to the decrease in wolf population.
             In relation to polar bears. page 33       of the draft study states. "Pregnant polar
             bears, and later their cubs, probably spend more time on the 1002 area than
             other segments of the polar bear population.. At least 15 dens have been locate

                                                                                                                                            Mr. Frank bunkle
                   American Petroleum Institute                                                                                             February 6, 1987
                   1220 L Street Northwest                                                                                                  page 2
                   Washington, D.C- 20005
                   202-682-8170                                                                                                             five basic criteria most occur.                 These include: a source sequence
                                                                                                                                            from which the oil can be derived; A migration path from the
                   S. P. Chamberlain                                                                                                        source to an area of accumulation; a reservqir rock and pore
                   04"..                                                                                                                    space, a trap to hold the oil in one area, and a seal to prevent
                                                                     February 6, 1987                                                       the oil from escaping and migrating to the surface.                           All five
                                                                                                                                            factors must be favorable or the result is no oil. Given the
                                                                                                                                            high degree of uncertainty and the unlikelihood of the existence
                                                                                                                                            of all five factors, the 19.percen,t noted in the LEIS Is an
                                                                                                                                            exceptionally promising prospect.

                   Mr. Frank Dunkle                                                                                                         We urge the Department to make the significance.of this
                   Director                                                                                                                 percentage more understandable in the final report to Congress.
                   U.S. Fish and Wildlife            Service                                                                                Additionally, many of the Individual companies with the expertise
                   U.S. Department of the            Interior                                                                               and technology to operate in the arctic environment are providing
                   Washington, D.C.            20240                                                                                        detailed comments on the LEIS.                 We urge you to carefully review
                                                                                                                                            their comments, as you proceed In fulfilling the mandates of the
                   Dear Mr. Dunkle:                                                                                                         report and recommendations to Congress.

                   The American Petroleum            Institute (API) appreciates the                                                        At a time of escalating heavy U.S. dependence on oil imports.and
                   opportunity to provide            su@plemental comments for the Department's                                             depressed conditions in the domestic petroleum industry, it is
                   consideration on the Draft Legislative Environmental Impact                                                              vital for the United States to increase its domestic energy
                   Statement (LEIS) an the Arctic National Wildlife Refuge tANWR)                                                           production and provide for secure and reliable energy supplies
                   1002 area.        Our written statement, presented at the January 9                                                      for the 1990s and beyond.               That is why the ANWR 1002 area is so
                   he--r-ng, d-scussed the national security and economic benefits                                                          vital to our nation's energy future.                    If we can find and develop
                   that'may rasult from leasing the coastal plain area, as well as                                                          the potentially vast resources of the 1002 area, we can help
                   the compatibility of oil, wildlife and the environment.                              In                                  reduce our future dependence on oil imports and increase the
                   addition to those comments, we wish to clarify the significance                                                          domestic oil and gas available to meet our needs a decade from
                   of the statements on pages 49, 68 and 72 of the LEIS regarding                                                           now and beyond.          We can lessen the threat of the Organization of
                   the estimated 19 percent chance of finding any economically                                                              Petroleum Exporting Countries regaining its dominant control
                   recoverable oil from the 1002 area.                                                                                      over world oil prices and we can lessen the chance of a return to
                                                                                                                                            the severe energy disruptions experienced In the 1970s. It is
                   Petroleum exploration is an extremely high risk activity.                              Even                              important to keep in mind that it takes as much as 10 to 15 years
                   the best data are often misleading, misinterpreted or erroneous.                                                         to explore for and place Into production oil fields from arctic
                   Exploration always carries a higher chance of failure than of                                                            environments.
                   success. However, the one-in-five chance represented by the 19
                   percent calculations of the U.S. Geological Survey and Bureau of                                                         Crude oil from the North Slope's producing oil fields is already
                   Land Management professionals reflects a higher-than-normal                                                              contributing over 20 percent of total U.S. crude oil production.
                   success probability.                                                                                                     The nation's dependence on foreign oil could increase markedly In
                                                                                                                                            the years ahead, as these fields -- along with other fields in
                   Unfortunately, the draft report fails to explain that this                             is a                              the lower-48 states -- reach peak production and start to decline
                   very promising percentage forsuccessfully finding economically                                                           -- as many already have.              One very promising place the United
                   recoverable oil resources, particularly in frontier areas such as                                                        States must turn to is Alaska's undiscoverea oil and gas, If our
                   those covered by the LEIS.               In fact, this is nearly a tenfold                                               future energy security is to be enhanced.                       The petroleum
                   increase in the industry's success rate in Alaska.                           Only one out                                industry's record in developing the producing fields on the
                   of 50, or about 2 percent, of the exploratory wells drilled in                                                           Alaska.North Slope proves that such operations can be and are
                   Alaska has ever resulted in a commercial discovery.                                                                      being conducted in an environmentally sound manner.                           The
                                                                                                                                            technology developed for arctic operations near Prudhoe Bay can
                   Undiscovered resources are not proved reserves and, until                                                                be used within ANWR in the search for the large deposits of crude
                   exploratory drilling occurs, no one c@an say if any producible oil                                                       oilthat may underlie the 1002 area.                     Nearly 20 years of
                   exists.       in order for oil to accumulate in recoverable quantities                                                   experience on the North Slope demonstrates that oil and gas
                                                                                                                                            exploration and development can exist in harmony with the arctic
                                                                                                                                            environment.

                   An eWal opp-" -P$Ww

             Mr. Frank Dunkle
             February 6, 1987
             page 3

             Development of petroleum resources in the 1002 area would result
             in significant economic benefits to Americans throughout the
             nation. For example, extrapolating from the employment and Gross
             National Product (GNP) effects of a recent Battelle/DRI study,
             which looked at the aggregate employment effects of incremental
             peak OCS production of 2.5 million barrels a day of crude oil
             equivalent, the following orders of magnitude are suggested.
             Based on a Department of the Interior peak production estimate of
             659,000 barrels daily (assuming recoverable recerves of 3.2
             billion barrels), the cumulative employment gains could be
             254,085 jobs. Using the same base projection of production, the
             GNP could increase about 0.25 percent above the level that would
             otherwise exist. Finally, significant discoveries within the
             1002 area could help reduce the nation's reliance on oil Imports.
             The 1002 area could thus benefit the economic and national
             :
             ecurity of the United States by helping to reduce oil imports
             nd the flow of American dollars overseas.

             In conclusion, the APT reiterates its support for the proposed
             "alternative A" recomipendation to permit full oil and gas leasing
             in the 1002 area.

                                               Sincerely,

                                               S. P. Chamberlain

                                                                                                    My name is Michael Johnson and I am Manager of Economics &
                                       STATEMENT ON
                                                                                                Planning for North America Exploration for Conoco Inc. based in

                                                                                                Houston, Texas. I am representing the American Petroleum

                              ARCTIC NATIONAL WILDLIFE REFUGE                                   Institute (API) which to a national trade.association

                                                                                                representing the domestic petroleum industry. API's membership

                                                                                                consists of a broad cross section of the Industry's functions,
                                             By
                                                                                                Including exploration, production, transportation, refining and

                                                                                                marketing. API's membership currently includes 215 companies and

                                      MICHAEL JOHNSON                                           about 5,000 Individuals.

                                                                                                    API supports the U.S. Department of the Interior's (DOI)

                                                                                                proposed "Alternative A" recommendation to Congress that the
                                        REPRESENTING
                                AMERICAN PETROLEUM INSTITUTE                                    Arctic National Wildlife Refuge (ANWR) coastal plain be opened to
                                                                                                oil and natural gas leasing. As. DOI's draft report states: "The.

                                                                                                (1002) area is clearly the most outstanding oil and gas frontier
                                         BEFORE THE
                                                                                                remaining in the United States and could contribute substantially

                                                                                                to our domestic energy supplies."
                                 DEPARTMENT OF THE INTERIOR                                         At a time of escalating heavy U.S. dependence on oil imports
                                      JANUARY 9, 1987
                                                                                                and depressed conditions in the domestic petroleum industry, it

                                                                                                is vital for the United States to increase its domestic energy

                                                                                                production and provide for secure and reliable energy supplies

                                                                                                for the 1990s and beyond. We agree with the DOI's draft report

                                                                                                that Alaska's 1002 area provides one of the nation's beat hopes

                                                                                                for the energy supplies needed in the years ahead. But the

                                                                                                area's vast potential will remain untapped unless oil and gas

                                                                                                lea sing is permitted in the area.

                                           -2-

            Why the 1002 Area is Vital to America's Energy Future                                     This means that there Is a significant probability that
                Curren'; U.S. energy supply trends underscore the urgent need                     within a relatively short period -- perhaps as few as three years
            to find and produce the potentially vast oil and gas resources of                     -- the United States and our allies could once again be
                                                                                                  significantly more dependent on the Middle East for our oil
            the 1002 area. Oil prices during 1986 dropped by about one-half.
            As a result, U.S. consumption has risen and domestic production                       supplies. Moreover, when supplies tighten and shortages
            has fallen. These trends have been accelerating. Consumption                          threaten, there is no rapid or easy way to *curtail demand,
            was up 1.2 percent In the first quarter of 1986 over the first                        increase domestic supplies, or find substitutes for many critical
            quarter of 1985, 2.4 percent in the second quarter and 3.8                            uses for oil. Thus, we will become more dependent on foreign oil
            percent in the third quarter. Production was barely down in the                       and extremely vulnerable to any form of disruptio6 of supply from
            first quarter, but fell 2.9 percent In the second quarter and 3.1                     the Middle East or from elsewhere.   it is important to keep in
            percent in the third quarter.                                                         mind that it takes as much as 10 to 15 years to explore for and
                This growing gap between domestic consumption and production                      place into production oil fields from arctic environments.
            has been filled by oil'imports, which were up 23 percent in 1986                          That is why the ANWR 1002 area is so vital to our nation's
       9                                                                                          energy future. If we can find and develop the potentially vast
        L   over the 1985 level. Imports In November constituted 38 percent
       ?0   of U.S. oil consumption -- a higher level of d ependence than at                      resources of the 1002 area, we can sharply reduce our dependence
            the time of the 1973-74 oil embargo.   Furthermore, U.S. imports                      on oil imports and have the domestic oil and gas we need to meet
            from the volatile Persian Gulf area have increased 300 percent In                     our needs a decade from now and beyond. We can lessen the threat
            1986 and accounted for more than half of the total Increase In                        of OPEC regaining its dominant control over world oil prices and
                                                                                                  we can lessen the chance of a return to the severe energy
            imports in 1986.
                if prices remain roughly equal to those of the late fall and                      disruptions experienced in the 1970s.

            early winter of 1986, these current production and consumption
                                                                                                  Resource Potential of the 1002 Area
            trends are likely to continue. If they do, U.S. dependence on
            oil Imports also will continue to rise.   As U.S. and other world                         in its draft report on the 1002 area, DOI estimates that
            demand grows, more and more oil will be Imported from the OPEC                        there may be billions of barrels of crude oil to be found under
                                                                                                  that 1.5 million acre area. DOI estimates that "recoverable
            cartel. Within OPEC, a small group of countries concentrated In

            the Middle East has most of the excess oil production capacity

            which will be called upon as the demand for oil increases.

                                              -4-

            reserves" range from 600 million to 9.2 billion barrels of oil,
                                                                                                                 Moreover, if exploration resulted in no commercially
            while the "in-place resources' range from 4.8 billion to 29.4
                                                                                                            producible discoveries, disturbance of the area by petroleum
            billion barrels. '  Recoverable reserves are estimates of                                       activities would cease and restoration measures would begin.            if
            economically producible reserves using today's technol      ogy;                                economically significant oil and gas discoveries were made, the
            in-place resources are estimates of the total amounts of oil                                    occupation of the area would last only as long as those
            thought to be in the reservoirs, some of which will not be
                                                                                                            discoveries were producible, perhaps 20 to 30 years -- a very
            economically producible.                                                                        short time In man's historical use of the area.
                Although there is uncertainty inherent In all oil and gas
                                                                                                                The petroleum.industry's record In developing the producing
            exploration methods which do not include actual drilling, the
                                                                                                            fields on the Alaska North Slope proves that such operations can
            Interior Department estimates Indicate a very large crude oil
                                                                                                            be and are being conducted In an environmentally sound manner.
            potential -- on the same order of magnitude as the nearby Prudhoe                               The technology developed for arctic operations near Prudhoe Bay
            Say field, the largest U.S.    .discovery to date.                                                 the area of the nation's largest      oil and gas fields -- can be
              .,crude oil from the North Slope's producing       oil fields is                              used within ANWR in the search for the large deposits of crude
      9     already contributing about 20 percent of U.S- crude oil
                                                                                                            oil that may underlie the 1002 area.
            production. The nation's dependence on foreign oil could                                            Numerous laws and regulations assure that oil and gas
            incre@ase markedly in the years ahead, as these fields -- along
                                                                                                            activities are designed to protect the surrounding environment.
            with 'older fields in the lower-48 states -- reach peak production
                                                                                                            Experience in Alaska and the lower 48 states shows that oil and
            and start to decline -- as many already have. one very promising
                                                                                                            gas activities are consistent with other goals such as wildlife
            place4the United States must turn to is Alaska's undiscovered oil
                                                                                                            protection. Nearly 20 years of experience on the North Slope
            and gas if our future energy security is to be enhanced..                                       demonstrates that oil and gas exploration and development can

                                                                                                            exist In harmony with the arctic environment. Techniques to
            Oil-and.,.Gas Operations In the 1002 Area                                                       minimize disturbance Include directional drilling, smaller and
                Only a.sma.1 II portion of the.1002 area would actually be                                  consolidated facilities, winter construction, use of temporary
            disturbed during exploration and production activities          Based on                        ice roads, use of special arctic equipment, and elevated
            experience.at nearby Prudhoe Bay, less than I percent of the                                    pipelines and facilities.      The U.S. Fish and Wildlife Service
            surface of  the. 1002 area  could be expected to be affected by                                 (USFWS) monitored all of     the surface activities and geophysical
            drilling  aqd,production pads, roads and facilities.

                                             -6-                                                                                        -7-

            operations conducted on the coastal pl3in and reported that no                            would not hurt the Porcupine caribou herd.      The 1002 area Is only
            significant environmental impact resulted from that activity.                             a portion of the calving grounds of the Porcupine herd.       Even
                Oil from the 1002 area would be transported by onshore                                discovery of a supergiant field would only involve a small
            pipeline to the Trans-Alaska Pipeline System (TAPS).      Experience                      portion of the area.    In some years, little or no calving occurs
            from TAPS and the Prudhoe Bay, Milne Point and Kuparuk                                    In the 1002 area, but takes place In the foothills to the south
            developments proves that pipelines can be designed, constructed                           and/or in Canada.
            and operated on the North Slope to allow passage of caribou and                               Oil and gas operations would also be compatible with other
            other wildlife.                                                                           wildlife and environmental aspects of the 1002 area:
                Exploration  activities would also be supported by temporary                              o   Muskoxen were Introduced into ANWR only 17 years ago and
            Ice roads, barges and Ice airstrips.    During development and                                    are still expanding their range.    As of 1984, there were
            production, more permanent gravel pads, roads and airstrips would                                 384 muskoxen in ANWR. Muskoxen spend most of their time
            be used to support year-round activities. One main road along a                                   In the foothills and water-adjacent, habitat, a* little
            pipeline into ANWR woUld be needed for pipeline service and                                       contact with oil and gas facilities would be likely.
      9
        L   resupply.  Roads and facilities would be placed In the most                                   o   A 1986 joint industry/state/federal bird impact study
            efficient manner possible and concurrence would be required     from                              Indicates that the development at Prudhoe Say has not
            the USFWS and the Alaska Department of Pish and Game.                                             affected the general use of the area by birds. While some
                Sensitive habitats are routinely avoided when routing roads                                   habitat lose resulted from the placement of facilities,
            on the North Slope. Some construction activities can be                                           certain species created new habitats at roadsides and
            conducted during the winter season when most wildlife Is absent                                   pads.
            from the 1002 area.   A pipeline can be designed to ensure passage                            o   All 1002 area facilitites will require air quality permits
            of caribou and other  wildlife during the summer by properly                                      to construct and operate.    Air quality monitoring at the
            located sections which are elevated, buried or ramped.                                            large Prudhoe Bay facilities and the other North Slope oil
                Development at Prudhoe Bay, Kuparuk and Milne Point In the                                    fields shows that oil and gas operations at these
            calving range of the  Central Arctic caribou has not had a harmful                                locations fully meet state and federal air quality
            effect on this caribou herd.    The herd has grown from about 3,000                               standards.

            animals In 1975 to its current size of over 13,000 animals. This
            experience is reason to believe that devel  -opment in the 1002 area

                                                                                                                                           -9-

                                                                                                         Peak annual employment effects are estimated at about 39,000
             Economic Benefits of 1002 Area Development                                                  direct jobs, and about 29,000 indirect jobs.      Aggregate
                 With regard to the economic benefits of coastal plain                                   development expenditures for North Slope fields, including
             development, the DOI draft report cites no Gross National     Product                       expenditures for the Trans-Alaskan Pipeline System of about $8.8
             (GNP) or employment gain estimates. While we have not derived                               billion, are estimated at about $36 billion through 1985.
             such estimates directly, it Is possible to develop some                                          Experience on Alaska's North Slope shows how states and
             approximate effects by extrapolating from other analyses.                                   communities benefit from an active exploration and production
             Development of petroleum resources in the 1002 area could     result                        program.   It is estimated that, between 1980 and 1986, the major
             in significant economic benefits to Americans throughout the                                oil companies operating on the North Slope spent more than $10.5
             nation.  For example, extrapolating from the employment and GNP                             billion Iin the United States  developing the North Slope oil
             effects of a recent Battelle/DRI study, which looked at t4w                                 fields.   Every state in the union participated in supply    .Ing goods
             aggregate employment effects of Incremental peak OCS production                             or services, with the shares of business ranging from nearly $1.4
             of 2.5 million barrels a day of crude oil equivalent, we can                                billion in Alaska. to so" $200,000 in West Virginia.
        9                                                                                                    However, the individual states and companies within those
         L   proJect the following results.     Based on a DO! peak production
         L   estimate of 659,000 barrels daily (assuming recoverable reserves                            states have not been the sole beneficiaries of oil company
             of 2.3 billion barrels), the cumulative employment gains could be                           activities. Federal lease sales, rents and royalties on federal
             254,085 jobs. Using the same base projection of production, the                             land In the U.S. are providing a major source of revenue --
             GNP. could increase about 0.25 percent above the level that would                           second only to the income tax in size -- for the federal

             otherwise exist.                                                                            government.
                 API estimates that, since 1980, when peak production of about                               If the coastal plain were to be leased an.d. a large field
             1.5 million barrels per day from the Prudhoe Bay field was                                  discovered in the 1002 rea, large royalty payments would be
             achieved, North Slope development has contributed to an increase                            generated.   The distrib:tion  .of t-h4a, potential revenues among the
             in the gross domestic product  I in excess of $19 billion per year.                         federal, state and local governments depends on the details of
                                                                                                         how the area will be leased, which has not yet been determined.
             1   The gross domestic   product is the sum of all goods and                                However, the federal share of the bonus monies, rents and
                 services  produced within a nation's border.     The gross                              royalties could help offset declining federal revenues from other
                 national  product to the sum of all goods   and services                                fields which have passed      or will  soon pass     peak production.

                 produced  by a nationl,a firms anywhere In   the world.

                                              _10-

                   To put potential revenues Into perspective, consider that, in                    recommendation to permit full oil and gas leasing in the 1002
               1984 alone, Alaska received about $1.4 billion In oil and gas                        area. We regard this step as vital to meeting the nation's
               royalties, rents and bonuses from leases on its own lands.                           future energy supply needs and reducing the risk of a return to
                   Development of the 1002 area would also have the important                       the energy disruptions of the 19709.
               economic benefit of providing a continuing oil flow for the

               Trans-Alaska Pipeline as oil fields elsewhere on the North Slope

               are depleted.

                   Finally, significant discoveries within the 1002 area could

               help reduce the nation's neliance on oil Imports. The 1002 area

               could thus benefit the economic and national security of the

               United States by helping to reduce the flow of American dollars

               to overseas.

               Conclusion

                   At a time of continuing political instability in the Middle

               East -- and when U.S. oil Imports are at a level even higher than

               at the time of the 1973-74 oil embargo -- it is critically

               Important for this nation to increase its development of domestic

               energy resources. As the Department of the Interior's draft

               report so effectively demonstrates, the 1002 area offers one of

               America's beat prospects for major new oil and gas discoveries.

               However, as noted earlier, it takes as much as 10 to 15 years to

               explore for and place into production oil fields in hostile

               environments such as that of the 1002 area.

                   Thus, the national interest requires that action be taken now

               to open the 1002 area to oil and gas exploration and production.

               We endorse the Interior Department's proposed Alternative A

                                                 P.O. Box 100767
                                                 Anchorage, Ak. 99510
                                                 January 10, 1987
               U.S. Fish and Wildlife Service                                                                        WRITTEN COMMENTS ON DRAFT& ARCTIC NATIONAL
               Attn: Division of Refuge Management
               2343 main Interior Bldg.                                                                              WILDLIFE REFUGE, ALASKA, COASTAL PLAIN
               18th and C Sts., N.W.
               Washington, D.C. 20240                                                                                RESOURCE ASSESSMENT

               To Whom It May Concern:
                     Enclosed are written comments on the draft. Arctic National
               Wildlife Refuge, Alaska, Coastal Plain Resource Assessment. I have                                    SUBMITTED ON BEHALF OF THE AMERICAN WILDERNESS
               prepared and submitted these comments on behalf of the American
               Wilderness Alliancej 7600 East Arapaho e Road, Suite 114, Englewoodr                                  ALLIANCE BY STEVE LIVINGSTON, N.D., ANCHORAGE,
        9      Colorado 80112.
        TL                                       Sincerelv.
                                                                                                                     ALASKA

                                                 Steve L vingston, M.D.

                AWA                                                                                     AWA                                                              2
                VAV        American Wilderness Alliance                                                VAV American Wilderness Alliance
                           76M ECMt Atapahoe Rood / Suite 1141 EnQWwOod Colorocio 801121(303) 771-MM                7600 East Arapohoe Rood I Suite 114 1 Eroewoock Colo(odo SM12 1 (303) 771-0380

                    The American Wilderness Alliance strongly opposes the                             the 1002 area. The major adverse environmental impacts of oil
             Secretary of the interior's preliminary recommendation for full                          leasing are understated throughout the.recommendation. We will
             oil leasing of the 1002 area in the Arctic National Wildlife                             document this further in our specific   Icomments below.
             Refuge. We urge the Secretary to reconsider this decision in his                                The executive summary is quite misleading, stating that
             final recommendation. After a thorough review of the draft                               the "evidence generated during the 18 years of exploration and
             report, we have a number of comments to make on the serious                              development at Prudhoe Bay indicates minimal impact on wildlife
             environmental consequences of oil exploration and development in                         resources.' This summary virtually ignores the potential
             this area.                                                                               environmental consequences of oil leasing on wildlife, and
                   We would first like to comment on the process used by the                          relegates its comments to a few small, meek paragraphs near the
             Department of the Interior in producing this report. It is only                          end of the summary. While we are not certain who wrote the
             through a lawsuit filed by Trustees for Alaska land joined by the                        executive summary, the author obviously d  id not read or chose to
             American Wilderness Alliance as a co-plaintiff), that the draft                          Ignore the chapter on environmental consequences prepared by the
             report was made public at all prior to its presentation to                               U.S. Fish and Wildlife Service# for there are no references to
             Congress. This cons%ituted a blatant attempt to keep the public                          the enormous adverse effects that are well-documented by PWS.
             from commenting on a major issue, and appeared to be collusion                           Since many congressmen, news media, and other officials are too
             with the oil industry. Such attempt to influence Congress without                        busy to read the full report, we feel that the current executive
             public input is not compati 'ble with the democratic process.                            summary offers a biased and unfair view of the reality of oil
             Furthermore, we question both the timing and the location of the                         leasing in the 1002 area. we urge the "executive- who wrote this
             public hearings. The hearings began immediately after the longest                        summary to prepare a more balanced one for the final report.
             holiday season of the year, and were held in only three places.                                The potential consequences to the physical environment of
             In particular, there was little opportunity for Alaskans, who                            full oil leasing may be considerably greater than that predicted
             would be affected most by oil drilling in ANWR, to give their                            in the draft report, for there is little attention paid to the
             views. A 60-day comment period may fulfill the letter of the law,                        issue of water access. As the FWS notes, there simply is not much
             but coming in mid-winter at a busy time, certainly does not                              water available in the 1002 area for oil exploration.- Most of the
             fulfill its spirit. in addition, the Department of the Interior                          lakes that occur in the 1002 area are shallow, and freeze to the
             continued to demonstrate its contempt for the public process by                          bottom in winter, making them inaccessible for use as water
             appealing the original decision requiring public comment. This                           sources during the usual time for exploratory drilling on the
             appeal, which also failed, was moot, and an unwarranted waste of                         North slope, which is winter. Furthermore, almost every one of
             taxpayers' money.. We urge the Department to be more forthright in                       the 10 major and 14 smaller streams in the 1002 area freezes to
             its future dealings regarding public lands.                                              the bottom in winter, making these also inaccessible for use as
                   We have numerous objections to the Secretary's                                     water sources. The few that do not freeze to the bottom are used
             recommendation itself. The Secretary's recommendation almost                             as fish over-wintering areas, and, therefore, could not logically
             mimics the oil industry in its attempt to compare environmental                          be used for water sources without doing irreparable harm to the
             effects of Prudhoe Bay oil development with potential effects in                         fish. According to FWS, as much as 15 million gallons of water
          Kbrklng Together To                                                                     VI/orking Together b
          Conserve WikJ Arnefico                                                                  Conserve Wild Arrietico

              AWA                                                           3                       AWA                                                            4
              VMV         American Wilderness Alliance                                              V.*V        American Wilderness Alliance
                          7600 East Arapahoe Road I Suite `114 / Englewood Colorado 80112 / (303) M-0380        7600 East Arapahoe Road I Suite M4 / Englewood Colorado 80112 / (303) 771-0380

             would be necessary to drill a single exploratory well.                                 finished.
                   There is water available from Sadlerochit Spring in the                                The report gives two suggest ions for obtaining water during
             Southwestern part of the 1002 area, as there is year-round flow                        full oil drilling and production. one is to use sea water for the
             from the spring. However, this 4,000-acre area has been nominated                      waterflooding used to sweep the oil toward producing wells and to
             as a National Natural Landmark and would be off-limits for                             maintain reservoir pressure. Waterflooding can involve enormous
             exploration under almost any foreseeable circumstances. There is                       amounts of water. For example, up to 400,000 barrels per day are
             a dense population of macro-invertebrates, as well as arctic char                      injected into the Kuparuk River field and up to two million
             and grayling in this area and the five miles downstream which                          barrels for Prudhoe Bay. The full leasing scenario, in fact,
             remain open during winter, and thus it is used as a                                    suggests two marine and saltwater treatment facilities, both
             fish-wintering area. in addition, this area is used for                                presumably located at the coast. This would require an insulated
             traditional subsistence.                                                               pipeline from the plants to each central processing facility, as
                   The report gives a totally inadequate evaluation of this                         well as heat generators spaced at intervals to keep the water
             problem, as illustrated by the three suggestions offered for                           from freezing. The treated sea water then would be piped to the
             exploratory drilling, one only addresses drilling near the coast,                      individual drilling pads for injection. This scenario could
             and involves the use of shallow ponds and snowmelters. The second                      contribute to the major environmental hazards caused by the
             addresses the few wells that could be drilled on corporation                           proposed east-west oil pipeline, particularly with regard to loss
             lands or near the band of small lakes east of  the Jago River. The                     of insect-relief habitat for the Porcupine caribou herd. The
             third concerns most of the 1002 area. According to FWS, *the same                      environmental consequences of these structures are not addressed
             innovative effort (obtaining water, snow, or ice from wherever it                      in the report and, of course, should be.
             can be found without disrupting the biological environment) would                            Second* the report states that "the most obvious, and
             be required for exploratory drilling elsewhere in the 1002 area."                      probably only feasible, solution relates to gravel sources." Full
             One wonders, from reading these suggestions, if this innovation                        development would involve possible mining and use of as much as
             would include a reversal of the miracle at Cana, i.e., turning                         50 million cubic yards of gravel from within the 1002 area. The
             wine into water.                                                                       FWS suggests that the gravel be mined from streambeds to create
                   The problem of obtaining water for-winter exploration pales                      elongated deep pools up to 40-50 feet deep, which, after spring
             by comparison to the engineering problems faced for full oil                           runoff, can supply water year round. It suggests excavations
             development and production. Water would be needed for up to 50-60                      within the river channel or immediately adjacent but connected to
             drilling pads, each with one or more wellsl plus about seven                           the channel. The environmental consequences of this are not
             large and four small central processing facilities. This water                         addressed. The on.ly comment is that this might create 20 to 30
             would be needed for human use as well as oil exploration and                           elongated deep pools for water storage within or adjacent to
             production. This means up to 10,000 gallons of water per day for                       river beds that now run dry during winter months. There is no attempt
             a construction camp of some 1,500 workers could be needed for                          made to assess what effects this would have on streambeds,
             human use alone. in addition# there would be up to 200-500                             floodplains, fish habitat, subsistence, etc.
             workers in a central processing facility once construction is
          Working Togeiher To                                                                   Working Together To
          Conserve Wild America                                                                 Conserve Wild America

                                                                               5                                                                                            6

                     A careful reading of the draft report reveals that the FWS                          approximately two miles on either side of the Milne Point road.
              appears to be unprepared to address the major issue.of water                               The picture of caribou grazing next to the Transalaska Pipeline
              access for oil exploration and production. An in-depth study                               is quite misleading, based on this information.
              would be necessary on this issue alone.                                                          Attempting to compare the effects on the CAH in Prudhoe Bay
                     Potential adverse effects on both the Porcupine caribou                             and those that potentially may occur on the PCH again may be
              herd (PCH) and Central arctic caribou he   Ird (CAH) are                                   inappropriate, for several reasons. The CAH has been displaced
              well-documented in the chapter on environmental consequences.      It                      from only part of its calving grounds; suitable al   ternative
              should be noted that Input on this part of the report was                                  high-quality habitat appears available for the CAH, and the
              received from 14 caribou biologists, including oil industry                                overall density of CAH caribou on their calving grounds is very
              representatives. Despite this notation on page 97, and the                                 low. The absolute density for the PCH on their calving grounds is
              subsequent report of major adverse effects on the PCH, the                                 14 times that of the CAH, and the difference in effective
              Secretary's recommendation only describes the potential effects                            densities is even greater.
              on the PCH as "some long-term widespread effects." in addition,                                  A substantially greater proportion of important calving
              the Secretary states on page 169 that the CAH "has increased     . .                       habitats would be involved with development that included the PCH
              substantially during the period-that development has occurred                              core calving area. There is a large overlap of potential oil
              within the heart of its range.n                                                            development facilities with PCH calving areas. The PCH would
                     Unlike the Secretary of the interior and oil industry                               annually encounter oil development during the most critical time
              officials. the caribou biologists were quite cautious in making                            in their yearly cycle, the report states. Seventy-eight percent
              analogies comparing the effects of current oil development on the                          of the PCHIS core calving areas is within the 1002 area and is
              CAH and effects of potential 1002 development on the PCH. Because                          designated as Resource Category I habitat. Category I habitat has
                                                                                                         a FWS mitigation goal of "no loss of existing habitat value.'
              of greater density of PCH on their calving grounds, the PCH would                          However, according to the report, an approximately two-mile
              interact with oil development 'much more extensively and                                   displacement of caribou out from oil facilities would include
              intensively' than the CAH has interacted with oil development in
              Prudhoe Bay.                                                                               loss of 32 percent of the most critical PCH core calving areast
                     Although the oil industry often points to the increase in                           According to the FWS, this would represent a complete loss of
              the CAH from about 3,000 animals to some 12,000-14    000 after                            habitat values.
              development at Prudhoe Bay, it does not add that almost no                                       in addition, predation on the PCH is more important than
              calving has been noted in the Prudhoe area since oil development                           for the,CAH in the Prudhoe area. The CAH hasbeen exposed to
              began. According to the report, this increase has been attributed                          minimal predation in recent years. The wolf population In the
                                                                                                         Central arctic area decreased in the 1970's and has remained low,
              to high calf production and survival as well as relatively light
                                                                                                         due to hunting. Brown bears are only moderately abundant in the
              hunting pressure. Attempting to attribute this even in part to
                                                                                                         area. In the 1002 area, however, brown bears are more abundant
              the presence of oil development is absurd, as the facts clearly
              show.                                                                                      and, in fact, shift their habitat use to  *coincide with areas
                     In addition to studies.which show decreased calving                                 occupied by the PCH during calving and pOBtcalving.
              densities around'Prudhoe Bay, a 1985 study reported that maternal                               Oil industry claims that caribou easily cross under the
              car ibou groups showed measurable declines in habitat use within                           Transalaska Pipeline appear to be just as misleading as other

                                                                                7

                                                                                                               The above reiteration of   the 1002 report on the PCH should
              industry claims. The report states that caribou crossing success                            not have been necessary in our  comments. However, the Secretary's
              is.generally greatest at buried pipelines and.then decreases for.                           recommendation and the executive summary persist in inappropriate
              roads without traffic, to elevated pipelines adjacent to roads                              comparisons of the CAH to the PCH and ignore the rest of the data
              without traffic, to pipelines adjacent to roads with traffic,
              respectively. Large mosquito-harassed.groups do not readily cross                           accumulated by FWS. We feel this is unfortunate, as it distorts
                                                                                                          the issue of whether or not the PCH would suffer major adverse
              beneath elevated pipelines. in the full leasing scenario                                    effects with full oil development. The mitigation proposed by FWS
              recommended by the Secretary, the pipeline/haul road would bisect.                          could do little to help the PCH.
              the 1002 area east-to-west. This barrier could significan    Itly                                other wildlife would be affected adversely as well by oil
              inhibit movements for the large postcalving aggregations which                              development. There would be major effects on the muskoxen
              annually occur on the 1002 area as the caribou move between                                 population. The report predicts that they could be displaced from
              inland feeding areas and coastal insect-relief habitats. Insect                             'UP to 71 p.ercent of their high-use.habitats within the 1002 area,
              (mosquito) harassment is one of the primary driving forces in.the                           with a possible change in distribution or decline affecting 25 to
              annual caribou cycle, the report points out, and follows closely
                                                                                                          50 percent of the population. A moderate adverse impact is
              behind the calving period. Insect harassment can have a                                     predicted for wolverines in the 1002 area, but the FWS cautions
              pronounced negative .effect on caribou survival, the report                                 that *inadequate controls on access and harvest could possibly
              states.                                                                                     reduce by half or-more the 1002 area wolverine population.6 The
                     Eighteen percent (294,000 acres) of the 1002 area,                                   report also predicts moderate effects on brown bears due to
              including native corporation lands, used for insect-relief and
              other purposes by the PCH lie north of the proposed pipeline/road                           several factors  While there are mitigation factors proposed for
                                                                                                          these animals that the FWS states would minimize many of the
              corridor. If caribou refuse to cross through any development                                effects they at .ill should be considered in the overall
              areas, then this area would be unavailable as habitat. This
              represents 80 percent of coastal insect-relief habitats. Even                               evaluation of the Secretary's recommendation.
                                                                                                                We are very much concerned about the environmental
              without such a major problem, the report states that 29 percent                             consequences .on marine mammals if oil development occurs, and
              of the coastal insect-relief habitat could be reduced or                                    feel that the report does not evaluate one very important factor
              eliminated. This could lead ultimately to reduced survival,                                 that could affect marine mammals. That is the cumulative impact
              particularly for calves.
                                                                                                          of offshore oil drilling from other lease sales, such as Camden
                     Increased harvest also could  beexpected to   occur  due  to                         Bay, on marine mammals, a long with development in the 1002 area.
              oil development. Based on experience of the North-Slope     haul                            This was not evaluated at all. We feel that such a comprehensive
              road, a significant proportion of the caribou har4est could be-                             study is essential, and do not feel that the effects of 1002
              from illegal hunting, due to increased access for all-terrain
                                                                                                          drilling and offshore drilling could be isolated. This is
              vehicles.
                     In conclusion, the FWS  states   that-fu111 oil development of                       particularly of concern with regard to   polar bears. Even though
                                                                                                          only a few bears use the 1002 area, the report states,that 'the
              the 1002 area could resultin a major population decline and
                                                                                                          exclusion of only one or two bears from areas consistently used
              change in distribution of 20-40,percent,-although this estimatq                             for denning would be a moderate impact on that segment of the
              is uncertain. A more moderate   decline of.5-10 percent was
                                                                                                          Beaufort Sea population." What would happen to the polar bear
              predicted for the CAH.

                                                                                                                                                                      10
                                                                             9

            population if.offshore development also occurs? We urge that this                       exploration and production during certain times of the year?
            be addressed.                                                                           Apparently not, for oil industry representatives objected to some
                . We also have some concerns an the effect of drilling and                          of these proposed mitigation factors at the initial public
            development on birds that use the 1002 area, particularly lesser                        hearing in Anchorage.
            snow geese. Although annual staging use by snow geese in the 1002
            area is noted to be quite varia Ible, the report states that the                               Full oil leasing Of the 1002 area.would have a major
                                                                                                    adverse effect on subsistence uses, according to the draft
            average number of snow geese annually staging on the 1002 area
                                                                                                    report. We do not see how any mitigation factors could prevent,
            could be reduced by almost 50 percent. Mitigation factors offered
            for this potentially serious adverse effect include number 25                           in particular,'the adverse psychological aspects associated with
                                                                                                    such a change in the subsistence lifestyle. Increased hunting
            listed on page 147. This calls for time and area closures or
                                                                                                    pressures from nonresidents who would work in the oil fields
            restrictions on surface activity in areas of wildlife                                   undoubtedly would affect subsistence adversely..We object to the
            concentration for a number of species, including snow   geese. The                      lack of concern demonstrated for Native villages which could be
            dates for the various wildli Ife listed would require rather                            impacted severely by a decline in the PC  IH population. The failure
            significant restrictions throughout certain parts of the 1002                           to hold a public hearing in Arctic Village Is a blatant example
            area from mid-April until late September. We wonder it such                             of this, as well as another example of the Department of the
            restrictions are entorceable or even practical in the face of
            massive oil development. If not, this mitigation factor would    not                    Interior's hurry to railroad its plans for oil development
                                                                                                    through Congress at the expense of the public's right to know.
            be useful.                                                                              These same sentiments have been expressed by villagers from Yukon
                  We also would like to point out the effects predicted on                          Territory, as well as the Yukon territorial government. we do not
            golden eagles, which could be a moderate population decline or                          feel that the secret and unethical dealings with Native
            change in distribution. The major mitigation factors proposed to                        corporations for land trades in ANWR would mitigate adverse
            protect eagles in the 1002 area are the same as those proposed to                       effects upon the subsistence lifestyle, for in some cases Native
            protect caribou. This causes some concern since there is so much                        corporations have demonstratedno more concern for villagers than
            evidence presented that indicates the PCH may decline                                   have the oil companies which traditionally have not hired
            significantly irrespective of attempted mitigation.                                     Natives.
                  Effects predicted on fish in the 1002 area are   minimal.                               Our most important objection to oil drilling in the 1002
            However, this depends in large part on what would be   allowed in                       area has not even been mentioned yet, and appears to hold no
            terms of water access and gravel removal. We have expressed our                         weight in the eyes of those who see only dollar signs as the
            serious concerns about these factors previously.                                        "national interest." The coastal plain of ANWR is one of
                  in the summary of unavoidable impacts with full leasing,                          America's premiere wilderness areas, yet only a small portion of
            there are 24 listed impacts. We have chosen to comment on only                          it, i.e., the northeastern corner, has been designated
            some of these. The 32 mitigation factors proposed on pages                              wilderness. There is no doubt from any point of view that the
            145-147 certainly could have some positive effects. However,                            1002 area is wilderness. It should be so designated. In addition,
            there is no comprehensive plan for what oil development would                           the rest of Alaska's arctic coastal plain outside ANWR is open to
            look like if all of these factors were implemented. Would it even                       oil drilling. Those who say we already have enough wilderness
           .be feasible to.implement them all without paralyzing oil                                have missed the point. We do not hold the purely anthropocentric

                                                                                                                                                                           12

              view that wilderness is primarily for   human beings to enjoy and                          contribution to independence.from our reliance on foreign oil
              contemplate, even though development types speak of an elite                               will be miniscule in the long run. The main reason to promote oil
              corps of backpackers and river runners. While we certainly value                           development in ANWR is not nationalsecurity, it      is pure profit.
              the 1002 area for its recreational opportunitiesp we seek its                              While we certainly do not object to the latter, we feel that this
              preservation as wilderness for much more profound reasons than                             magnificent area's preservation far outweighs any profit motive.
              that4 our view is biocentric. We believe humans are part of the                            Any claim that oil development can proceed in the 1002 area and
              earth's ecosystem, not its masters who have the right to                                   preserve its wilderness values simultaneously is absurd. To quote
              interrupt it an a whim.                                                                    from the draft report on page 131, the Owilderness value of      the
                    We strenuously obj ect to the  Secretary's contention that
                                                                                                         coastal plain of the Arctic Refuge would be destroyed."
              oil drilling in the 1002 area,is necessary for national security.                                In summary, we oppose full oil    .leasing of the 1002 area for
              This is typical of the hoax perpetrated on the    American people by                       the following reas6nss
              the Reagan administration for the past six years.to justify                                I.The 1002 area of ANWR is incomparable wilderness.
              everything from environmental pollution to its Star Wars program.                          2.There is very little water available for oil exploration and
              it is obvious the Secretary is following the party line, with     not                      development, and the adverse consequences of obtaining it are
              a thought about what,really is necessary for our national                                  unacceptable.
              security. is it in our national interest to continue to waste     our                      .3.Oil development would have unacceptable adverse consequences on
              natural resources as we have done for years with no plan for the                           the PhYa--Jr--al environment of the coastal plain.
              future and no concern for future generations? Why do we have no                            4.Oil development would have a major adverse effecton the
              national energy plan? What happens in the year 2630 when we have                           Porcupine caribou herd, possibly.resulting in a 20 to 40 percent
              guzzled most of the oil from the 1002 area? Will technology have                           decline in population.
              found a way to circumvent our need for oil completely by then?                             5.0il development would have a major adverse.effect on muskoxen.
              The wasteful habits promoted by the Reagan administration are                              6.There would  be major adverse effects on snow geese staging in
              indeed myopic, and the failure to complete the ANWR ecosystem by                           the 1002 area.
              adding the arctic coastal plain to its wilderness is just                                  7.There would be moderate effects on    golden eagles, wolverines,
              another illustration of this. How will the four percent of our                             wolves., brown bears, and the Central   arctic caribou herd.
              nation's lustful oil demand.  supplied by the 1002 area in 2005                            8.The effects  on marine mammals havenot been studied adequately.
              help us in the long run? Why is there no discussion in the draft                           9.There is,no  comprehensive study of the cumulativ  .a effects of
              report of energy conservation or alternative energy sources? In                            offshore oil development and oil developmen   It in the 1002 area.
              our parIanoia about f.oreign control of oil sources, we have                               1O.There is. no comprehensive plan for the use of mitigation
              decreased dramatically funding for research on the latter.      We                         factors in oil  development.
              submit that what the Secretary really means by "national -             -                   ll.Subsistence  would be affected severely by oil development.
              interest* and what the oil companies really mean by that term is                           12.There is no  evidence that oil development is necessary for
              simply profit cloaked in the word patriotism. It is a fact      that                       national security.
              oil development in the 1002 area will not be the panacea for our                           13.Oil development is not in the national interest in the 1002
              energy needs that the oil industry seems to claim. in fact, its                            area.
                                                                                                         1A.The nation has no comprehensive plan for energy production,

                                                                       13

            use, and conservation.
                  In conclusion, we will work diligently to see that the
           Congress of the United States designates the 1002 area
           wilderness.

                                                     Steve Livingston, N.D.
                                                     January 10, 1987

    W. Eugene Guess 1932-1975
    Joseph Rudd 1933-1978
    THEODORE E. FLEISCHER
    FRANCIS E. SMITH, JR.
    HERBERT BERKOWITZ
    MICHAEL G. BRIGGS
    DAVID H. BUNDY
    HARRIS SAXON
    PHILLIP J. EIDE
    GARY A ZIPKIN
    JOSEPH M. WILSON
    GORDON E. EVANS
    LOUIS R. VEERMAN
    CLIFFORD W. HOLST
    RICHARD M. ROSSTON
    JAMES D. LINXWILER
    JOSEPH J. PERKINS, JR.
    PATRICK J. COUCHLIN
    LYNN M. ALLINGHAM
    TRICIA COLLINS
    MARK E. WILKERSON
    DEBRA J. BRANDWEIN
    ROBERT A BASSETT
    SUSAN E REEVES
    GEORGE LYLE
    SUSAN D. OJA
    PAUL H. ASHTON
    JOAN E. ROHLF
    MICHAEL S. MCLAUGHLIN
    JOCELYN M. SEDNEY

    U.S. FISH AND WILDLIFE SERVICE
    Attn: Division of Refuge Management
    2343 Main interior Building
    18th and C streets, N.W.
    Washington, D.C. 20240

    	Re: Alliance Testimony on ANWR Draft
    	    Environmental Impact Statement

    Dear Sirs;
    	The Alaska support Industry Alliance(the Alliance) is
    pleased to offer testimony on the draft Environmental Impact
    Statement prepared regarding the opening of the Arctic National
    Wildlife Refuge (ANWR) to oil and gas leasing.

    	The Alliance strongly endorses leasing in this area.

    	The alliance consists of 300 corporate and private
    members engaged in the oil and gas and mining support
    Industries in Alaska. Our unique level of experience with oil
    and gas operations on the NOrth Slope is reflected in our
    testimony. we have focused upon subjects we believe probably
    will not be adquately covered in other testimony, including
    leasing methods, transporatation, existing regulatory
    mechanisms, etc.

    	Sincerely,

    	James d Linxwiler
    	Chairman
    	Alliance ANWR committee

    JDL: Kdw
    Enclosure

    Law Offices of
    GUESS & RUDD
    a PROFESSIONAL CORPORATION
     	510 L STREET
    	SEVENTH FLOR
    ANCHORAGE, ALASKA 99501

    TELEPHONE (907) 276-5121
    	TELEX (090) 25-292
    TELECOPIER (907) 279-8354

    February 6, 1987

    318 foruth street
    JUNEAU, ALASKA 99801
    telephone (907) 586-3210
    telecopier (907) 586-3762

    	#7232W

    	ANWR TESTIMONY-ALLIANCE

    	I. Leasing Methods

    	The most basic action contemplated by congress with
    respect to the Arctic National Wildlife Refuge (ANWR) is
    leasing. However, a full discussion of the merits of this
    basic action has been obscured by teh debate about the
    environmental consequences of oil development in ANWR. There
    are significant aspects with respect to the leasing program
    which should be developed with care. The purpose of this
    section is to discuss this issue.

    	The draft Environmental Impact statement states, with
    respect to leasing systems, as follows as page 89, in its
    discussion of "Alternative A*:

    Under the alternative of full leasing, it is
    assumed that congressional action would
    allow all Federal subsurface ownerships of
    the S 1002 area to be available for
    development through a leasing program
    administered by teh Department of the
    Inteior. this action would also open to
    oil and gas development in production the
    private lands within the refuge. The exact
    terms of the leasing program would be
    developed in response to specific
    legislation passed by the Congress. If the
    congress chooses to authorize leasing in the
    entire s 1002 area, the legislation would
    probably contain the important elements of
    the Mineral Leasing Act and the NPRA
    legislations, with special provisions to
    meet the unique needs of the Arctic Refuge.

                       This statement appears to be made almost in passing,
                                                                                                       competitive onshore leasing program utilizing the statutory
             and there are several significant problems with it:                                       authority and well developed procedures of the Mineral Lands

                                                                                                       Leasing Act, as applied by ANILCA to the unique circumstances
                       First, it is important that no element of the NPRA
                                                                                                       in Alaska. The important features of this program include
             legislation be used. The well demonstrated record is that the                             procedures intended to provide significant environmental
             .NPRA leasing program was not a success.   It was create .d by the                        protection, and to apply in the case of game refuges in Alaska
             Secretary using regulations because the Department itself                                 in particular.
             lacked the statutory authority to provide a normal leasing
             program.   In this environment, the leasing program did not, for                                   The procedures provided in 5 1008   are similar to those
             instance,  contain normal and necessary lease provisions                                  contained in the Outer Continental Shelf Leasing Act (OCSLA, 43
             regarding  unitization, for the maintenance of the lease and the                          U.S.C. S 1401 at seq.) including the preparation, pursuant to
             extension  of the priImary period by shut-in production, etc.                             S 100d(f), of an exploration plan, and, pursuant to 5 100919)f
             The above-referenced statement encourages Congress to create a
                                                                                                       preparation of a deveiopment and production plan. The
             new and untested programs and experience has shown this to be
                                                                                                       Secretary retains the authority to monitor and modify the terms
             unnecessary and undesirable.                                                              of such plans pursuant to S 1008(h), and if the   Secretary

                                                                                                       determines that %mmediate and irrepairable damage will result
                       Second, this statement ignores that there already                               from a continuation enforce of a lease,* then the lease may be
             exists a  weii-developed and environmentally sensitive program                            suspended or cancelled pursuant to S 1008(1).
             expressly created for Alaska game refuges in SS 1008 and 1009

             of ANILCA (16 U.S.C. SS 31, 48 and 49).                                                           Congress need  not attempt to 'reinvent the wheel.'

                                                                                                       The preparation of an environmentally sensitive leasing program
                       We believe that the secretary should recommend to                               which applies to game refuges in Alaska has already been
             Congress that it adopt, with respect to ANWR, the ANILCA                                  accomplished by Congress and all Congress need do is to
             S5 1008 (16 U.S.C. 5 3148) and 10 09 (16 U.S.C. S 3149) onshore                           implement it.  In other words, the simplest action for Congress
             leasing program. The SS 1008 and 1009 program is the                                      to take in this instance would simply be to revoke SS 1002(1)

                                                                                                       J16 U.S.C. S 3142(1)) and 1003 (16 U.S.C. S 3143), and the

                                                                                                       SS 1008 and 1009 program will automatically apply.

                                                                                                                                      -3-

                             ii. NATIVE SUBSISTENCE WITHIN ANWR                                          herd, along with water   fowl. The industry's excellent record

                                                                                                         in protecting caribou and other subsistence resources from

                        Preservation of the subsistence resource is one of    the
                                                                                                         impact at Prudhoe Say and Kuparuk is a further reason why
               most d,ifficult and important issues relating to.opening ANWR to                          subsistence resources will not be impacted in this area.
               oil and gas development.   In evaluating  this issue, it is
               important to keep in mind  the following  points:                                                   Third, the subsistence lifestyle requires access to

                                                                                                         cash, for.purposes of obtaining three-wheelers, guns,

                        First, the oil and gas industry has a   strong                                   ammunition, and related supplies. The villagers in the local

               commitment to preserving  subsistence resources, and an                                   area will be able to utilize job opportunities offered by oil

               .excellent track record in having done so. The,oil and gas                                development to enhance their subsistence activities.

               industry has worked on the  North Slope and in western Alaska in

               close contact with Native  communities and regulatory agencies                                      Fourth, Natives in the area,   who are well experienced

               seeking to preserve the subsistence resources which otherwise                             with the interactions between oil and    gas development and
               might be affected bY oil*and qas exploration and develooment.                                  j sttpneqi. favor oil ana.gas develop ment in ANWR. in fact,
               As a,result, no significant  impact upon any subsistence                                  Jacob Adams,  President of the Arctic Slope Regional
               resource has ever been substantiated as a result of oil                                   Corporation,  himself a whaling captain, has offered testimony

               exploration and development  in Alaska -- and it is our   strong                          in favor oUopening ANWR.to leasing which states that the

               belief that this excellent track record will continue in ANWR.                            Eskimo community is familiar with the favorable record of the
               The industry is strongly committed to this concern and will                               oil companies in regard to the preservation of the subsistence

               closely cooperate with Native subsistence users.                                          resource.

                        Second, it is also important to take note that                                             Preservation of  subsistence  resources, and access to

             ..subsistence impacts can only occur if there are significant                               them, is  a high priority  of Kaktovik  residents.   Dall sheep,

             .Impacts upon the wildlife resources of the area.     The primary                           caribou,  fish, seals, whales, birds and eggs, moose, and

               subsistence resource in this area is the Porcupine   Caribou                              furbearers contribute to their subsistence economy.

                                              -4-

                      As is the case in other North Slope villages, most                                               III. DRILLING TECHNOLOGY

             residents obtain at least some of their food by hunting and
             fishing, and many get half or more oftheir total household                                      we believe the EIS should take more complete
             food through hunting and fishing.                                                      recognition that drilling conditions in ANWR will not be vastly
                                                                                                    different from Prudhoe Bay. The terrain, climate, logistics
                      While the villagers of Kaktovik retain strong ties to                         and necessary support system will not be anything new and we
             the land, they also have adopted and incorporated many elements                        will have had the benefit of over 40 years of arctic
             of western culture, technology and economy into their                                  experience. This is especially important in that a "learning
             lifestyle. Oil and gas development, and the subsequent North                           curve" has been established and we will not be making the same
             Slope Borough capital improvement program, have Increased the                          mistakes. Over 1100 wells have been drilled in the North Slope
             village's economic activity.                                                           area witn no disastrous consequences to the environment. The
                                                                                                    oil industry rec6rd &no methods of operation in the arctic are
                      Changes in the Inupiat subsistence economy at Barter                          truly exceptional.
             Island began about 1890 when whaling ships anchored in the
             harbor, and food, utensils, firearm a and other items were                                      Prior to drilling in ANWR, a comprehensive
             exchanged for caribou and sheep meat, and clothing made of                             environmental study will probably be required. Assuming this
             caribou bides. Bowhead whaling ceased from 1910, but economic                          is completed, a variety of permits will be requested that will
             activity.continued in the forms of reindeer.herding, trapping                          insure environmental integrity. This is the first phase of the
             and postwar construction.                                                              drilling operation and it will be administered by a host of
                                                                                                    government agencies. These agencies will spell out
                      This activity created a dependence upon cash, and most                        stipulations pertaining to all aspects of the program so that
             villagers see local petroleum development as a positive means                          in a sense, the government will be implementing and enforcing
             for maintaining a cash flow. At the same time they believe                             their own recommendations.

             that, given appropriate.environmental safeguards, oil and gas

             development will not endanger important subsistence resources.

                                           -6-                                                                                     -7-

                                                                                                                Extensive use of ice roads, and ice airstrips will lie

                                                                                                       used resulting in no environmental damage.

                                                                                                                In addition, depending on well requirements the use of

                                                                                                       Ice pads may be applicable. This.type of construction is

                                                                                                       cheaper and more time effective than conventional gravel

                                                                                                       contruction. it is also in the beat interest of the operators

                                                                                                       since it is more cost effective.

                                                                                                                With today's state-of the art rigs less pad space is

                                                                                                       required and a rig can fit on a 25,000 sq. ft. site.

                                                                                                       Additional opace for camp and other drilling equipment Will be

                                                                                                       needed.

                                                                                                                Once the rig is mobi lized actual drilling operations

                                                                                                       can commence. Of primary concern is well control and Mud

                                                                                                       disposal since these are the major sources of any  potential

                                                                                                       pollution. Well control is of utmost-importance   to everyone on

                                                                                                       the rig and all supervisory personnel will be 14MS certified in

                                                                                                       well control.

                                                                                                                in addition to trained personnel, all equipment will
                                                                                                       be "state of the art.* Normal blowout prevention equipment
                                                                                                       would Include three ram type prevent6rs and one annular

                                                                                                       preventor aesigned to exceed all expected pressures.

                                                                                                                                      -9-

                        Hydraulically operated chokes, pump stroke counters,                                    Again, it is in the operator's beat interest to
              trip tanks "flow-showo meters, Kelly cocks, trip tanks and                               minimize the fluids in the pit since "Mud" costs money. By
              inside BOP's are all part of the well control equipment. These                           using solids control equipment such as shale, shakers,
              items are considered "standard' on arctic drilling rigs.                                 desanders, desilters and centrifuges only the cuttings end up

                                                                                                       in the reserve pit with minimal amounts of   mud.

                        In addition to the basic equipment, mud logging
              functions woula normally be used on exploratory work. This                                        Mud monitoring is usually required and includes data
              system provides continuous monitoring of the mud flow and other                          on muds discharged, cuttings discharged, product concentrations
              drilling parameters such as mud density,.background gas,                                 and other parameters. Certain products may also be prohibited
              drilling rate and pore pressure.                                                         by the EPA, and the mud system must fall into one of their
                                                                                                        generic" types. All mud additives are basically approved
                        The use of this equipment helps predict bottom hole                            prior to actual drilling operations. Alot of effort is
              pressures and consequently adjustments to mud density can be                             extended in these two areas, (blowout prevention, and mud
                                                                                                       disposal) and again our record'to date in Prudhoe shows that we
              made before actually needed. Pi.t level inuicators, pit
              watchers and.continuous monitoring by the mud loggers are a                              have done a good job.

              normal part of well control. All of this equipment and
              measuring devices help insure minimal risk-of a blowout.                                          Other areas of concern include water supply, fuel
                                                                                                       storage, and sewer discharge. Again these are closely
                        Another area of concern is mud disposal. Mud cuttings                          monitored and spelled out in the permits.

              are normally dumped in a reserve pit and then covered and
              reseeded. This system works quite well and the top soil                                           Only deep water lakes will be used for water sources.
              removed is usually stockpiled so it can be used to cover the                             with screen hoses to insure no fish are pulled into the hose.
              reserve pit.                                                                             Fuel storage is normally in double wallea tanks se  It in a linea
                                                                                                       and boxed in area. Sewer discharge is monitored daily and all

                                                                                                       plants must have an approved system.

                                             _10-

                          The agencies    .issuing the drilling permit set the                              which take place within the State    of Alaska, whether they be
                 ground rules and they also monitor the overall drilling                                    conducted on federal, State, Municipal or private lands, are
                 program.  Provided they  Ido not put prohibitive restrictions in                           governed by a broad array of regulatory programs to insure the
                 the per mit we can meet and often exceed their requirements.                               prevention or mitigation of environments   11 impact. The Arctic
                                                                                                            National Wildlife Refuge is no exception to this rule. The

                                                                                                            1002(h) report does not acknowledge the importance of these
                          Once drilling operations are complete, the rig will be
                                                                                                            programs, which are above and beyond any operating conditions
                 demobilized to Prudhoe Say. Normal procedure is to clean up
                                                                                                            and stipulations which the Department of Interior, Fish
                 the location after demob and then return again in the summer to
                 pick up any debris that was frozen in.                                                     Wildlife Service will impose on operations in that area.

                                                                                                                                   B. FEDERAL PROGRA14S
                          Other than a wellhead sticking up, many locations are

                 difficult to find once final clean up has been done.
                                                                                                                      on federal lands such as ANWR, federal agencies

                                                                                                            orovide  the Drimarv reaulatorv structure covernina oil and aas
                                   IV., REGULATORY FRAMEWORK IN
                             ARCTIC NAT   IIONAL WILDLIFE RE FUGE (AhWR)                                    operations. The Department of     the Army, Corps of Engineers and
                                                                                                            Environmental Protection Agency are responsible for
                                          A. INTRODUCTION                                                   implementing programs establish d by the Clean Water Act and
                                                                                                            the Clear Air Act. The Corps o: Engineers is responsible for
                         The mitigation measures directly applied as part of                                administering the Section 404 program which governs the
                 the opening of ANWR are not the only applicable mitigation                                 deposition of fill ma  Iterials in *waters of the United States,'
                 measures.' We believe the EIS in its discussion of potential                               which includes wetlands.     IIn its lead agency role it accepts
                 impacts and mitigation should take fuller account of the                                   comments from all interested state and federal agencies as well
                 extensive local, state and federal regulatory system already in                            as the public in developing conditions and stipulations to
                 place, and which has mitigated essentially all major impact   Ia                           mitigate or prevent any environmental impacts related to fill
                 for existing North Slope developments. Oil and gas operations                              operations. Many of these conditions and stipulations in the

                                                -12-                                                                                        -13-

               past have extended to restrictions on operations not directly                           Washington, D.C. This authority has a similar affect to that
               related to the actual construction fill operations. By the                              of the Environmental Protection Agency veto authority described
               imposition of these stipulations and conditions the interested                          above.  Fish & Wildlife Service uses this authority more
               agencies and the public have strictly controlled the type and                           frequently.  Such elevation makes the review process ever, more
               quantity of operations which taXe place in those areas falling                          exhaustive and is one more guarantee that impacts will be
               under the jurisdiction of the Corps of.Efigineer's program.-                            prevented or mitigated, even when the quality and scale of
                                                                                                       impact is questionable.

                        The Environmental Protection Agency and Fish
               Wildlife Service play key roles in the management of the                                         The Environmental Protection Agency has prima  ry
               Section 404 program. Although the Corps of Engineers is the.                            authority over two important regulatory programs -- the Clean
               lead federal agency in managing the program, the Environmental                          Water Act discharge program known as the National Pollution
               Protection Agency has the authority to veto any Corps of                                Discharge Elimination System (NPUES) and the Clear Air Act
               Engineers' approval of a project which it considers to be a                             permitting program known as Prevention of Significant.
               detrimental fill. Though this authority is rarely used, the                             Deterioration (PSD). The NPOES program regulates the discharge
               potential that it might be used gives the Environmental                                 of water or other fluids from a *Point source.* A point source
               Protection Agency a substantial voice in project reviews.                               is any means of transmitting or carrying or disposing of water
               Under the Fish & Wildlife Service Cooraination Act the Fish                             or other liquids such as a pipeline, outfall line, hose or even
               Wildlife Service also has substantial influence over what                               a tanker truck. As a part of the Clean Water Act, this program
               stipulations and conditio .no are imposed on a project,                                 dovetails with that of the Corps ot Engineers under Section 404
               specifically relative to how such projects might impact fish                            to provide a complete system of regulatory coverage of water.
               and wildlife in the vicinity of the project area. Though the                            quality.. The PSL) permit regulates the discharge of elements
               Fish & Wildlife Service does not hav Ie an absolute veto, it does                       into the air from operation of equipment, machinery, motors,
               have the capability of elevating a decision made at the local                           and other devic.es. both the NPDES and PSD programs require
               level of the Corps of Engineers.to the headquarters offices of                          intensive coordination between the applicant and the
               the Corps of Engineers and Fish & Wildlife Service in                                   Environmental Protection Agency, including the providing by the

                                              -14-

                applicant of large amounts of detailed specifications and                               a clearing house for the comments from all interested State
                chemical analyses.  In the case of the PDS application, in                              agencies.  The  ANWR lands fall within the coastal zone, as
                particular, the process may take years to complete.                                     defined by the  State program, and are therefore subject to this
                                                                                                        consistency requirement.

                         The regulatory umbrella  described above provides
                complete coverage of land, water  and air quality concerns.                                      The interested State agencies include agencies such as
                Superimposed on that coverage that is proposed by the Fish                              the Department of Environmental Conservation and the Department
                Wildlife Service through the stipulations is proposed for                               of Fish and Game which are the counterparts of the federal
                application throughout the 1002 area, as well as the coastal                            Environmental Protection Agency and Fish & Wildlife Service.
                zone management certification requirements described below.                             Accor.dingly, this program provides yet another Layer of
                                                                                                        regulatory mitigation or prevention of environmental impacts.

                               C. STATE COASTAL ZONE MANAGEMENT
                                                                                                                                 D. CONCLUSION

                         State agencies have the opportunity to influence the
                federal regulatory program on federallands throughthe State                                      The existing panoply of regula .tory programs vitiates a
                of Alaska Coastal Zone Management Program. The State program                            perceived need for additional regulatory control. Any
                was conceived with federal authorization under the Federal                              management program conceived by the Fish a Wildlife Service
                Coastal Zone Management Act of 1972. Since the approval by the                          should take into account these programs which are already in
                                                                                                        place and not duplicate or layer further upon these programs.
                federal government of the State program, it is required that

                federal agencies receive from the State of Alaska a
                                                                                                                        V. TRANSPORTATION - SEA     ROAUS
                certification that a given project or permit approval therefor,

                is consistent with the federally approved State Coastal Zone
                                                                                                                 The discovery and Subsequent production of large
                Management Program. Until the State of Alaska approves the
                :
                 dministration of the State program by a local area, the Office                         quantities of oil an; gas in remote areas of the Arctic brought
                 f the Governor, Division of Governmental Coordination acts as                          about the development of Innovative logistical support systems,

                                              -16-                                                                                     -17-

               insuring timely delivery of supplies and equipment under severe                           all-terrain vehicles or by ice roads.    ice roads are
               conditions without damage to the fragile environment.                                     constructed of ice and fresh water which allows conventional
                                                                                                         trucks to transport cargo over four to six inches of ice. This
                        A network of snow trails, offshore   Ice roads and ice                           ice protects the tundra. Exhaustive tests have been done on
               landing strips combine to provide environmentally sound water                             the effects of ice roads on tundra degradation and compacting.
               transportation. Summer transportation may be accomplished                                 The end results are no long term effect.

               utilizing barges and CATCO type low ground pressure vehicles.
                                                                                                                  All-terrain vehicle design has evolved from tracked
                        Exploratory well pads made from ice have replaced the                            caterpillar type units, to low pressure tracked units, to
                                                                                                         rubber tired units and finally to low pressure soft pliant
               gravel pad further lessening the impact of exploration.
                                                                                                         airbag units. The designing and utilization of the CATCO
                        Equipment designed for the a  nvironmentally sensitive                           all-terr.ain vehicleIhas proven that operations over tundra in
               tundra has been developed and exhaustively tested in Alaska and                           summer and winter operations can be completed with no
               Canada. The hovercraft and hoverbarges were designed to                                   degradation to the tundra. CATCO offers an innovative strategy
                                                                                                         in off-road heavy cargo transport. Designed to protect fragile
               transport loads over water. sea ice and tundra without damaging
               the surface. For local tundra travel CATCU designed a top                                 ecosystems and get the job done, the CATCO is a lightweight
                                                                                                         vehicle that looks and handles like a truck but rolls on@
               roller driven alrbag tractor which traverses the delicate
               summer tundra without lasting effect. After many years of                                 pliant, low-pressure airbage whichallow the Vehicle to "float"
               Arctic experience. Ind .ustry has developed the equipment and                             heavy loads over.the ground. With this cushioning effect and a
                                                                                                         unique system of suspension and locomotion the CATCO can
               more importantly an attitude of sensitivity in the work force
                                                                                                         operate throughout the year on all types of terrain with a
               so exploration and production can develop fields'without
               environmental damage.                                                                     minimum of environmental disturbance. Most importantly is
                                                                                                         CATCO's experienced work force; when combined with the unique

                                                                                                         CATCO all-terrain equipment has an unsurpassed record of
                        Transportation from coastal staging areas to
               particular well locations Is easily done over the tundra by                               environmental safe operations In over 14 years of.operation in
                                                                                                         the Alaskan Arctic..

                                                                                                                                        _19-

                          The annual Sealift has developed equipment and                                          During the mid 1970s, the Canadian Arctic Gas Study

                 techniques which allow the cost effectiveness of modular                                Ltd., and its counterpart, the Alaskan Arctic Gas Study

                 construction methods in developing production facilities.                               Company, engaged In a $200 million research project that

                 Since 1969 over thousands of tons of modules and general cargo                          examined the impact of development on caribou and other aspects

                 have been delivered to Prudhoe, Kuparuk, Milne Point and                                of the arctic environment.   The studies indicated that the

                 Endicott fields. Development of ANWR would be considerably                              impact of development could be minimized.

                 easier due to the perfected techniques of Prudhoe Bay.

                                                                                                                  In addition, since the mid 1970s the state of Alaska

                                VI. INTERNATIONAL COMMUNICATIONS                                         and the United States Fish and Wildlife Service have discussed

                                                                                                         with Canadian officials mutual concerns about management of the
                          A Canadian government official, speaking at the ANWR                           Porcupine Caribou herd. The discussions were motivated by
                 hearing in Anchorage, contended that the oil and gas leasing                            pending settlement of lands issues, and proposed oil and gas
                 issue should take into consideration the concerns of his                                leasing within the range of the herd.
         9       --.ry. The    -96:4-4-1 -- 'Jected a sentiment that opening
          A                    --c- re-
         CO
                 coastal plain to leasing could damage the integrity of the                                       Talks were suspended in 1980 pending resolution of
                 Porcupine caribou herd, and thereby hurt the interests of Yukon                         domestic issues on both sides of the border. ANILCA resolved a

                 Territory residents.                                                                    major conservation issue for Alaska and the United States, and

                                                                                                         the Canadian government reached settlements with the Natives by
                          In addition, he said the U.S. Interior Department has                          1985. These events set the stage for subsequent international
                 not solicited input from Canadians regarding this                                       negotiations. Now the two countries are nearing the point

                 "international issue."                                                                  where an agreement can be written-that will promote

                                                                                                         international coordination of management of the Porcupine

                         In evaluating these comments, the following should be                           caribou herd. The pending agreement will ensure the continued
                 considered:                                                                             integrity of the herd.

                                               -20-

        National                   11405 Hawking Lane
        Wildlife Refuge            Anchorage, Alaska 99516                                                                                     Mr. William P. Horn                                             Page 2
        Association                January 26, 1987                                                                                            January 26, 1987

                                                                                                                                               The Baseline Study of Fish and Wildlife Resources section should
                                   Mr. William P. Horn                                                                                         be moved to the Fish and Wildlife Resources section on page 27
                                   Assistant Secretary  for                                                                                    and the Oil and Gas Exploration Program section to page 47 to
                                   Fish and Wildlife   and Parks
                                                                                                                                               Improve  continuity and clarity, as well as to avoid cluttering
                                   U.S. Department of the Interior                                                                             the introductory chapter if there is to be one.           A concisely
                                   Fish & Wildlife Service                                                                                     written introduction would suffice In lieu of draft chapter 1.
                                   2343 Main Interior Building                                                                                 The Introduction would. incorporate the existing Introductory
                                   18th & C Street, N.W.                                                                                       material, report purposes and a more comprehensive review of
                                   Washington, D.C. 20240                                                                                      legislative   history (aside from ANILCA deliberation period as
                                                         of Refuge Management                                                                  reported).    The latter is important background material for
                                       Attn: Division                                                                                          readers to have a complete and accurate insight of the
                                                                                                                                               establishing  process, resource values, and the vulnerability of
                                   Dear Mr. Horn:                                                                                              these values  under leasing Incursions. In sum, the introduction
                                                                                                                                               should be limited to study purposes and scope, and that
                                   This supplements previous comments made by the National Wildlife                                            background material required to put problems and requirements in
                                   Refuge Association (NWRA) as transmitted January 15,            1987 by                                     perspective.    Guideposts should be Included to help orient the
                                   Mr. Forrest A.  Carpenter regarding the draft          Arctic National                                      reader.
                                   Wildlife Refuge. Alaska Coastal Plain Resource Assessment (1002)
                                   report released for public review.on November 24. 1986.                                                     In Chapter 11, Existing Environment, the text contains mis-
                                   To reiterate NWRA's positiont we cannot support the Interior                                                leading, contradictory, and Inadequate information.
                                   Department's recommendation of leasing the 1002 area, and we Instead                                        Page 21y Water Resources, the lead statement that "water
                                   favor the "no action alternative" and urge that the Arctic NWR be                                           resources are very limited" contradicts the reporting of
                                   managed for its Intended purposes. This position is predicated In                                           12 major riverine systems (29 percent of the 1002 area) and
                                   part upon the Inadequacies of the 1002 assessment report.               We                                  extensive wetland habitats (99 percent of the 1002 area).
                                   suggest this report be redrafted to improve overall objectivity.
                                   organization. accuracy, completeness, ate., if indeed it to to be                                           Page 27, Fish and Wildlife -Resources section inappropriately
                                   used as a decision-saking document.                                                                         refers first to treaty obligations. This Is not in context with
                                                                                                                                               the Existing Environm%t Ct          er.   Tr eaty and congressional
                                   our previous memorandum dealt with concerns in       a general way and                                                        ld be . ffva@p
                                   provided some examples in their support.      These  comments here deal                                     obligations shou                  d to a separate. clearly-defined
                                                                        urther substantiating the reasons                                      section and discussed in terms of their relationships to oil and
                                   with technicalities as a means of f                                                                         gas leasing.
                                   underlying NWRA'a position on this issue.           These comments are
                                   neither complete nor exhaustive because this complex issue. together                                        As mentioned, the page 11 Baseline Study             gh        Wildlife
                                   with the extensive difficifin.lea of the draft loo2 report. make the                                        studies should be part of the Introduction %IeFtd ptiarndgraphs) to
                                   task of providing a comprehensive review too unreasonable for me to                                         the Fish and Wildlife Resources section beginning on page 27.
                                   undertake at this time. Although these comments represent the tip                                                                         ---IT be better described in terms of
                                   of the iceberg, they amply demonstrate that the 1002 report to badly                                        The baseline study effort shou
                                                                                                                                               when and where studies were performed.            Were studies. for
                                   flawed. Our position is consequently well justified.                                                        example. limited to summer field periods or were they conducted
                                                     a  and Need for this Report is overly complicated.                                        throughout the year?
                                   Chapter 11 lpossu                                                                                           Baseline studies are ordinarily performed to determine specific
                                   disjointed    d    perfluous in some instance         The purpose(s) of
                                   this report are not expressed In succinct terms; background material                                        biological parameters as a be     sis for monitoring change attrib-
                                   Is excessive in some instances, incomplete In others; topical                                               uted to consequential factors.      Considering this as a baseline
                                   material is awkwardly organized. The organizational problem can be                                          study purpose, the species-specific
                                   alleviated   by              the   topic.    Program    DefflcriEtin    and                                                                            Information reported for
                                                      placing                                                                                  some mammals, birds. and fish In the Fish and Wildlife Resources
                                   I lamentation, together    with the subtopic, Report Preparation, on                                        section does not reflect such a baseline study approach.             We
                                   as iv (now blank). Pages iv and v in the final report would thus                                            understand that the final baseline and 1985 update reports were
                                   have two topics:      1) Pr                      Id
                                                              oaramw=r             aprC Implementation, and                                    not prepared in tAme for the results to be incorporated in the
                                   2) R;p                      L,         =a           ontr Ibutlons to the                                    1002 report.    If this to true, then a statement to this effect
                                      0 tgrt.::;j:jation which
                                   Rep                 appearing in pages iv through 11 Of the draft                                           should be made.
        Dedicated to the           document.
        preservation and
        oeipetustion of The
        National Wildlife
        Refuge System.

    				Page 3
    Mr. William P. Horn
    January 26, 1987

    In certian instances, life history aspects presented for
    specific species are irrelevant and without bearing on 1002
    report purposes.

    Page 29, next to last paragraph, reference is made to an
    estimated 2- to 3 thousand post-calving caribou using the 1002
    area and an additional 1,000 caribou located west of the
    sadlerochit River and north of the Sadlerochit Mountains. Do
    these caribou use the 1002 area or not?

    Page 30. The section on muskox does not report the number of
    animals using the 1002 area. If use varies seasonally an
    average annual use figure would be important to document.

    The Moose section does not recognize the average number of moose
    ranging in the 1002 area. In view of the 60 some staff years
    represented in the baseline study effort, I.E. 57 separate filed
    studies conducted over a five-year period, we would expect a
    substantive accounting of 1002 area moose and other large mammal
    populations. The statement that "moose numbers are probably
    less than 25 animals" should be a highlight of the lead
    paragraph rather than relegated to a supportive paragraph as
    drafted, for this single remark is the most meaningful
    "observation" in this section. Again, a crucial need is to
    quantify mammal use of the 1002 area, and while winte moose
    populations occuring outside the 1002 area is a noteworthy
    subject, such remarks have less importance and can thus be
    relegatedd to subordinate paragraphs.

    Page 31, Dall Sheep. This section is superfluous unless Dall
    sheep occur within or proximal to the 1002 area. What is the
    linear distance between their Sadlerochit Mountain rangelands
    and the southern edge of the 1002 area? Mention of traditional
    Dall sheep range characteristics has no relevancy to the
    purposes of this report.

    Page 31, Wolves. This section has no substantive value. using
    a density estimate reported by bilogist Mech is invalid for the
    Arctic Coastal Plain. To see a Wolf in the 1002 area would be
    an absolute rarity. A partial reason for wolf ( and Wolverine)
    scarcity along the coastal fringe is their vulnerability to
    Native hunters using snowmachines. Some life history material
    here is not relevant to report requirements.

    Page 31, Arctic Foxes, has no substantive value. Ideally, it
    would be useful to show density estimates for the 1002 area
    during year of low, moderate, and high levels of abundance, but
    evidently this was not an objective of the baseline studies
    unfortunately.

    Mr. William p. Horn				Page 4
    January 26, 1987

    Page 31, Wolverines. It is utterly ridiculous to use density
    figures reported by Magoun ( an unexploited wolverine population
    in the mounainous foothill habitats of the petroleum Reserve)
    as a basis to estimate a heavily exploited wolverine population
    occupying flat open terrain of the coastal plain. Wolverine,
    like wolves, would expectedly be as scarce as hen's teeth here
    during the optimum observation period of winter. How many
    wolverines were observed when they scavenged caribou during May
    and June, and in June and July when they preyed on birds and
    eggs as reported? Do ADF&G pelt sealing records reveal the
    locations wolverines were actually taken?

    Page 32, Brown Bears. This section has substantive content and
    thsi, along with the caribou presentation, serves as a baseline
    information model that should be used to report other mammals of
    socioeconomic significance.

    page 32, Arctic Ground squirrels and other Rodents. This
    section contains life history information of little importance
    to the report's purposes. Ground squirrel density estimates
    should have been obtained during periods of low, moderate, and
    high levels of population abundance. In the absence of such
    information, thsi section should merely describe species present
    and a statement to the effect that arctic rodent populations
    exhibit cyclic fluctuations.

    Page 39, Subsistence use. With reference to the second
    paragraph statement that, "aside from Kaktovik, Villages
    dependent upon PCM caribou are considered only generally."
    appears to be overly simplistic. Arctic village and old crow,
    for example, may have a greater need of PCM caribou than
    Kaktovik residents who have greater access to marine and fish
    resources.

    Page 41, last paragraph, with reference to whaling, lead
    sentences are confusing. What is meant by "historic period?"

    Page 45, Recreation. This section contains little quantified
    information on recreational use of the 1002 area. If there is
    an explanation for not having conducted a recreational use
    survey during the FIve-year study period, it should be presented
    in this section.

    Wilderness and Esthetics. This section does not provide enough
    descriptive background to adequately inform the reader about
    wilderness qualities. Are abandoned DEW-line sites part of the
    wildland environa or deemed to be obtrusive and in conflict with
    wilderness classification? We find this section
    scant--considering the importance of wildland resources relative
    to the implications of oil and gas leasing.

                                Mr. William P. Horn                                             Page 5                                            Mr. William 11. Horn                                             Page 6
                                January 26, 1987                                                                                                  January 26. 1987

                                Page 46. first paragraph, reference the statement that the                                                        Pages   97-98,   Chapter    TV,   Environments  1   Consequences.     in
                                entire   1002   area   could meet     the  criteria.     We    suggest,                                           reference to FWS mitigation policy, this bureaucratic         verbosity
                                truthfullyo that thi -word "does" should be used in place of                                                      does little to improve the quality of this report nor the
                                "could.                                                                                                           reputation of the FWS.       If It comes to employing mitigation
                                                                                                                                                  measures, It would seem necessary to consider steps to minimize
                                Chapter III, Assessment of Oil and Gas Potential and Petroleum                                                    degradation of the wildland resource which, after all, Is a
                                Geology of the   100, Area points to disproportionate reporting of                                                prime factor for originally designating the Arctic Range.            The
                                assessed resources.    This IS a WIldlife refuge. not a petroleum                                                 habitat resource categories may fit a typical refuge, but the
                                reserve. As drafted, the oil and gas potential was described in                                                   Arctic    Refuge's     wildland     uniqueness     warrants      special
                                24 pages of a single chapter compared to 11 pages and sectional                                                   consideration.
                                treatment of fish and wildlife resources.
                                                                                                                                                  Page 99, Alternative A, reference the environmental effects of
                                Page 50, Significant Findings and Perspectives.         This section,                                             Ice roads and airstrips, and reported nil effects on arctic
                                reference Figure 111-2, contradicts the proposition that the                                                      tundra, is without scientific basis. . Repeated use of ice
                                1002 area is the "most outstanding prospect in the USA."            This                                          structures   alters    the microclimate and prolonged physical
                                figure compares estimated recoverable reserves with proven                                                        changes would indeed effect tundra ecology. A number of studies
                                fields.   Recoverable amounts (952) depleted are far below that                                                   relative to motorized equipment and fee road use support this
                                of largest known fields.                                                                                          thesis.   Scars left by the "Hickel Highway" (ice road used to
                                                                                                                                                  freight supplies to Prudhoe Bay during Bickel's administration
                                Page 54. in reference to the statement that "exploratory                                                          as governor of Alaska) are still much In evidence today.
                                drilling would resolve the questionable presence of Ledge
                                Sandstone rocks, as an indicator of oil deposit," it appears to                                                   Pages 104-105, Sadlerochit Special Spring Area, in reference to
                                conflict with the full leasing recommendation In lieu of the                                                      use of water, the beat mitigation measure In this special case
                                further exploratory drilling alternative.                                                                         would be avoidance.     Under no circumstances must water removal
                                                                                                                                                  be allowed. The statement that "full leasing. and implied use
                                Page 91, Chapter V, Alternatives. The statement in reference to                                                   of spring water. would have negligible effect on this special
                                not leasing or developing tFe--"traditional core calving area"                                                    area" Is an absurdity.
                                merits an explanation as to why this exclusion Instead of the
                                "concentrated     calving"    area.     The    use    of   the     terms                                          P g   108, reference next to the last paragraph. on effects of
                                "concentrated" and "core" to confusing. Plates (maps) contained                                                   IMIng the 1002 area on caribou calving.            According to this
                                in the report envelope are difficult to Interpret. We suggest                                                     report, the Interior Department's recommendation blatantly
                                clearly delineating the peripheral boundaries of the traditional                                                  violates FWS mitigation policy.       The loss of existing habitat
                                core and concentrated calving areas on these maps.                                                                value conflicts with the purpose of refuge establishment and
                                                                                                                                                  flaunts congressional management and conservation mandates.
                                Page 93. reference to comprehensive conservation planning (CCP)
                                process in second paragraph, It is prudent to include the 1002                                                    Page t1lo Mitigation section, In reference to measure numbers 8
                                area, "the most biologically productive part of the refuge," in                                                   and 9 whereby hard size would be monitored toward determining
                                the ongoing CCP effort for obvious reasons.          Again, this to a                                             adverse effects of leasing, should notbe viewed as a mitigative
                                refuge, not an all reserve, and Congress must render a decision                                                   measure unto Itself.      This is a procedural activity and not
                                an both the Interior Department's 1002 report recommendation and                                                  mitigative by definition.       Annual surveys are standard refuge
                                the "preferred alternative" advanced by CCP document for the                                                      and state game management practices.         Other measures reported
                                Arctic Refuge.       If the     1002 area     leasing recommendation                                              are too general and nebulous to be as definitive as this section
                                prevails. what    management category, i.e., intensive, minimum,                                                  should be for a decialon-making document.
                                and traditional, will apply to the 1002 area?
                                                                                                                                                  Pages 114-125, concerning conclusive effects on major species*
                                Page 94. reference to ANILCA, Section tOlO, implies use of                                                        are misleading,     Incomplete. and Incorrect.         Alterations of
                                motorized equipment throughout the entire refuge when, In fact,                                                   habitats, particularly in productive riparian zones associated
                                this section applies only to the most southerly part of the                                                       with development and water removal. would have substantial
                                refuge.     Impartial or distorted       reporting of     this nature                                             effects on moose and other wildlife.           Increased hunting and
                                reflects negatively on agency credibility.                                                                        sportsfishing    pressure    would   have   an   adverse    effect    on
                                                                                                                                                  population composition and productivity. To say that regulatory

                                  Mr. William P. Horn                                        Page 7
                                  January.26. 1987

                                  adjustments could be made to offset use effects           Is too
                                  simplistic and Irrational considering that the regulating
                                  mechanism to already overburdened and stressed from addressing
                                  regulatory problems In the more accessible parts of Alaska, let
                                  alone the remote Arctic.  Intelligent conclusions are difficult
                                  to draw In light of the superficial baseline studies pertaining
                                  to wolves, Arctic fox, and wolverine.        Major declines In
                                  respective populations and brown bears can be anticipated. The
                                  statements that "brown bears are not readily displaced by human
                                  activities" and '"bears along the TAPS corridor became habituated
                                  to development" are absolute absurdities. As a wilderness
                                  critter. brown bears are readily df      ced by human activity.
                                  .Immature             -FaWTry-grup:p!%
                                                                          . I it
                                           and yearling                      b  . a proclivity to
                                  habituate human developments, but this should not be construed'
                                  to mean all brown bears react accordingly.            Black beer
                                  habituation poses a different problem. The lose of immature and
                                  family group brown bears, either through habituation or natural
                                  mortality factors, Is. a normal aspect of population ecology.
                                  Other population components. mature sales and females, females
                                  with young of the year, and many subadult.boars will be affected
                                  by leasing developments.   The conclusion dispelling the Impact
                                  on fish does not recognize the effect of water removal.

                                  We could elaborate further upon this report. but quite candidly,
                                  the quality of this report should reflect the ability of the
                                  authors rather than the comprehensive Input of Its reviewers.
                                  Considering the time, personnel, and funds allocated for the
                                  1002 assessment study, we who understand what's going on and
                                  what may happen have every reason to be disappointed with the
                                  Interior Department's recommendation and the myopic manner In
                                  which it was formulated.

                                  St   0.   ours.

                                  Richard J.  noel
                                  Alaska Representatives

                                  "H*nw
                                  .33C/160a
                            4
                                  S         our
                                  RI:cha,ed akn. 1

    	ANIMAL
    	PROTECTION
    	INSTITUTE
    	OF AMERICA

    6130 Freeport boulevard
    po box 22505
    sacramento, ca 95822
    (916) 422-1921
    TWX 910 387 2375 API SAC

    January 23, 1987

    U.S. Fish and Wildlife Service
    Attn: Division of Refuge Management
    2343 Main Interior Building
    18th and C streets, N.W.
    Washington, dc 20240

    	The Animal Protection Institute requests that the
    following comments on the Arctic National Wildlife Refuge
    Draft Coast Plain Resource Assessment be entered into
    the hearing record and addressed more fully in preparing
    the final plan. Having read the assessment, we are
    opposed to oil and gas development in the areas of the
    Arctic National Wildlife Refuge (ANWR) as proposed by
    section 1002 of the Alaska National Interest Lands
    Conservation Act (ANILCA).

    	The Department of the Interior's selection of
    Alaternative A- "Full lesin gof the 1002 area"-
    completely ignores the findings of the U.S. Fish and
    Wildlife service that a long-term commitment to oil and
    gas development, production, and transportation would
    inveitably result in long-term losses in fish and wildlife
    resources, subsistence uses, and wilderness values.

    	The report minimizes the impact of development on
    the Porcupine caribou herd with the statement that the
    TAPS pipeline has had "minimal impact on wildlife
    resources" and projects this conclusion to the circum-
    stances surrounding the Porcupine herd. We believe that
    this is not a valid assumption, since the Central Arctic
    caribou herd does not migrate from a winter range to  a
    coastal calving ground as does the Porcupine herd. The
    density of calving caribou on the POrcupine calving grounds
    is 14 times greater than the density of calving caribou
    					continued . . .

    U.S. Fish & Wildlife Service      -2-      January 22, 1987

    on the Central Arctic herd's calving grounds.

    	In light of the reported displacement of calving
    Central Arctic caribou resulting from oil development
    at Prudhoe Bay (1), it is reasonable to expect that not
    only will displacement of calving occur on the ANWR,
    but that displacement will be more severe due to the
    increased density of caribou on the ANWR calving grounds
    This is alluded to by the statement of page 112 of the
    report which says (in reference to calving Porcupine
    caribou), "Given the geography of the calving areas and
    the current densities in those areas, the availability
    of suitable alternative habitats is not apparent." Clearly
    if calving caribou are displaced, they will be displaced
    to habitat not conducive to successful calving which
    would result in a population decline for the Porcupine
    herd.

    	Immediately after calving, herds of caribou cows
    and claves form in the area south of camden Bay ( a Pro-
    posed drilling site). These herds move constantly to
    forage and find habitat providing shelter from the
    millions of mosquitos which hatched around calving time.
    Mosquitos are a major cause of calf mortality. It has been
    demonstrated (curatolo and murphy, 1983) that mosquito-
    harassed caribou herds do not readily cross under elevated
    pipelines. The development of main and subsidiary pipelines
    south of camden Bay would provide an additional sterss on
    the caribou at a time when it could not be tolerated, e.g.
    when newborn calves and their mothers have the lowest
    energy reserves of the year. We believe this would
    magnify the effect of calving displacement and lead to
    further decreases in the size of the porcupine herd.

    	The interior Department's rcommendation also ignores
    the USFWS finding that muskoxen- a species successfully
    reintroduced to the Arctic Refuge- could be affected
    adversely by the destruction of habitat values on nearly
    75 percent of the areas heavily used for calving. A de-
    crease in the productivity of muskoxen, due to displacement
    of calving activity, appears to be in direct opposition
    to the ANWR's stated goal of encouraging a healthy growth
    of the muskoxen population.

    	As reported by USFWS biologists in the assessment,
    other wildlife species (vertebrate and invertebrate) and
    native plant species will be impacted, some to a greater
    degree than others, but all will be adversely affected
    by direct oil and gas developemnt, auxiliary activities,
    and possible contamination from spills and leakages. To

                     U. S. Fish   Wildlife Service      -3-      January 22, 1987

                     disrupt critical breeding areas of caribou, muskoxen, and
                     waterfowl, among other wildlife, in order to recover an
                     unsubstantiated amount of oil when producing wells are
                     currently being capped throughout the United States, pro@
                     vides a weak argument for the full or partial leasing of
                     the ANWR at this time. Equally nonsensical is the practice
                     of promoting oil drilling on the North Slope based on
                     current and future consumption estimates, while at the
                     present energy conservation programs are tossed aside
                     in favor of more consumptive choices.

                          The Animal ProtectionInstitute of America takes a
                     firm position in believing that opening the Arctic
                     National Wildlife Refuge to oil and gas exploration will
                     set a precedent to opening other refuges and wilderness
                     lands to exploitation detrimental to the health of native
                     plant and animal species and is in direct conflict with
                     the goals of the Department of the Interior and its
                     divisions to protect and preserve these species as national
                     treasures and for the benefit of the people of the United
                     States and-future generations.

                          We recommend that the Secretary of Interior designate
                     the Arctic National Wildlife Refuge as a wilderness area.

                     Most sincerely,

                     Catherine A. Smith
                     East Coast Regional Director
                     Animal Protection Institute of America
                     1755 Massachusetts Ave., N.W.
                     Suite 418
                     Washington, DC 20036

                     CAS/bms

                                                                                                                                  refuge in a manner consistent with the purposes for which it was
         ARCTIC AUDUBON SOCIETY                                                                                                   established, the conservation of unique wildlife and wilderness values.
                              P.O. BOX 82098
                         COLLEGE. ALASKA 99708
                                                                                                                                  Arctic Audubon f inds the report profoundly f )awed. There are numerous
                                                                                                                                  errors in scientif Ic detail and there are illustrations of bad faith in the
                U.S. Fish and Wildlife Service                                                                                    execution of the process. The following comments, while not totally
                       Ivislon of Refuge management                                                                               inclusive of all objectional assumptions and items, summarize our
                Attrt D                                                                                                           response to the " 1002 report.'
                2343 Main Interior Building
                I 8th and C Streets, NW
                Washington, DC 20240                                                                                              PRECONCEPTIONS AND Elf AS
                                                                     January 30, 198                                              It should be kept in mind that it required a lawsuit by several Alaskan
                Dear U.S. Fish and Wildlife Service.                                                                              environmental organizations to make the FWS '1002 report' available to
                                                                                                                                  the public and open to public comment. Although court action required
                The Arctic Audubon Chapter of the National Audubon Society Is pleased to                                          pub] Ic hearings and time for public comment, FWS held hearings in only
                respond to the U.S. Fish and Wildlife Service's (hereafter FWS) Report and                                        two Alaskan locations, Anchorage and Kaktovik. This omitted two critical
                Recommendation to the Congress Of the United States regarding the future                                          locations for hearings: Arctic Village, a Native village south of the
                management of the coastal plain area of the Arctic National Wildlife                                              Arctic Refuge which will certainly feel Impacts from any decision
         9      Refuge (Arctic Refuge). Arctic Audubon, with a membership of 320                                                  regarding its resources, and Fairbanks. the hometown of one of the
                residents, recently -adopted" the Arctic Refuge as part Of the National                                           organizations originally requesting hearings. Fairbanks Is the       I
                Audubon Society's 'Adopt-A-Refuge program. This reflects the special                                              northernmost urban area In Alaska and Is the home of thousands of
                Interest of chapter members In the Refuge and it commits us to active                                             citizens with interest in the future of the Arctic Refuge. Arctic Audubon
                service toward wise and benevolent stewardship for the Refuge.                                                    had to allocate membership dues for plane fare to have our organization
                                                                                                                                  represented at the Anchorage hearings, as did other smai I, nonprof it
                The FWS Report and Recommendation to congress, which Is a resource                                                organizations.
                assessment of 1.55 million acres of coastal plain within the Arctic Refuge                                        Furthermore, the two hearings were held during the first week of January
                and a recommendation for management Policy, was mandated by Section                                               close on the heels of Christmas and New Years during which many people
                1002 of the 1980 Alaska National Interests Lands Conservation Act                                                 are out of down, and decidedly inconvenient for those of us who remained.
                (ANILCA). The .1002 areaC (that part of the Arctic Refuge defined as the                                          And.finally, the period for public comment was originally only 60 days as
                .coastal pIaln7 by Section 1002(b) of ANILCA) required special treatment,
                independent from the Comprehensive Conservation Management Plan                                                   compared with a more usual 90 day comment period, and was extended by
                process for the rest of the* Refuge, due to Congressional hesitation to act                                       two weeks only after the request of the Governor of Alaska.
                on this part of the refuge wittast accurate and adequate information                                              This peculiar timing and haste on the part of FWS is attributed by agency
                regarding both the oil and gas potential of the area and the wildlife and                                         personnel to the fact that the report was late and they were hurried.
                wilderness values. To gather coi..PrehenSive Information, to provde it to                                         However, the report was more than three months past deadline already.
                Congress In comprehensible and useful terms, and to recommend                                                     The decision to make up time lost by government personnel, at the expense
                management policy for the area based on this data, was the point of the                                           of public comment on what is by law a public process. seriously calls into
                report.                                                                                                           question agency regard for citizen input.
                In brief, we disagree with-the Executive Summary Of the 1002 report and                                           In addition to the above difficulties, the report itself contains many
                bellve that the Arctic Refuge is best managed under Alternative E. with                                           subtle indications of bias toward industrial development of the Arctic
                wilderness designation. This is the best way to permanently protect the                                           Refuge. These include:

                        Oanguage patterns favoring development, i.e., on page 84 and
                           with Increasing frequency thereafter, "will" instead of                                                                    "Analyses of different rock units throughout northeastern
                           .would" is used when describing oil development, thus                                                                      Alaska (-location of the Arctic Refuge) indicates that the
                           strengthening the assumption of this eventuality;                                                                          Shublik Formation, Kingak shale, pebble shale unit, Hue Shale.
                                                                                                                                                      and shales in the Canning Formation may be potential oil or
                         b)very tentative language when discussing wilderness values,                                                                 gas source rocks. The f irst three units are considered to be
                           i.e., page 131 states, "Most recreationists     might perceive                                                             the source for the oil in the Prudhoe Bay !leld.' (p. 62)
                           the existence of oil facilities in the area as lessening the
                           qual I ty of that experience.' We think *would' Is more accurate                                              Counter-
                           than "might'.-                                                                                                   point:    'Analysis of the oils from seeps and stained outcrops in or
                                                                                                                                                      adjacent to the 1002 area. and of the different potential
                         Othe disproportionate discussion of oi I and gas values (24                                                                  source rocks, suggests that the Hue Shale is the most I ikely
                           pages) when compared to the discussion of wildlife values 0 1                                                              source rock In the 1002 area. None of the sampled oi Is are
                           pages) and to the startlingly cursory discussion of wilderness                                                             similar to Prudhoe Bay oil.' (p.62)
                           values (five paragraphs).                                                                                                  "in addition, the distribution of the Shubl lk and Kingak is not
                                                                                                                                                      known, and because of the pre-pebble shale erosion, these
                                                                                                                                                      rocks may not be present in much of the 1002 area." (p.62)
                COWA351% AND CONTRADICTORY PRESENTATION OF EVIDEKE
                                                                                                                                                      "if most of the Ellesmerlan rocks are missing in most of the
                More Important than a suspect process and some questionable overtones to                                                              1002 area, the assessment number would be reduced consid-
                the text, however, is the       fusing and oftentimes misleading manner in                                                            erably.' (p.54)
                which the scientific resez;7c@ and data are presented. The confusion Is so                                                            'Well control west of the 1002 area and seismic data indicate
                extreme that the report contains numerous contradictory statements and
                conclusions on pivotal Issues. Some examples, which do not exhaust the                                                                that most of the Ellesmerlan sequence Is missing in the
                list which has been culled from the report, follow:                                                                                   northwestern quadrant of the 1002 area, but seismic data
                                                                                                                                                      suggests that a significant part of the sequence may be pre-
                   a) By discussing the oil-bearing geology of the Prudhoe Bay area                                                                   sent in the eastern part of the area.- (p.54)
                     and by noting the proximity of the Arctic Refuge area to Prudhoe,                                                                "Such fault.-bounded blocks [as the Ellesmerian rocks) are
                     the report suggests that the geology of the 1002 area is similarly,
                     significantly oil-bearing. The evidence Isconfused                                                                               well known in the Prudhoe Bay area, but have not been identi-
                     Pointo 'All of the oil production In the Prudhoe Bay-Kuparak River                                                               f led thus far on the seismic data in the 1002 area.' (. p. 67)
                              field areas Is from rocks of the Ellesmerlan sequence.' (p.54)                                           These confusing and contradictory statements attest        .to the wisdom of the
                              "The Ledge Member [of the Ellesmerian sequence) ... Is the main                                          suggestion on page 54 'If most of the Ellesmerian rocks are missing In
                              producing reservior at the Prudhoe Bay field" (. p. 56)                                                  most of the 1002 area, the assessment number would be reduced
                                                                                                                                       considerably. Drilling one or two wells In critical areas would resolve
                              "The Shublik (shale, of the Ellesmerian sequence] Is consid-                                             this auestion." But these statements could not support the conclusion on
                              ered to be an Important oil-source rock for Prudhoe Bay oi L"                                            page SO: ' The 1002 area Is clearly one of the most outstanding prospec-
                              (p.56)                                                                                                   tive oil and gas areas remaining in the United States* since the evidence
                                                                                                                                       of what it may contain is unclear.
                              "Parts of the Kingak [shale, of the Ellesmerian sequence) are
                              thought to contain enough organic matter to be a source rock
                              for some of the Prudhoe Bay oil and gas.* (p.56)

                It should be remembered that the whole discussion is within the context                                             "Analogies comparing the ef fects of current oil development on the Central
                of an 819 chanre that no oil will be located at aU, letalonethe5x                                                   Arctic Herd and effects of potential 1002 area development on the
                conditional probability that, if any oil at all Is found, it will be of the                                         Porcupine Caribou Herd must be &awn with caution.-the PCH would
                Prudhoe Bay field size. The computation of conditional probability puts                                             interact with oil development much more extensively and intensively than
                the liklihood of a large oil rind, realistically, In the arena of 1%.                                               the CAH has interacted with oil development in the Prudhoe Bay area.-

                Regarding consideration of gas as a potential resource in the 1002 area,                                            The discussion of mitigation measures beginning on page I 11, which
                the conclusion above appears to be directly contradicted by a passage                                               admits that Resource Category I (no loss of habitat) is impossible should
                from the same page. 'Gas was not included in the calculation of                                                     oil development take place, concludes that even with the mitigating
                economically recoverable resources. Gas resources are unlikely to be                                                stipulations, the population decline and change in distribution could be
                economic at any point in the time period being considered."                                                         as severe as from 20-402 of the Porcupine Herd (Paragraph 3, page 1121-
                                                                                                                                    also summarized on page 144). In the same paragraph on page 1         12, the
                                                                                                                                    report states that the estimate is uncertain, due to the many variables
                11. On page 50, the bar graph at Figure 111-2 compares the estimated                                                Involved, the lack of experience with this herd, and the difficulty in
                recoverable reserves of oil on the Arctic Refuge with those of proven                                               quantifying impacts.
                fields. For all possible prospects on the refuge, the most likely estimates
                are well below most of the largest known f lelds. Yet the paragraph at the                                          The significance of this projection for the Porcupine Herd Is not so much
                top right of the page (cited above) concludes that the area Is one of the                                           the figures themselves as another consideration: the Baseline Study
                most outstanding prospects in the United States. This conclusion does not                                           reports for the Arctic National Wildl   'Ire Refuge, required by Section 1002
         9      follow from the graph on which it is supposedly based Rather, the graph                                             (c) of ANILCA, and upon which much of the wildlife data for the coastal
         -L     indicates that there is a 95X chance to the contrary. The use of this                                               plain report was to have been based, was not made f Inal and distributed
         -4
         0      bar graph and the statistics it claims to show are confusing and                                                    until the third week in January. It is difficult to make or evaluate
                misleading.                                                                                                         population projections at all, and especially so without access to baseline
                                                                                                                                    studies. It is unclear how this projection of a possible 20-40Z herd
                                                                                                                                    reduction or dislocation was computed, and without clarity on this point,
              - Ill. Similarly, the statistical chart on page 50 (Table Ill- 1) Is ambiguous                                        the f igure is worse than uncertain, it Is meaningless. The impact of oil
                and potentially misleading. The caption states that the "figures do not                                             development on the Porcupine Caribou Herd could be significantly less than
                ref lect the risk that economically recoverable oil resources may not                                               the 20-40% figure or it could be several t Imes more severe.
                exist in the planning area." Does this mean that the risk (This refers to
                the 8 1 X chance that there Is no economically recoverable oil in the 1002                                           Nowhere In the 1002 report is it acknowledged that projections of
                area at. all, as discussed in the report.)  Is not calculated In to the figures                                     wildlife populations and the impacts upon them by industrial development
                presented for the 1002 area, or that the same risk is not calculated Into                                           are wildly unpredictable, and therefore, that suggested mitigation
                the figures for all areas being compared? If the former is true, thecom-                                            measures are merely theoretical constructs.
                parison ( the point of this chart) is Invalid. if the latter is true, all
                relevant data (the conditional risks for the other areas) Is not provided
                and the comparison is useless. Either invalid or incomplete, the
                'data* presented are confusing.                                                                                      V. The narrative discussion of the contribution that the possible 1002
                                                                                                                                    area oil would make toward reducing national dependence on imported
                                                                                                                                    oil states,
                IV. A paragraph on page 106 discusses that studies have noted an increase                                                 "Production of oil from the 1002 can also help achieve this
                In the Central Arctic Caribou Herd since the Prudhoe Bay oil f ield has been                                              Nation's national economic and security objectives..." and
                developed in their area. (Oil industry documents make frequent use of this
                fact.) However, the report correctly states on the same page that,

                    'Thus, the 1002 area's oil may be able to significantly reduce
                    the economy's vulnerability to world oil market changes.' (p. 164)                                            VII.The discussion of Alternative B includes the statement that the impact
                    and                                                                                                           of this alternative on the muskox population would be the same as under
                                                                                                                                  Alternative A (p. 134). Impacts of Alternative A are considered to be
                    ,'In summary, the 1002 area has a very significant potential to con-                                          .maior , with the possibility that the animals would be displaced from
                    tribute to the national need for oil." (p. 166)                                                               7 1 X of their high-use, year-round habitat (p. 114). Yet, the discussion of
                                                                                                                                  Alternative 8 and muskox concludes with, 'Therefore, effects of limited
                                                                                                                                  development would be moderate - (p. 134) These statements are
              However, the data which support these statements is presented in Table                                              inconsistent. Would the impact be major or moderate ?
              VI 1 -2 (p. 162) and the data there are unclear. Do these figures reflect the
              ,conditional probability regarding whether oil will be found in the 1002
              area at all? If not, they are misleading. If so, do they reflect the high,
              optimistic projections of potential oil reserves? Or do they reflect the                                            VIII.A f inal example of confusing and incomplete data follows: the report
              lower. conservative projections? Without this Information, the use                                                  states that one exploratory well would require as much as 15 million
              of the statistics as evidence for anything is ridiculous. The presentation                                          gallons of water (p. 76). The report also states,
              of data is confusing and Irresponsible.
                                                                                                                                         Specific locations and sources of water and gravel
                                                                                                                                         for exploration and development activities have not
              V1. In the discussion of Alternative A and the Impacts of this alternative                                                 been identified; and it is understood that these re-
              on recreational uses of the areas. the report states that some hunted and                                                  sources. especially water, are not readily available
      9       trapped species might be displaced, thus lessening opportunities for these                                                 on the 1002 area (p. 75).
      -       activites. The report contirmes,
      -4
                                                                                                                                  The report refers to this absence of the necessary water and gravel
                    'Because much of that displacement would be from the area                                                     as an "engineering problem' (p. 76) but does not address that it is
                    in which firearms could not be discharged and access would                                                    poses tremendous economic and environmental problems also. The report
                    be restricted, the net effect on hunters would be negligible.'                                                suggests possible scenarios which might locate     .a suitable water source"
                    (p. 13 1                                                                                                      but It does not settle on one solution over the others.

              The report writer has neglected to consider that "firearms could not be                                             This omission calls Into guestion all proiections of economically
              discharged and access would be restricted* when he concludes that the                                               recoverable oil since apparently the cost of 'the ma-lor engineering
              impact on hunting will be negligible. On the contrary, It appears that                                              problemm (D. 76) is not computed Into the formula. Further- It calls into
              hunting would be prohibited. Where? Over how much of the 1002 area?                                                 guestion all assessments of imaDcts on wildlife and habitat since the
              Within all private lease holdings?                                                                                  report does not discuss answers about where the 15 million gallons of
                                                                                                                                  water per wel I w I I I come from.
              It Is Important to recall that although wilderness status and other
              conservation designations are charged with the alledged unfairness of a
              land "lock up', there is no greater 'lock up' than private ownership or                                             These are but a few examples, some critically important and some less so,
              private management which precludes public access.                                                                   of contradictory statements within the report and of the confused
                                                                                                                                  presentation of data and evidence. They suggest that the report was
              The statement regarding negligible impacts on hunting is misleading and                                             prepared with haste that jeopardizes its validity or that conclusions were
              is contradicted in the very paragraph which contains it.                                                            drawn on the basis of something other than the research provided.
                                                                                                                                  Nowhere is this more graphically illustrated than by the following
                                                                                                                                  statements, when compared with the whole conclusion drawn by the
                                                                                                                                  report:

                     "If most of the Ellesmerian rocks are missing from most
                     of the 1002 area, the assessment number would be greatly                                                     INCOMPLETE COVERAGE
                     reduced Drilling oneor two wells In critical areas would
                     resolve this question.' (p. 54)                                                                              In addition to the biased overtones and in addition to confused and contra-
                                                                                                                                  dictory presentation of evidence, there is a third major area of concern
                     'Only actual exploration can provide the information                                                         about the '1002 report." This is the vacuum within which it seems to have
                     needed to determine the extent and distribution of the resources,                                            been written and the lack of information provided to Congress regarding
                     and, therefore, the potential benefit to the econorny.* (p. 166)                                             numerous relevant contexts. For example, the report:

             In the face of such clear recornmendat Ions in the text. the numerous                                                1. leaves out discussion of the fact that pro-development and
                     IIons of inadequate evidence and uncertain projections, much                                                    pro-conservation interests have negotiated extensively on
             confused data, and the option of a Management Alternative (Alternative Q                                                Alaska's north slope acres already with the result that almost 90 per
             which would respond explicitly to all three, the Interior Secretary's                                                   cent of the slope is open to oil and gas leasingL The expansion of the
             Recommendation is drafted Instead in support of Alternative A, the full                                                 Arctic Refuge in 1980 (ANILCA) was a compromise position which
             leasing to private development Interests of the whole 1002 area. Why?                                                   reserved only 2 million acres of the North Slope for conservation. The
                                                                                                                                     - 1002 report* should make this context clear and perhaps would have,
             The report says clearly,                                                                                                had it not skimmed so rapidly over the legislative history of the area
                     "The Arctic Refuge is the only conservation system unit that                                                    and the background of Congressional Intent.
                     protects, in an undisturbed condition, a complete spectrum of
                     the various arctic ecosystems In North America.' (p. 45)                                                     2. leaves out discussion of impacts on f ish and wildlife habitat from oil
      I?                                                                                                                             and gas development within the 1002 area, given that the rest of the
       L     and. *The 1002 area Is the most biologically productive part of the                                                     coastal plain is already available for gevelopment. Le:,thereport
      rl             Arctic Refuge for wildlife and Is the center of wildlife activity                                               suggests that the population decline and change in distribution of the
                     on the refuge." (p.46)                                                                                          Porcupine Caribou Herd could be as great as 20-40X, but this assurnes
                                                                                                                                     there is remaining, similar, adjacent habitat for the animals to
             Despite these outstanding natural values and the acknowledgement of                                                     relocate to. Similarly, the report suggests that the muskox
             the serious, deleterious effects on them from Industrial development,                                                   population could be displaced from 719 of their high-use, year-round
             ("Oil and gas development will result In wide-spread, long-term changes in                                              habitat, and the assumption is that they would go somewhere else.
             wildlife habitats, wilderness environment, and Native community                                                         Since the Arctic Refuge is the sole remaining land area on the north
             activites.' p.6) the Department of Interior recommends full leasing.                                                    slope protected from oil and gas development, the report should have
             The recommendation is supposedly on the basis of the '1002 report"                                                      analysed Impacts on wildlife given that the rest of the plain mgy also
             the body of which, In fact, explicity recommends that more information is                                               be developed.
             needed before we really know what oil potential exists.                                                              3. leaves out discussion of the additional 24 million acres of nearshore
                                                                                                                                     (state) and offshore (federal OCS) lands available In the adjacent
             The SecretaU's recommendation is inconsistent with the data presented                                                   Beaufort Sea for oil and gas leasing. The current activity in this area,
             by the Fish and Wildlife Service and there Is no rationale provided for the                                             from the amounts of of I and gas available and amounts produced to
             radically developMent-oriented recommendation made by the                                                               impacts on north slope and offshore wildlife and habitat is pertinent
             report.                                                                                                                 to decisions regarding the 1002 area.

                                                                                                                                  4. leaves out discussion of the oil resources available within the National
                                                                                                                                     Petroleum Reserve-Alaska , the 37,000 square mile reserve
                                                                                                                                     established by the Federal Government In 1923 due to its high oil
                                                                                                                                     potential. This national resource was specifically set aside to be

                explored and developed In time of national need, but despite charts In
                the 1002 report which graph the alledged scarcity of reserves, this                                           It. leaves out discussion of wilderness, for all practical purposes. The
                area( In as close proximity on the west to the Prudhoe Bay field as the                                          report Includes five short paragraphs about potential wilderness
                Arctic Refuge Is on the east) Is omitted                                                                         status for the 1002 area, but neglects to mention the two formal
                                                                                                                                 wilderness studies that have been conducted for the 1002 area,
             5. despite the many claims regarding our national need for petroleum                                                Including the USFWS (1973) study for the entire wildlife range and
                resources, the report leaves out discussion of the 1986 National                                                 a second study (Thayer, 1982) conducted on the 1002 area specifically.
                Appliance Energy Act. This legislation would love provided a no-risk,                                            Both studies found the 1002 area especially suitable for wilderness
                certain savings of millions of barrels of oil (not to mention billions of                                        status, but none of this Information Is reflected In the five paragraphs
                dollars on utility bills) which would have made development of the                                               of the present 1002 report which address wilderness.
                Arctic Refuge unnecessary. Passed overwhelmingly by both houses of
                Congress, President Reagan vetoed this bill. He has also opposed                                                 The omission of a thorough wilderness review, which was mandated
                the establishment of fuel efficiency standards for automobiles and                                               by ANILCA Section 1317 Ic  ')r all nonwilderness lands In the national
                the continuance of the 55 mile/hour speed limit. Claims by the Depart-                                           parks and national wildlife refuges, Is egregious. Furthermore,
                ment of Interior that the notion needs new oil loose their teeth when                                            wilderness review for the 1002 area Is specifically required by ANILCA
                the Administration acts as If the nation doesff t. This and other similar                                        Section 1004 as well. Wilderness status for the 1002 area Is not being
                energy-saving plans should have been discussed In Chapter VI I: National                                         addressed In the Arctic Refuge Comprehensive Conservation Planning
                Need f or Domestic Sources.                                                                                      process because that process explicitly excludes the 1002 area. But
                leaves out discussion of the politically sensitive and highly secretive                                          the 1002 planning process has also shunned the wilderness review
                proposed land swaps between the federal goverment and Native                                                     required by law. .
                corporations wl,'--mk,, I.-&. within 'LhV- 1002 are to be traded into
                private ownership. Clearly, private Inholdings In the area affect
                management plans, and these very controversial swaps are germane to                                           RECOtMNOATION TO THE DEP
                the 1002 report. The swaps themselves undermine directives to DOI In
                ANILCA, and the lack of discussion regarding them In the 1002 report                                          Although, as Indicated above, a reasonable conclusion from the text of the
                underynines the Integrity of the report.                                                                      1002 report as It Is now written would be Alternative C, the report has
                                                                                                                              serious omissions and blased emphases. Signif Icantly, it failed to
             7. leaves out discussion of Chevron's test well drilled within the coastal                                       adequately address the Public Land Order which created the Arctic
                plain (on private land) which produced significant Information about                                          National Wildlife Range In 1960 and the purpose of that land stated there:
                the potential for oil and gas In the area These proprietary data are                                          'to preserve  unique wildlife, wilderness and recreational values.' In
                available to only a few. Even the existence of these data, however,                                           1980 when the passage of ANILCA changed the Arctic Range to the Arctic
                was omitted from the report.                                                                                  Refuge. the following explicit and primary purposes'were added to the
             IL leaves out discussion of research on environmental Impacts of     .the                                        management directivd:
                Prudhoe Bay development on air and water quality, which would be                                              Lto conserve f Ish and wildlife populations and habitats in their natural
                extremely Important Information for any similar Industrial                                                    diversity;
                development In similar country. Additional research and Impact studies
                on wildlife populations, many of which were conducted within the                                              2.to help the United States fulf III Its International treaty obligations;
                boundaries of the 1002 area and done by FWS staff, were not reviewed
                In preparation of the report. A partial listing of pertinent studies                                          3.to provide opportunities for continued subsistence uses by local
                on arctic oil development Impacts Is attached to this letter as                                               residents; and
                Appendix A.
                                                                                                                              4 to ensure the water quantity and quality of the natural area.

            There is no interpretation of the 1002 report which does not admit to                                          References cited:
            the fact that oil and gas exploration and development in the 1002 area
            will seriously affect the wildlife and wilderness values listed within                                         1. U.S. Fish and Wildlife Service (USFWS) 1973. Arctic wilderness study
            the original legislation which created the Arctic Refuge. Whilethere                                              report. Unpubl. manus., U.S. Dept. Int., Fish Wildl. Serv., Washington D.C.
            may be debate on whether portions of the wildlife can be maintained                                               69 pp.
            during oil development. it is Incontrovertable that, aswilderness, the
            area will be destroyed The coastal plain is f lat. The air there is pristine,                                  2. Thayer, A 1982. Wilderness evaluation of 1002 (c) area. Memorandum to
            and crystal clear. Even small sounds carry easily and almost eerily over                                          Refuge Manager, Arctic NWR, U.S. Dept. Int., Fish Wildl. Serv., Fairbanks,
            the undisturbed f latlands, and the presence, even ten miles in the distance,                                     3 pp.
            of oi I wel Is, burning Industrial wastes, and aircraft, would be a travesty.

            Hence, Arctic Audubon joins with the National Audubon Society and the
            environmental community across the nation In recommending to Congress
            Alternative E for management of the 1002 area. Only true wilderness
            status is grand enough for this remaining area of untouched Arctic coastal
            plain. And only this choice is wise enough to protect this land In the name
            of current and future national Interest.

            Your consideration of our comments and recommendations Is greatly
            appreciated

            Sin@erely,

            April E. Crosby, Conservation Committee Co-Chair
            Arctic Audubon Society

            Attachment

            cc: Honorable Steve Cowper, Governor
                Senator Frank Murkowski
                Senator Ted Stevens
                Representative Don Young
                Representative Bennett Johnston

    	Terrestrial Studies, Birds

    Conners, P.C., C.S. Connors and E.G. Smith. 1982 Shorebird
    litteral zone ecology of the Alasken Beaufort Coast. In:
    Environmental Assessment of the Alaskan Continental Shelf, Final
    Reports of Principal Investigators, National Oceanic and Atmos-
    pheric Administration/cuter continental Shelf Environmental
    Assessment Program, Juneau, Alaska.

    	Hansen, H.A. and L.E. Eberhardt, 1981. Ecological
    infestigations of Alaskan resource development. In: Pacific
    Northwest Laboratory annual report for 1980 to the C.O. E.
    Assistant secretary for the Environment, Part 2. Ecological
    sciences.

    Troy, D.M. and S.R. Johnson. 1982. Bird monitoring program.
    annual Report of the Prudhoe Bay Monitory Program, U.S. Aray
    corps of Engineers, Alaska District, Anchorage, Alaska. 62 pp.

    Truett, J.C., R. Howard, and S.R. Johnson, 1982. The Kuparuk
    oilfield Ecosystem-- A literature summary and synthesis and as
    analysis of impact research. L.C.L. Ecological Research
    Associates, inc. Prepared for: ARCO Alaska, Inc., Anchorage,
    Alaska. 168 pp.

    Woodward-Clyde consultants. 1982. Oliktok Point and Vicinity:
    1981 Environmental Studies. Prepared for: ARCO Alaska, Inc.,
    Anchorage, Alaska.

    Woodward-Clyde consultants, 1982b. Kuparuk Waterflood Project
    - Final REport, Chapter 6- Avifausa. Prepared for: ARCO
    Alaska, Inc., Anchorage, Alaska.

    Woodward -Clyde consultants. 1983. Lisburne Development Area:
    1983 Environmental studies. Prepared for: ARCO Alaska, Inc.,
    Anchorage, Alaska.

    		Terrestrial Studies--Vegetation
    Ebersole, J.J. and P.J. Webber. 1983. Biological decomposition
    and plant succession following disturbance on the Arctic Coastal
    Plain, Alaska. Proceedings of the Fourth International
    Conference on Permafrost, University of Alaska, Fairbanks,
    Alaska; 18-22 July 1983. washington, D.C.: National Academy
    Perss. PP. 266-271.

    Howe. E. 1982 Obesrvations of impoundments and culvert
    performance along the West Dock to Pad E Road, Prudhoe Bay.
    Alaska. Draft Interim report to Alaska Department of Transpor-
    tation and Public facilities 44PP.

    Elinger, L.F., D.A: Walker, M.D. Walker and P.J. Webber. 1983
    The effects of a gravel raod on adjacent tundra vegetation.

    Prudhoe Bay waterflood Project Environmental Monitoring Program.
    Prepared for the Alaska District, corps of Engineers, Anchorage,
    Alaska, 99310.

    Webber, P.J. and J.D. Ives. 1978. Recommendations concerning
    the damage and recovery of tundra vegetation. Environmental
    conservation 3(5):171-182.

    		Aquatic Studies--Fisheries

    Biosonics, Inc. 1984. Prudhoe Bay waterflood Project Fish
    Monitoring Program. 1983. Prepared for Department of
    the Army Alaska Distric, corps of Engineers, Anchorage.
    161 p.

    Bryan, J.E. 1973. The influence of pipeline development on
    freshwater fisheries resources of northern Yukon
    Territory: aspects of research conducted in 1971 and
    1972. Envoron.-soc. comm., North. pipelines, Task force
    North. oil dev., rep. 73-6. Ottawa. 63 P.

    Chihuly, M., D. Ward, P. Craig R. Mcmillan and R. MOrrison.
    1979b. Spring fisheries survey and provisional list of
    waterbodies along the Alaskan gas pipeline route(Prudhoe
    Bay to the Yukon Territory) proposed by Northwest
    Pipeline company. Rep. by LGL Ecol. Res. Assoc., Inc.
    for northwest Alasken Pipeline Company. 210 p.

    Chihuly, M., D. Ward, P. Craig, R. Mcmillan and R. Morrison.
    1980. Spring fisheries survey and provisional list of
    waterbodies along the Alaskan gas pipeline route (Prudhoe
    Bay to the Yukon Territory) proposed by Northwest Alaskan
    Pipeline co. Rep. by LGL Ecol. Res. Assoc. for northwest
    Alaskan Pipeline Co. 211 p.

    Craig, P.C. 1976. Preliminary fisheries survey along the
    coastal alternative corridor ( Arctic National Wildlife
    Range). Unpub. Rep. by Aqust. Environ. Ltd, for Alaskan
    Arctic gas study co., Nchorage, Alaska, with revised
    figures (30 dec. 76). 5 p.

    Craig, P.C. 1977a. Ecological studies of anadromous and
    resident populations of Arctic char in the canning River
    drainage and adjacent coastal waters of the Beaufort Sea,
    Alaska. Aarctic Gas Biol. Rep. Ser. 41 (1). 116 p.

    Craig, P.C. 1977b. Arctic char in sadlerochit springs,
    Arctic National Wildlife Range. Arctic Gas Biol. Rep.
    ser. 41(2). 29 P.

    Craig, P.C. 1977 c. Fisheries research in the Shaviovik
    Drainage, Alaska, with emphasis on arctic char in the
    Kavik River. Arctic Gas Biol. Rep. Ser. 41(3). 28 p.

    Craig, P.C. 1978. Movements of stream-resident anadromous
    Arctic char (Salvelinus aloinus) in a perennial spring on
    the canning River, Alaska. J. Fish. Res. Board Can.
    35:48-52.

    Craig, P.C. 1984. Fish resources. Chapt. 6. p. 240-266.
    In: J. Truett (ed.), Proceedings of a synthesis seeting:
    the Barrow Arch environment and possible consequences of
    planned offshore oil and gas development. MMS/NOAA,
    Outer contineltal Shelf Environ. Assess. Prog.,
    Anchorage, AK.

    	Aquatic Studies, cont.

    Craig, P.c. 1984. Aquatic survey of the Kaktovik dredging
    operation, 1983 and 1984. Rep. by LGL Alaska res. Assoc.
    for North slope Borough, Barrow. 25 p.

    Craig, P.C. and W.B. Griffiths. 1981b. passage of large fish
    around a causeway in Prudhoe bay, Alaska. Arctic 34:314-
    317.

    Craig, P.C. and G.J. Mann. 1974. Life history and
    distribution of arctic cisco(corergenus autumnalis) along
    the Beaufort Sea" coastline in Alaska and the Yukon
    Territory. Arctic Gas Biol. Rep. Ser. 20 (4). 27 p.

    Craig, P.C. and P. Mccart. 1974. Fall spawning and
    overwintering areas of fish populations along routes of
    proposed pipeline between prudhoe Bay, Alaska, and the
    Mackenzie Delta 1972-73. Arctic Gas Biol. Rep Ser.
    15(3). 36 p.

    Craig, P.C. and P. Mccart. 1975. Classification of stream
    types in beaufort sea drainages between prudhoe Bay,
    Alaska and the Mackenzie Delta, N.W.T. Arctic and Alpine
    Research 7:183-198.

    Craig, P.C. and D. Schmidt. 1982. Fisheries surveys at
    potential dredging sites at North Slope villages:
    Wainwright, point Lay, Atkasook, Nuiqsut and Kaktovik.
    Rep. by LGL ltd. (Sidney) for the North Slope Borough,
    Barrow, Alaska. 43p.

    Critchlow, K. 1983. Fish report, Prudhoe Bay Waterflood
    project environmental monitoring program, 1982. Rep. by
    Woodward-Clyde consultants for Dept. Army, Alaska
    District, Corps of Engineers, Anchorage, Ak. Vol. 3,
    Chap. 5. 327 p.

    Dames and Moore. 1985. Prudhoe Bay unit waterflood project,
    marine life return system monitoring program. Quarterly
    Rep. for ARCO Alaska Inc., Anchorage, AK.

    Daum, D., P. Rost, M. Smith. 1984. Fisheries studies on the
    North Slope of the Arctic National Wildlife Refuge, 1983.
    U.S. Fish and Wildl. Serv., Fish. Res. Prog. Rep. No.
    fy84-1. Fairbanks, AK. 58 p.

    Denbeste, J. and P. Mccart. 1984. Results of studies of the
    long-term effects of the Trans Alaska pipeline System on
    fish and aquatic habitats. Rep. by Aquat. Environ. Inc.
    for Alyeska pipeline Service co., Anchorage, Alaska. vol.
    2. 313 p.

    Dew, C.B. 1982a. Marine and anadromous fish. In: Kuparuk
    Waterflood environmental studies, final report Rep. by
    Woodward-Clyde consultants for ARCO Alaska, Anchorage.

    		Aquatic Studies, cont.

    Mccart, P., P. Craig and H. Bain. 1972. Report on fisheries
    investigations in the Sagavanirktck River and neighboring
    drainages. Rep. to Alyeska pipeline Service Co.,
    Bellevue, Wash. 83 p.

    Moles, A., S.D. Rice and S. Korn. 1979. Sensitivity of
    Alaskan freshwater and anadromous fishes to Prudhoe Bay
    Crude oil and benzene. Trans. Amer. Fish. Soc. 108: 408-
    414.

    Moulton, L. 1980a. Effects of gravel removal on aquatic
    biota. p. 141-214. In: Gravel removal studies in
    arctic and subarctic floodplains in Alaska, technical
    report. Rep. by Woodward-Clyde Consultants for U.S. Fish
    and Wildl. Serv., Anchorage, Alaska. Rep. No. FWS/OBS-
    80/08. 403 p.

    Moulton, L. 1980b. Kuparuk field fish survey. Rep. by
    woodward-Clyde consultants for ARCO oil and gas co.,
    Anchorage, AK. 26p.

    Moulton L 1983. Kalubik Creek fish survey-1983. Rep by
    Woodward-Clyde Consultants for Kuparuk River unit. Arco-
    Alaska Inc., Anchorage, Ak. 20p.

    Moulton L. and M. Fawcett. 1984. oliktok point fish
    studies--1983. Rep by woodward-Clyde consultatns for
    Kuparuk River Unit, ARCO-Alaska Inc., Anchorage, Ak.

    Moulton, L., B. Gallaway. M. Fawcett. W. Griffiths, K.
    critchlow, R. Fechhelm, D. Schmidt and J. Baker. 1985.
    1984 Central Beaufort Sea fish study., Waterflood
    monitoring program fish study. Rep. by entrix Inc., LGL
    Ecol. Res. Assoc., and Woodward-Clyde consultants for
    Envirosphere co., Anchorage, AK. 194 p.

    Moulton, L., K. Tarbox and R. Thorne. 1980. Beaufort Sea
    fishery investigations, summer 1979. In: Environ.
    studies of the Beaufort Sea. Rep. by Woodward-Clyde
    consultants for prudhoe Bay unit. Anchorage, AK. 89 p.

    Neill, W., R. Fechhelm, B. Gallaway, J. Bryan and S. Anderson.
    1983. modeling movement and distribution of young Arctic
    cisco (Coregonus autumnalis) relative to temperature-
    salinity regimes of the Beufort Sea near the Waterflood
    causeway, Prudhoe Bay, Alaska. Biol. Pap. Of the Univ.
    of Alaska 21:39-61.

    Poulin, V.A. 1977. Part 6, fishes. In: Environmental
    assessment of construction adn construction support
    activities related to the proposed ten year beaufort sea
    offshore exploration program. Vol. 2, part 1 of 2. Rep.
    by F.F. Slaney & Co. Ltd. for imperial Oil Ltd., Calgary.

    Comments to: Department of Interior
    		November 1986 Draft Arctic N.W.R.
    		Costal Plain Resource Assessment

    From:      Martha K. Raynolds
    	     1099 Farmers Loop
    		Fairbanks, Ak 99709

    I appreciate the opportunity to comment on the Draft ANWR
    coastal plain Resource Assessment, and sincerely hope that
    the deficiencies pointed ou in my comments and others will
    be addressed in the final document. I thought most of the
    report was well prepared, but found several problems with
    chapter vI Environmental consequences, and found the
    Executive summary to be a very poor representation of the
    contents of the report. I also disagree with the Interior
    Department's conclusion that Alternative A, full leasing of
    the coastal plain, should be the recommended alternative.

    1. Water and Gravel Resources
    The problems caused by lack of water and gravel resources on
    teh coastal plain are not adequately addressed. Although
    their scarcity is mentioned, the alternative measures which
    woudl be required to extract the gravel adn water required
    from development are not fully described. consequently, the
    impacts which would be caused by gravel and water extraction
    are not covered in chapter VI.

    2. Central Arctic Caribou Herd
    The impacts of development on the Central Arctic Caribou
    Herd (CAH) are not adequately described. The discussion in
    Chapter VI does not include the impacts due to the pipeline
    and road which would be required to join the 1002 area to
    the Trans-Alaska pipeline (TAPS). This east-west connecting
    corridor would be a preprequisite for development of the 1002
    area. It would have a very significatn impact on the CAH,
    by cutting across its summer habitat, used for calving and
    insect relief. The impacts of this pipeline and parallel
    road must be included in the discussion of the impacts of
    development of the 1002 area. THe impacts to the Porcupine
    Caribou Herd are thoroughly addressed.

    3. Petroleum Resource Potential
    Chapter III statess that there is a 19% chance of there being
    an economic sice accumulation of oil and gas on the coastal
    plain. The executive summary does not even mention the 81%
    probability that no economic oil or gas exists in the
    coastal plain. It only discusses the probable size of such
    an accumulation, should it occur. This is very misleading.
    The full probabilities of finding oil and gas should be
    presented very clearly in the summary.

                4.  Discussion Of Impacts in Executive Suminary
                The Executive Summary glosses over the Impacts      o f
                development as described In Chapter V1. The statenacuL,
                "Most adverse effects would be attinliul--cd ot -:11minat--d
                through carefully applied mitigation .... expluration and
                development at Prudhoe Day Indicates minimal Impact on
                wildlife resources. Hence It Is reasonable to a5:iume that
                development can.proceed on the. coastal plain and generate
                similar minimal effects."# Is EXTREME    .LY misleading. FIr5t,
                the Impacts to caribou, muskox, and snow geese, as described
                In Chapter VI are MAJOR impacts that cannot be mitigated.
                Secondly, development at@Prudhoe Bay has had some very
                significant impacts on wildlife in the area. And thirdly,
                the Prudhoe Bay area Is not directly comparable to the 1002
                area. The ANWR coastal plain provides much more critical
                habitat for caribou, muskox and snow geese than Prudhoe Bay
                ever did. Most of the impacts of the recommended
                Alternative A are very clearly stated In Chapter VI, and
                should be Included In the Executive Summary.

                5. Recommended Alternative
                Personally, I would recommend Alternative E.       If and when
                oil and gas resources become so scarce and precious (ar. they
                are clearly NOT right now) that we should risk the wildlife
                and wilderness resources of the ANWR coastal plain, an act
                of Congress could d1low drilling. Until such time, the
                coastal plain should be protected. If development Interests
                ire so strong that drilling cannot be prevented, why Is
                Alternative C not adequate? The report states that even
                under Alternative A, considerable further exploration would
                have to be carried out before any companies would be
                Interested In leasing. If preliminary exploration needs to
                be done, why not allow that and THEN review the data and
                assess the tradeoffs with more complete Information to
                decide whether to open the 1002 area to leasing?

                                   signed
                                           Martha K. Raynolda
                                           Biologist.

                                    Date

                                                                                                          I  am presenting this      statement on the draft     report    to

                                                                                                     Congress required by Section 1002 or the Alaska National Interest

                                                                                                     Lands Conservation Act   on behalf of the Arctic Audubon Society.
                                         TESTIMONY
                                                                                                     The Arctic Audubon Society is the most northerly chapter of the
                                    ON BEHALF OF THE                                                'National Audubon    ISociety.   The chapter is composed of 320

                                                                                                     members, mostly from-the Fairbanks area.       The chapter  plans to

                                                                                                     submit more extensive written   comments at a  later date.

                                                                                                           People   or Fairbanks have historically been           extremely

                                                                                                     interested in the Arctic- National Wildlife Refuge from its
                                  CONCERNING THE DRAFT
                         ARCTIC NATION .AL WILDLIFE REIFUGE, ALASKA                                  beginbing.    Arctic Audubon Society members as well        as   other
                                                                                                     segments    of the Fairbanks community were instrumental             in
                            COASTAL PLAIN RESOURCE ASSESSMENT
                                                                                                     originally establishing,the   refuge in 1960 as the Arctic National

                                                                                                     Wildlife Range to preserve    its unique wilderness, wildlife,,and

                                                                                                     recreational values.

                                  FOR A PUBLIC HEARING                                                    Lost   year  the Arctic Audubon Society adopted      the Arctic
                                  IN ANCHORAGE, ALASKA                                               Refuge   under   the National Audubon Society's Adopt-a.-Refuge
                                                                                                     Program.    The  chapter has become actively involved with reruge
                                     JANUARY.5, 1987                                                 management issues a.nd intends  .to work closely with Arctic refuge

                                                                                                     staff in Fairbanks.      Fairbanks is the closest major population

                                                                                                     center to the refuge and the second largest city in the state.
                                 Arctic Audubon Society                                              For these reasons we feel that it is particularly irresponsible
                                     P.O. Box 82098
                                 Fairbanks, Alaska 99708                                             of the Interior Department to hot hold a public hearing in

                                                                                                     Fairbanks on this important matter so crucial to the future of

                                                                                                     the Arctic Refuge and Alaska.

                                                                                                      c:) nz: ]._15 4-
                                                                                                              -11   that  the area 14 "thP WOSt                 Oil   and  gas
               Another   community where a public hearing should       rightfully                     frontier area in North America."      If the report is right, then it
         be hold is Arctic Village.       The draft report to Congress states                         leads  also to the conclusion that instead of drilling        for    more
         that   one of the major environmental impacts of full oil and         gas                    oil in our few remaining large pristine wilderness areas, we need
         leasing would     likely be a population decline of the Porcupine                            to  instead search for alternative energy sources that will          not
         Caribou Hard.     The report also states that the people of Arctic                           run out nor require sacrificing the natural character of our last
         Village and the village of Old Crow in Canada depend largely on                              wilderness habitats.
         this caribou hard for subsistence.        By not holding a hearing in
         Arctic Village the Interior Department is effectively depriving                                   The report also goes on to predict that if full leasing is
         residents of their most meaningful way of providing input                                    implemented major     negative imPaOts would likely     occur on the
         to the report.                                                                               Porcupine Caribou Herd,    muskox,   and snow geese.      Less serious,
                                                                                                      but  nonetheless detrimental,     effects would occur to the Central
               We have reviewed the draft report to Congress and find one                             Arctic caribou herd,    wolf,   brown bear,   polar bear,    and golden
         of 'its major deficiencies       to   be that    the conclusions      and                    eagle.   The report predicts that full leasing would also have a
         re:ommendations    drawn are not supported by the report itself.                             Major adverse impact On subsistence in the region.
         The report states that there is only a 19 percent chance of
         finding an eco   nomioal)y recoverable oil prospect on the       coastal                         One Of the Most important major effects would be the loss        of
         plain.    The report    further states that it recoverable oil         is                    the  last area on the North Slope of Alaska that we still have an
         found, there is a 95 percent chance that it would produce no more                            opportunity   to set aside as wilderness.      The two   million acre
         than 600 million barrels of oil.      For comparison, the Prudhoe Bay                        Wastal   plain   represents a small fraction of the      North Selope.
         field   is estimated to have originally contained about 9 billion                            The: 23 million  acre National Petroleum Reserve and millions        of
         barrels of recoverable oil, or 15 times as much oil.                                         =res Of state    land in the Prudhoe Bay region have already       been
                                                                                                      committed   to    Oil    and gas exploration       and     development.
                According  to the report,    the chances of the Arctic     Refuge                     Additionally some 24 million acres of near and offshore lands are
         producing a     Prudhoe Bay equivalent oil reserve is only           five                    available  for oil and gas leasing in the adjacent Beaufort Sea.
         percent.   These figures and other information given it) the report                          The Arctic Refuge coastal plain is the Only region on the          North
         about   the geology,   in our opinion,    do not support the report's                        Slope  that is not opened to oil and gas      development.    Must we
                                                                                                      grant access to the entire North Slope for the oil indnstry?         Is

    	this a fair balance in the eyes of the American people? We
    absoultely cannot afford to compromose the last virgin tract of
    Arctic costal plain.

    	The 1002 area is the last stand for wilderness on the North
    Slope. Because of its remotaness and isolation from the rest of
    industrialized American it stands as a symbol of this country's
    pristine natural areas and the concept of true wilderness. If it
    is lost to development it will be a major statement by our
    society that we really aren't concerned about preserving
    undisturbed regions on the earth for future generations. It will
    seem that we are driven by our gluttony for cheap energy and the
    corporate dollar. It will mean that no place on earth is really
    sacrosanct from huma development no matter how highour ideals.

    	We beleive that the Interior Department is not complying
    with ANCILA sections 1004 and 1317 which both call for a
    wilderness review of the Arctic Refuge costal plain. The report
    to congress certainly does not, in our opinion, satisfy this
    requirement. Since the costal plain is being left out of the'
    refuge comprehensive conservation planning process, it will not
    receive the wilderness reveiw that has been a normal part of that
    procedure for other refuges. We believe that it is wrong and
    premature for the secretary to be making a recommendation for
    full leasing to congress before complying with these
    Wilderness review provisions of ANILCA, and we draw this to the
    attention of congress.

    	Finally, we would like to bring one other aspect concerning
    the coastal plain to the attention of the secretary adn congress.
    In recent months the Department of Interior has conducted land
    exchange negotiations involving the 1002 area. We believe it is
    premature for the Secretary to consider trading away the 1002
    area prior to congress reviewing the coastal plain resource
    assessment. We believe that the department is circumventing the
    intent of section 1002 of ANILCA by taking much negotiation
    action, and funding such action with taxpayer dollars. We
    recommend that the department cease all land exchange negotiation
    work involving the coastal plain.

    	In closing, our view is that the coastal palin entirely
    meets the standards for calssification and protection as
    wilderness, with the exception of two dew line sites. The area
    area deserves full wilderness protection perhaps more than any
    other area in the united states today. We beleive that once the
    Interior Department conducts a meaningful wilderness review it
    will discover this as well. We are unconvinced by the report to
    Congress that leasing the arms for oil and gas is wise and in the
    national interest considering the balance between the area's
    wilderness and wildlife values adn its potential oil and gas
    resources as stated in the report.

    	We urge the secretary to conduct a thorough wilderness
    review as required under section 1317 and 1004 of ANILCA, and
    ultimately recommend that the coastal plain be designated as
    wilderness. Wilderness status will protect the coastal plain

          from  industrial development and provide an Arctic REgion which

          will  remain   undisturbed for future generations of mankind and

          wildlife. We hope the Secretary will have the foresight, insight

          and courage to take such action.

        9
        Go

                                                                                                     souqht to combine the best elements of a cash and subsistence
                                  REMARKS OF JACOB ADAMS ON                                          lifestyle in a manner that gives us, the Inupiat residents of the
                          THE DEPARTMENT OF THE INTERIOR DRAFT REPORT                                Arcticp the opportunity to participate In the chance location of
                        CONCERNING THE ARCTIC NATIONAL WILDLIFE REFUGE,
                            ALASKA, COASTAL PLAIN RESOURCE ASSESSMENT                                mineral resources while ensuring the continued vitality of our
                                                                                                     living resources.

                                     KAKTOVIK PUBLIC MEETING
                                         January 6, 1987                                                   My people And the shareholders of ASRC have major cultural,
                                                                                                     subsistence and economic interests in the decisions that will be
                  My name is Jacob Adams.   I am an Inupiat Eskimo from Barrow,                      made based on the Coastal Plain Resource Assessment Report. As the
            Alaska and President of the Arctic Slope Regional Corporation.                           Report rightfully points out, the Inupiat Eskimo Villaqe at
                                                                                                     Raktovik has survived as a community because of 'strong family
                  I am pleased to have the opportunity to comment this evening                       cultural ties, ties to the land, and economic opportunity for both
            on the Secretary-of the Interior*s draft report concerning resource                      jobs and subsistence."
            assessments and recommendations for the Arctic National Wildlife
            Refuge Coastal Plain.                                                                          Our people have traditionally used and continue to use today
                                                                                                     the ANWR and the Coastal Plain for subsistence, cultural and other
                  The North Slope of Alaska has been and continues to be our                         traditional purposes. We are also beneficiaries of increased
        9   'people's home. We use these lands to maintain our culture and                           economic activity in the North Slope  that has resulted from oil and
            traditional lifestyle, for,a variety of subsistence.uses and for                         qas development.
            other purposes. As users and residents of the North Slope's lands,
            we have for centuries faced the issues of using the land's                                     Today,*ASRC and Kaktovik Inupiat Corporation are the owners
            resources,while respecting and conserving that same land and.its                         of 92,000 acr es of highly prospective private land located within
            living resources. Our use of the land and its resources is a                             ANWR and adjacent to and within 6e Coastal Plain area.
            dynamic and changing process; it is not static preservation, but
            rather is something that must be lived and experienced.                                        Our interests in the.Coastal Plain area, as its residents and
                                                                                                     stewards, and as shareholders of ASRC, are unique and balanced. As
                  More recently, the Inupiat Eskimo of my generation have had                        President of ASRC, I.think it essential that our views on the
            to balance the benefits of change and   .tradition in our culture.                       future of the Coastal,Pid'ln be given careful consideration so that
                                                                                                     my people's interests will be protected by Congress' decisions
                  We have learned to speak English while trying to preserve our                      concerning uses of the Coasta 1 Plain.
            Inupiat lanquage. We have benefited from technology, but remain
            subsistence hunters. we have a cash economy, but we still highly                               I would like to sayr qenerally,  that we support the Report's
            value and rely on the Inupiat Eskimo tradition of sharing. We have                       proposed Alternative A and aqree with  the recommendation by the
                                                                                                     Secretary of the Interior to fully lease the Coastal Plain to
                                                                                                     develop oil and qas resources, provided that appropriate measures
                                                                                                     are taken to protect continuation of and access.to wildlife
                                                                                                     resources and ensure coordinated and efficient oil and gas

                                                                                                                                         -2-

           activities. We think that the Secretary's recommendation is
           consistent with our people's desire for a balanced approach to the                            We question the Report*s conclusion that oil and gas
           use and conservation of all of the land's resources.    we do not                       development would result in a major population decline of the
           feel that any of the other alternatives would accomplish our                            Porcupine Caribou herd. We believe that this conclusion is
           objectivesy in particular, I would note that we find the wilderness                     erroneous for two reasons.
           designation alternative most objectionable to meaningful use of the
           area by our shareholders.                                                                     First, we do not believe that development necessarily will
                                                                                                   result in increased harvests. Though Kaktovik residents 'Will
                 Simply stated, we favor development of the Coastal Plain In a                     continue to hunt caribou to meet their subsistence needs,
           manner that is compatible with our long-term interests in                               non-subsistence hunting should be severly limited to prevent siqni-
           protecting the environment, the fish and wildlife and human values                      ficant reductions of the herd.
           of the residents of the North Slope.
                                                                                                         Second, we do not think that development activities, of
                 As residents and stewards of the North Slope lands, my people                     themselves, will  threaten the caribou. Even the Report
          .have watched oil development over the past 20 years at Prudhoe Bay                      acknowledges that there is insufficient experience to support the
           and Kuparuk.                                                                            conclusion that development will necessarily result in a
                                                                                                   significant decline in the number of Porcupine Caribou. In fact,
       9         Because of our interests in the effect of this development on                     all the relevant experience to date indicates that caribou and the
        L  the environment and wildlife that is central to our way of living,                      oil industry can anti do successfully coexist.
       T   we have followed these developments with some skepticism.
           Nevertheless, we have been very impressed with the energy                                     The coexistence of caribou and development is a concern we
           industry's gains In planning, In technology and In operating                            have faced before when the Prudhoe Bay oil field was developed In
           projects in the Arctic environment - particularly those on shore.                       the mid-1970s. Many of the same questions that were asked then
                                                                                                   about the effect of development on the Central Arctic Caribou Herd
                 We have read with interest the Report's conclusions                               are being asked now about the Porcupine Caribou Herd.
           concerning the projected effect of development on the wildlife that
           is important to our people's subsistence. The report.notes that                               Will they be diverted by traffic, roads or pipelines? Will
           the full leasing program of the proposed Alternative A would have                       their calving habits be clanqed?
           minor effects on fish, waterfowl and bowhead whales--species that
           are Important to our subsistence needs and traditions.                                        Scientific studies and our own experience show that the
                                                                                                   Arctic Caribou Herd has not been weakened or reduced by development
                                                                                                   j.
                 The Report also notes that the Impact of a.full leasing                          'at Prudhoe Bay, Kuparuk and Milne Point. Oil industry operations
           program could he greatest on the caribou, a resource which is                           within those general regions do not appear to have affected the
           important to our people, especially those here at Kaktovik.                             calving success of the caribou.

                                                                                                         In fact, the Central Arctic Herd has increased at a rate of
                                                                                                   12-18 percent per year during the past decade.

                                               -3-                                                                                      -4-

                 We are convinced that experience gained by the exploration                             No one disputes that the Coastal Plain of ANWR represents the
           and development of energy sources,within the last 20 years will                        best on-shore prospects for oil and gas in the United States today.
           lead to the development of new energy production facilities that                       Widely accepted studies show that current North Slope oil
           can be operated very.compatibly with the caribou and other living                      production will decline significantly in the next 15 years.
           resources of the Coastal Plain. We know that it will require
           careful regulation and will increase project costs, but we believe                           Without the development of new and best prospects such as
           a productive balance can be achieved.                                                  that which is apparant In the ANWR CoastalPlain, our country
                                                                                                  places itself in a more perilous position as a hostage to foreign
                 Our own local governments and companies  have brought their                      supplies of oil.
           experience and knowledge to bear on the energy development process,
           resulting in sensitive and effective decisions. The lands we own                             Exploration and development of Arctic Oil and gas usually
           within ANWR were cooperatively placed under a regulatory scheme and                    takes more than ten,years from the initial discovery to first
           set of stipulations that has demonstrated the compatibility of                         production. To anticipate this country's future needs and to
           living resources and energy development.                                               reduce the dependence on foreign sources of oil, we as Americans,
                                                                                                  believe It important that decisions be made today to explore and
                 As a people reliant on our land and its resources, we are                        develop the oil resources of the ANWR Coastal Plain.
           sensitive to the long-term significance that development of the
           ANWR Coastal Plain may represent. We think that sound environmental                          We do not believe that the issue of development in the ANWR
           studies and mitigation measures have been and will be  successful in'                  Coastal Plain requires an "either/or" decision with respect to
           limiting the adverse effects of development. we are also confident                     conservation of important fish and wildlife resources. Though
           that.the existing and improving technologies can ensure the                            diverse goals are presented by petroleum development and
           inteqrIty of the environment during oil and gas operations.                            conservation of these.resources, the record of prior p6troleum
                                                                                                  development on the North Slope supports our belief that these goals
                 we agree with the Report's recommendation that leasing in the                    are not mutually exclusive.
           "core calving* areas of the caribou In the southeastern corner of
          .the Coastal Plain be done in the final phase of exploration and                              These goals can be successfully reconciled to ensure the
           development. This phased leasing would allow for ongoing                               continued availability of our subsistence resources, meet the need
           evaluation of development Impacts so that appropriate mitigation                       for this country's additional, dependable energy supplies and
           measures could be developed for the more sensitive environmental                       preserve the wilderness of nearby lands@
           areas. This will also ensure adequate opportunity to monitor and
           ensure continued viability of the Procupine Caribou Herd and access                          We support the recommendation of the Secretary of Interior in
           to the caribou for subsistence use by residents of Kaktovik.                           the draft Coastal Plain resource assessment. We are confident that
                                                                                                  a balanced program of development and conservation can be
                 in addition to being residents of affected lands and the                         implemented. We look forward to continued participation in the
           lands that are adjacent to the Coadtil Plaint we wishr as                              implementation process.
           Americans, to express our concern about these significant land   use
           decisions that will be made soon.                                                            Thank you.

                                                                                                                                     Page 2

                                                ANCHORAGE
                                                                                                                                     ANWR was established to preserve for all time the       spectacular wilderness
                                                    dubon Society, Inc.                                                              ecosystem of northeastern Alaska. Major compromises have already been
                                                                                                                                     made on Alaska*s North Slope between development and conservation
                                                A CHAPTER OF THE NATIONAL AUDUBON SOCIETY
                                                                                                                                     Interests. These compromises have resulted In current land jurisdictions
                                                                                  January 23, 1987                                   that essentially make almost 90 percent of the Slope potentially available
                                                                                                                                     for oil and gas leasing. Additionally, 24 million acres of nearshore (state)
                                                                                                                                     and offshore (federal OCS) lands are also available for leasing In the
                                                                                                                                     Beaufort Sea. These policies lead us to question if any public wilderness
       Office Box 101161                                                                                                             lands along the Arctic coast of Alaska will be considered sacrosanct.
       AnchaMe, Mesita  U.S. Fish and Wildlife Service
                0010    Attention: Division of Refuge Management                                                                     Despite the outstanding natural values pointed out In the &aft assessment
                        2343 Main Interior Building                                                                                  report and the fact that the chance for discovery of an economically
                        I Oth & C Street, N.W.                                                                                       recoverable oil field Is only 19 percent, the Department of Interior is
                        Washington, D.C. 20240                                                                                       recommending that the entire coastal plain be made available for leasing to
                                                                                                                                     the oil industry. Meanwhile, officials of the Department are conducting
                        Re: Comments of Anchorage Audubon Society on the Draft Arctic National                                       negotiations In secret to trade away refuge lands on the coastal plain to
                            Wildlife Refuge Coastal Plain Assessment                                                                 private Interests. This action subverts the entire assessment report
                                                                                                                                     process, preempts Congreslonal options, and.could lead to privatization of
                        Dear Sir or Madam:                                                                                           the refuge. Apparently, little was learned by the Department of Interior
                                                                                                                                     from their St. Matthew Island experience where a federal judge ruled that
                        The Board of Directors of Anchorage Audubon Society on behalf of Its 1400                                    Interior officials made serious errors In judgement In their attempt to trade
                        members urge that leasing or land exchanges on the coastal plain of the                                      away wilderness lands to oil interests, and that the land trade was not In the
                        ANWR be deferred at this time. Based on the Information in the 1002 report                                   public Interest.
                        we believe that It Is not In the.long-term conservation, economic or national
                        security Interests of the US to open the coastal plain to leasing now. We                                    It Is difficult to accept the premise that ol I resources of the Arctic Refuge
                        recommend that additional Information be gathered to better assess the                                       are critical to fulfilling growing national energy needs, when there Is no
                        hydrocarbon potential of the coastal plain, ft wildlife and ecosystem values                                 national energy plan In place and since President Reagan recently vetoed the
                        before making a leasing decisloft Further, a national energy policy must be                                  National Appliance Energy Act of 1986. This act, supported by both houses of
                        established which provides real alternatives to the exploitation of our                                      Congress, would have saved the nation both millions of.barrels of oil and
                        remaining wilderness lands.                                                                                  billions of dollars on utility bills by the year 2000, thus making exploitation
                                                                                                                                     of the Refuge totally unnecessary.
                        The Anchorage Audubon Board agrees with the finding of National Audubon
                        Society's Alaska Regional office that the Department has left us no                                          The Audubon Energy Plan which National Audubon Society has developed w,ith
                        reasonable alternative but to oppose Its recommendat Ions because of the                                     Input from energy experts, industry, government and the academic
                        serious shortcomings In Its resource assessment process for the coastal                                      community provides a practical, step-by-step alternative to the
                        plain of the ANWR outlined In the Testimony on the 1002 Report given by                                      Administration's energy policy of opening up the remaining wilderness lands
                        David R. Cline on January 5, 1987. We find the report deficient in essential                                 in the United States for leasing. The plan shows that proper planning and
                        Information, particularly on oil and gas potential, the national need for                                    policy development at the federal level will enable the U.S. to produce more
                        developing this oil and compromises already made to Arctic wilderness                                        goods and services while actually Improving the environment.
                        Palues.

                Page 3

                We urge the Administration to take reasonable administrative and legislative
                action to promote cost-effective conservation. The adoption of a well
                thought out National Energy Plan will preclude the leasing of our last
                remaining pristine areas.

                The Administration practice of offering tens of millions of acres of public
                lands each year at a time when oil prices are at their lowest level raises
                serious question about whether the entire federal leasing program amounts
                to a giveaway to the oil Industry. This f lood of lease offerings is helping
                drive down the price of leases and bringing an unfair return to the
                taxpayers for use of non-renewable public resource.

                Less than 6 percent of oil resources in Alaska are estimated to lie beneath
                designated or potential wilderness lands. In the lower 48, only 4% of the
                wilderness heritage remains. Unless the nation maintains the sanctity of
                designated and potential wilderness areas, even that small percentage will
                disappear. The Audubon Energy Plan demonstrates that there are practical
                alternatives to exploiting the last of our wilderness areas. The U.S. can
                                                                           M T
                leave w 1 lderness -!one and st, 11. 1, solve 1, 'Is ol 1. Import proble . I he tota 1
         OD     amount of oil and gas under wilderness lands Is too small to justify the
          4     abandonment of the nation's remaining wilderness heritage.

                The Anchorage Audubon Society is not an anti -development group. We expect
                that more than 95 percent of oil and gas resources on federal lands will
                eventually be tapped. Howeve, we believe that leasing on the coastal plain
                should be deferred until there is more Information about the oil and gas
                potential and the Impacts on wildlife and ecosystems.

                Your consideration of our comments and recommendations Is greatly
                appreciated.

                Sincerely,

                Sandra Cosentino
                President

                cc: David R. Cline, Regional Vice President, National Audubon Society
                   Alaska Congressional Delegation, Washington, D.C.

    ~0

                DO YOU WANT TO MAKE PUBLIC COMMENTS?

                If you would like to speak at the hearing today. please fill in the blanks
                below and turn it In to one of the Fish and Wildlife Staff members present.                         National Aud
                You need not complete this sheet to submit written comments. Thank you.
                                                                                                                                  ALASKA REG~qK
                                                                                                                    308 G STREET. SUITE 217. ANCHOR

                Please print
                Name  ~0qDA~4qV I          ~6qC-4~q1A~q)~qf~=                                                                                   TESTIMONY
                mailing Address ~-~0qM~2qP                      ~0qV~p                                                                  ON BEHALF OF TH

                                                                                                                         NATIONAL AUDUBON SO
                Check appropriate box below:

                      1 am here to offer my own views.
                              --or-
                      I am speaking for ~q)~6qU~0qA~2qT~8qO~qA~q)~6qA~qA
                                     (please enter name of organization you represen~0qP~8qr~6qY                                 AT A PUBLIC HEARING

        9                                                                                                                         DRAFT

        CO
        CO                                                                                                      ARCTIC NATIONAL WILDLIFE RE

                                                                                                                    COASTAL PLAIN RESOURCE A

                                                                                                                                     BY

                                                                                                                              DAVID R. CLINE

                                                                                                                    REGIONAL VICE PRESIDENT
                                                                                                                         NATIONAL AUDUBON S

                                                                                                                            Anchorage, Alask
                                                                                                                             January 5, 1987

                                                                                                                     A %a ~rv~ir A ~v~c r~n~%~4~1~k~f~l~'~r~r~rn T~n ~qr~qn

                                                                                                         NA:3, Tentinumy rm 1062 ;@ep,@rt
                                                                                                                     199-

                   My name is Dave Cline, and    I am the Alaska Regional Vice
             President for the National Audubon Society. I am testifying
                                                                                                         northeastern Alaska   as a whole. Audubon stronqly supported       this
             today on behalf of the Society including its.2,600 members in
             Alaska.                                                                                     far-sighted action,   and so too enlaiQerent of the refuce in      the
                                                                                                         Alaska National Interest-Lands Act of 1900-1ANILCA). Over the
                   After carefully examining the *Resource Assessment Report'                            yearswe have worked with other conservaLionints to protect the
             for the coastal plain of the Arctic National Wildlife Refuge, we                            refuge from a series.of threats from developme      .nt interests.
             are convinced it in not in the long-term conservation, economic
             or national security interests of the United States to open the                                   -In this debate over the future of the Arctic Refuge and
             coastal plain to leasing at this time. We urge, therefore, that                             its coastal plain, it    .is vitally important to realize that major,
             no leasing or land exchanges be permitted by Congress, and that                             compromises have already been made on Alaska's North Slope
             the U.S. Fish and Wildlife Service be directed to protect and                               between development and conservation interests         These
             manage the entire.Arctic National WildAife Refuge consistent                                compromises have rAulted in current land jurisdictions that,
             with the conservation purposes for which it was originally                                  essentially make almost 90 percent of the slope potentially
             established by Congress.                                                                    available for oil and gas leasing. This is not to mention the
                                                                                                         additional 24 million acres of nearshore (state) and offshore
                   We wish to commend the many dedicated resource                                        (federal OCa) lands available in the adjacent Beaufort Sea. A
         L
        OD   professionals in the U.S. Fish and -wildlife service,     U.S.                              mere 2 million acres of of the entire North Slope has been
             Geological Survey and Bureau of Land Management who gathered                                committed to conservation purposes in the Arctic Refuge. Now
             information for the assessment report, often at great personal                              most of that is under siege by development interests. The
             risk and sacrifice. Because of their many contributions, the                                questions must be asked: Where will the compromising stop?
             outstanding wildlife and wilderness values of the coastal plain                             Aren't there any public wilderness lands along the Arctic coast
             have been reconfirmed and understood better than ever before.                               of Alaska that should be considered sacrosanct?

                   As one of the oldest and largest conservation                                                It is also important to note that this IS       million-acre
             organizations in the United States, the National Audubon Society                            refuge is-the second largest unit in the National Wildlife
             has a long history of involvement in the Arctic National                                    Refuge System, and the larqest and most spectacular arctic
             Wildlife Refuge. We recognize it as a very special national                                 wilderness sanctuary for wildlife in the world. Wildlife
             treasure. Dedicated friends in conservation, including Olaus                                species of particular national and international concern include
             and Margaret Muria, worked long and hard for its establishment                              the 180-thousand-member Porcupine caribou herd (whose calving
             in 1960 to preserve a portion of the eastern Brooks Range of                                ground is an the refuge coastal plain), polar bears, grizzly
             arctic Alaska for its outstanding wilderness values. Thus,                                  bears, muskox, Dall sheep, wolves, wolverines, snow geese,
             unlike many other refuges in the system, the Arctic Refuge was                              peregrine falcons and other migratory birds, and Arctic char and
             established not out of a singular need to conserve wildlife, but                            grayling.
             to preserve for all time the spectacular wilderness ecosystem of
                                                                                                               When considered in conjunction with the North Yukon
                                                                                                         National Park that adjoins it on the east# tne Arctic Refuge

                                                                                                  uA:@  fat@i       i nins@ a-pcrt
          NAS Testimony on 1002 Report                                                                        I 9A,,)
          January 5, 1967
          Page 3

          constitutes an international commitment to the protection of                              2)  Failure to release for public review and comment qeoloqic
          nature. Major industrial developments on either of these units                                information critical to the 1002 assessment process. This
                                                                                                        gi.Lves those who could profit from exploiting refuge
          is clearly incompatible with their purposes.                                                  resources advantage over those who actually own those
                                                                                                        resources--the American people.
                 We agree with the Department of the Interior (on page 45
          of the draft assessment report) that:
                                                                                                    3) -Failure to reveal its proposed land trades with various
                   'The Arctic Refuge is the only conservation system unit                              Alaska Native corporations and the State of Alaska, and to
                 the protects, in an undisturbed condition, a complete                                  demonstrate how such trades will serve in the public
                 L
                 pectrum of the various arctic ecosystems in North                                      interest.
                  erica.".
                                                                                                    4)  Failure to justify full leasing when prospects for
          and (on page 46) that:                                                                        discovery of even one major economically recoverable oil
                                                                                                        field on the coastal plain is only 19 percent (pages 49
                   *The 1002 area is the most biologically productive part                              and 60), and with the market value of leases depressed
                 of the Arctic Refuge for wildlife and is the center of                                 because of the world oversupply of oil.
                 wildlife activity on the refuge. Caribou migratinq to and
                 from the 1002 area and the post-calving caribou                                    5)  Failure to conduct a comprehensive economic analysis to
                 aggregation offer an unparalleled spectacle.*                                          show how the benefits to the Alaska and national economies
                                                                                                        can be optimized from leasing. both in the short and long
                 Despite these outstanding natural values, and the fact                                 term.
          that the chance for  discovery of an economically recoverable    oil
          field is only 19 percen r, the Department of the Interior is                              6)  Failure to provide evidence that the Department will
          recommending that the.entire coastal plain be made available     for                          ensure that air and water quality will be protected from
          leasing to the oil industry. The Department has left us no                                    toxic chemicals and other pollutants such as those
          reasonable alternative but to oppose its recommendations because                              creating problems in the Prudhoe Bay oilfield.
          of the following serious shortcomings in its resource assessment
          process for the coastal plains                                                            7)  Failure to explain how adequate water and gravel supplies
                                                                                                        will be obtained after finding that "...specific locations
            1)   Failure to point out that the compromise to establish the                              and sources of water and gravel for exploration and
                 Arctic Refuge in 1960 to preserve its unique wil  Idlife,                              development activities have not been identified; it is
                 wilderness and recreation values resulted in the remainder                             understood that these resources, especially water, are not
                 of Alaska's vast North Slope and adjacent offshore waters                              readily available on the 1002 area," (page 75.)
                 being made available for oil exploration.
                                                                                                    8)  Failure to explain w1ay it wouldn't be in the strategic

            NAS Testimony on 1002 Report
            January 5, 1987
            Page 5

                   interests of the United States to purchase more foreign                                   international management agreement that has been
                                                                                                             negotiated over rne part rtpveral years.
                   oil at current low prices for addition to our nation's
                   *Strategic Petroleum Reserve" rather than lose income to                            14)   Failure to hold public hearin  Iga in all Alaskancommunities,
                   the federal treasury by further flooding a depressed lease                                that will be directly affected by the proposed action, and
                   market through opening the Arctic Refuge.
                                                                                                             to make an adcquate number of copies of the assessment
               9)  -Failure to evaluate cumulative impacts on the Arctic                                     -report, available in a timely manner.
                   Refuge from oil and gas lease sales on more than a million
                   acres of adjacent state lands (Camden Bay, Demarcation                                    Unfortunately, a series of citizens'    lawsuits proved
                   Point and Prudhoe Day uplands) and 21.2 million acres of                           necessary during the assessment process to     assure that the law
                                                                                                      was followed, and citizen monitoring of government activities
                   OCS leases (Sale 97) in the Beaufort Sea'scheduled for
                   July 1987.  The latter sale, just off the refuge.coast, is                         was required as well to learn of industry activities taking
                   the largest oil and gas lease sale ever held in the Arctic                         place on the Arctic refuge. And. despite      the magnitude of
                   Ocean.                                                                             resources at stake and the seriousness of     the consequences of
                                                                                                      the decisioq on people both in Alaska.and     throughout the nation,
                                                                                                      the Department of the Interior chose not to make this report
             10)   Failure to.thoroughly discuss alternative energy policies
                   that i.f implemented could make the nation energy secure                           available for public review and comment. A citizen lawsuit was
                   without exploiting the Arctic Refuge.                                              necessary to make the report available. Then, after being
                                                                                                      forced to release the report for public review, the Department
             11)   Failure to assure that scarce refuge staff and funds will                          abbreviated the comment period to 60 days over the Christmas
                   not be divertLed from refuge conservation programs.to                              holiday period. This is not the way a democracy like ours
                   monitor and regulate industrial activities on the coastal                          should work.
                   plain. (Since the coastal plain resource assessment was
                                                                                                                                                      of involvement in
                   initiated in 1982, more than 90 percent of the refuge                                     in addition to Audubon's long history
                   budget has been devoted to the 1002 assessment process,                            wildlife conservation, another major priority goal of the
                   resulting in the almost total neglect of the overall                               Society is to *promote national strategies for energy
                   refuge conservation program.)                                                      development and use, stressing conservation and renewable energy
                                                                                                      resources." in an effort to achieve this goal, we have
             12)   Failure to recognize that a North Yukon National Park                              developed an energy plan with input.from energy experts in
                   adjoins the Arctic Refuge and that the United States has                           industryt government and the academic community. This was done
                   responsibilities to cooperate with Canada in protecting                            in the realization that energy in a major factor in determining
                   shared wildlife resources.                                                         the quality of human life. It furthers the productio@ of goods
                                                                                                      and services, but its production and use can seriously impact
             13) Failure to address the need for cooperative management of                            the quality of the environment.
                   the Porcupine caribou herd with Canada through the

           NAS Testimony on 1002 Report
           January 5, 1987
           Page 7

                 The Audubon Energy Plan is a practical, step-by-step                                     In the meantime, and as long as this Administration
           alternative to the Administration's energy policy of exploiting                          lefuses to take reasonable admini-rtrarivo ana _1Pc7iqt:%tjve action
           the last remaining wilderness lands in the United States.      it                        to promote cost-effective energy conservatinn, wa@ will have no
           shows that proper planning and policy development at the federal                         choice but to oppose attemptn to cpcn the Arctic Refuqe to oil
           level will enable the United States to produce more goods and                            and gas development.  'Audubon has worked ha  .rd, particularly at
           services while actually improving the environment. The                                   the state level, to get appliarce efficivncy rtandards enacted.
           environmental pay-off will be cleaner air, purer water, and less                         In New York, we initiated the process that led Governor,Cuomo to
           pressure to exploit wilderness lands and wildlife habitat such                           introduce a tough efficiency stand  *ards bill last year.
           as that in the Arctic Refuge.                                                            Massachusetts Audubon played a similar role in getting a bill
                                                                                                    introduced (and passed) in Massachusetts. Aud    Iubon members are
                 True, the.Audubon Plan requires the introduction of                                well aware thae preser'Vation of wildlife and protection of the
           regulatory measures that correct imperfections in the                                    human environment requires wise husbanding of our energy
           marketplace, such as efficiency standards for home appliances                            resources.
           and fuel economy standards for automobiles. Such reliance in
      9    our Plan on modest measures to promote cost-effective                                          Audubon has been actively involved in   efforts to develop a
        L  conservation stands in contrast to the approach taken by the                             long-range comprehensive management plan for the Arctic Refuge.
           Administration, which holds that conservation should be left                             However, We have not been party to any actions that would
           solely to the marketplace, no matter how far economists tell     us                      preempt a thorough review of the mandated assessment report,
           individual markets are operating from the cost minimum, no                               waiting to judge it on its merits, waiting to see if there were
           matter how much energy is being wasted as a result. When this                            a few key areas in which drilling could be allowed without
           blindspot toward energy conservation is combined with the                                risking serious interference with wildlife and the wilderness
           Administration's skepticism towards envirorunental protection,      it                   quality of the land.   Instead of a complete and objective report
           is perhaps not surprising that the Administration makes drilling                         with viable management options, we found the 1002 report biased,
           in wilderness areas one of the pillars of its energy policy.                             contradictory, and lacking essential information. The only
           Fortunately, the recent bipartisan show of support in Congress                           Possible excuse for this report is that Interior must not really
           for appliance efficiency standards,indicates that the                                    be Serious, but is floating a totally unreasonable position in
           Administration is out of touch with the country when it comes to                         the hopes of maximizing its bargaining power in Congress.     if
           tolerance of modest conservation regulations. we are confident                           so, the tactic is likely to backfire by completely alienating
           that a Presidential veto of the appliance bill in the upcoming                           those organizations willing to keep an open mind on resour   ce
           session will be overridden by Congress. We are also confident                            exploitation in the Arctic Refuge. Certainly, this has been the
           that, when the choice is clearly put, Congress will decide to                            effect on the National Audubon Society.
           enact additional conservation legislation in order to preserve
           our national treasures such as the Arctic Refuge (as well as to                               The major undiscovered deposits of oil and gas on federal
           save consumers money.)                                                                   land holdings are though t to lie off the coast of the lower 48
                                                                                                    states and Alaska. Thus# in the 14ext two decadese as known

             TIAS Testimony on 1002 Report                                                                                 on
             January 5, 1987
             Page 9                                                                                         !,aar

             onshore reserves are depleted, offshore development will become                                      The General Accounting-Office found that the number of
             more important. Relatively little offshore land is currently                                         bids per tract declined from of 2.44 bids to 1.65 bids
             off-limits to energy development. Most of these deposits will                                        under the area-wide program.
             eventually be tapped.
                                                                                                               Al GAO estimated that "the federal government received about
                    The fact that all federal lands have not yet    'been leased                                  $7 billion (or a discounted value of $5@4 billion in 1984
             does not mean that development is proceeding too slowly. These                                       dollars) less than it would have received if*the same
             leases will be much more valuable ten to twenty years from now.                                      acreage were under the tract selection program," (GAO
             If the government were to lease all these lands at once, it                                          Report, RCED-85-66, 1985, p.i.v.)
             would get an unfair economic return for the taxpayers.
                                                                                                                  Even the industry recognizes*'the lease price denression'
                    Judged in this context, the Reagan Administration is                                          caused by area-wide leasing--the 0;1 and Gas Journal
             making a serious mistake in rushing to     -lease virtually the                                      reports that "offshore producers agree that acreage costs
             .entire U.S. Outer Continental Shelf (OCS)--almost a billion                                         on area-wide lease sales are lower than under the previous
          9
             acres--and onshore prospects as well. The practice of offering                                       nominated tract concept because more acreage is offered at
           A tens of millions of acres of public lands each year at a time                                        one time." (Washinoton Postt November 8, 1983.1
          (D when oil prices are depressed raises very serious questions
          CA
             about  whether the entire federal leasing program is amounting to                                    Aside from the economic arguments aqainst leasing so much
             a giveaway to the oil industry.                                                              so fast when oil prices are depressed, there is a compelling
                                                                                                          conservation argument. Huge lease Offerings involving tens of
                    By flooding.the market with lease offerings, it is clear                              millions of acres make it impossible to do meaningful
             that the  administration is helping to drive the price of leases                             environmental impact analyses. Additionally, they make it
             down# thereby providing the oil    Iindustry with an opportunity to                          extremely difficult for states like Alaska to conduct rational
             lease large acreages at bargain-basement prices. Evidence of                                 development.planning.
             this downward pressure on lease prices in overwhelming:
                                                                                                                  In Alaska, less than 6 percent of oil resources are
                    The average bid per acre under the Reagan Administration's                            estimated to lie beneath designated or potential wilderness
                    5-year program has been less than half that under the                                 lands, including those*in the Arctic National Wildlife Refuge.
                    Carter program ($1,092 per acre versus $2,381 per a      cre),                        Clearly, Congress.and the federal government have made sure that
                    (Washington Post, November 8, 1983.)     1Before interior went                        lands with th@e vast majority of highest potential for oil and
                    to area-wide leasing in 1982, the average price per acre                              gas have been excluded from consideration as potential
                    for OCS lease bids in Alaska was $2,794. After area-wide                              wilderness.
                    leasing was initiated, OCS lease sales in Alaska netted an
                    average of only $1,229/acre, (OCS Report, MKS 86-0067,                                        Relatively little oil and gas is estimated to lie under'
                    September 19 86.)                                                                     wilderness iands. When this country was first settled by

           NAS Testimony on 1002 Report                                                                  IV     i9i:7
           January 5, 1987
           Page 11

           Europeans, 100 percent of the land area corresponding to the 48                          limited view on wilderness protection espoused by such'
           states was wilderness and teeming with wildlife. The                                     urgand --at ions as the American Petroleum Institute, there is
           unrestrained pressure of civilization has  .steadily eroded                              obviously a clash in values between advocates of exploitation
           wilderness areas to a small percentage of the total--4 percent                           and those whose favor preservation--a dispute that must
                                                                                                    continuously be settled through the political process. The
           in the lower 48 states. To those who assign value to
           wilderness,.it is incomprehensible that anyone would object to                           Audubon Energy Plan has been developed with this dispute in
           protecting the nation's last remaining fragments. Unless the                             mind.. The Plan  Idemonstrates that there .are practic@l
           nation'maintains the sanctity of designated and potential                                alternatives to exploiting the las.t of our wilderness areas.
           wilderness areas, even that small percentage will disappear.                             The United States can leave wilderness alone and still solve its
                                                                                                    oil import problem. The totalamount of oil and gas on
                  There will always be proposals to use wilderness and                              wilderness is too small to   .jubcify the abandonment of the@
                                                                                                    nation's remaining wilderness heritage.
           critical habitats for other purposes, particularly energy and
           mineral development. But little wilderness will be left if the
           engineers are allowed to scour the land for the next thirty                                    Under the Audubon Energy Plan, the mean risked estimate of
           years and beyond--building new roads and drill sites, returning@                         1.6 billion .barrels of oil and the 1.6 billion barrel equivalent
       9                                                                                            of natural gas estimated to lie under land already legally
        L  for a closer look each time the price of energy or minerals
           jumps, and returning whenever a new technology allowing reco   Ivery                     designated as wilderness would remain underground forever. The
           of formerly inaccessible resources is developed.                                         same would be true for the 2.3 billion barrels of oil and the
                                                                                                    2.5 billion barrel equivalent of natural gas estimated to lie
                  The National Audubon Society believes that a nation like                          under wilderness land that has yet to be formally designated as
           ours with a 200-year history should look at the wilderness                               wilderness, IA. Stege and J. Beyea, *Oil and Gas Resources on
           preservation issue in a time frame that spans hundreds of years                          Special Federal Lands: Wilderness and Wildlife Refuges," Annual
           rather than decades. only with such perspective can the nation                           Review of En2M, Vol. 11, 1986. pp. 143-161.) Because
           pass on to succeeding generations the wilderness resources that                          wilderness land-would never be exploited under the Audubon Plan,
           are still intact.                                                                        there would be no need for exploration.

                  The fact is that.wilderness  such as that on the Arctic                                 The estimates for oil in wilderness lands given above
           Refuge coastal plain serves a variety of valuable, noncommercial                         assume a mean risked estimate of 600 million recoverable barrels
           uses: wildlife habitat, watershed protection, scientific study,                          of oil for the Arctic Refuge@ In contrast, the Draft Coastal
           fishing, hunting, camping, hiking, and most other forms of                               Plain Resource Assessment mentions  .a figure of 3.2 billion
           dispersed, low density outdoor recreation. Such wilderness                               barrels, without clearly specifying whether or not the estimate
           lands offer also the spiritual lift of peaceful, truly natural                           is *risked.*   (We suspect it is not.) Clarification on this
           settings.                                                                                point is needed from Interior.    If the 3.2 billion figure in
                                                                                                    risked, that is, already incorporates the risk of finding no     oil
                  Although not every oil industry organization takes the                            (81%), Interior would be claiming that there are 2.5 billion.

             NAS Testimony on IM Report
             January 5, 1987
             Page 13

             more barrels of oil likely to be found in wilderness lands than                                     It is argued by industry that the coastal plain of the
             in the estimates we have been using. Nevertheless, even 'an                                  Arctic keiuao must r*p 1-ned now-L--cause it will take at leact
             additional 2.5 billion barrels would notchange the fact that a                               fifteen years to d@velors-any oil fields discovered there.        it
             very small percentage of U.S. oil is in potential and designated                             ruct be remembered that followinq 41scovery of oil at Prudhoe
             wilderness lands. The percentage of U.S. o     il resource s o n these                       Bay in 1968, Oil was.flowing through the 800-mile-long Trans
             lands would rise from 3.5% to 5.81.                                                          Alaska Pipeline (TAPS) by June of 1977, a period of only 9
                                                                                                          years.. All that would be needed should oil product'ion be
                   Certainly, any exploration that may     eventually be                                  permitted on the Arctic Refuge would be'a 100 to 150-mile-long
             permitted on these areas should be made by nonintrusive methods,                             pipeline spur (at@maximum) to.tie into TAPS. Our guess is that
             such as satellite survey. Nonintrusive methods are currently                                 industry could bring an oilfield an line in the refuqe within 5
             in.adequate for confirming existing Interior estimates. but the                              years should it someday prove in the national interest to do so.
             situation will no doubt change in the future.. Fifty years from
             now, technologies for identifying natural resources will have                                      It is an illusion to believe that leasing on the coastal
             surpassed the crude methods available to energy companies                                    plain of the Arctic Refuoe will solve the economic problems of
             today. With such asmall percentage of U.S. land remaining as                                 the North. After all# its whole purpose is to deliver northern
             wilderness, it would seem wise for the'nation to be patient in                               oil to homes and industries in the South--or perhaps the
             confirming interior's istima   tes.                                                          Orient. Indeed, rather than solving the North's economic
                                                                                                          problems, it may accentuate them. For evidence of this, we need
                   As has been indicated, the National Audubon Society is not                             look no further than the situation in Alaska today. With the
             blindly opposed to resource extraction on federal lands. We                                  Trans Alaska Pipeline carrying oil at near full capacity, the
             expect that more than 95 percent of oil and gas resources on                                 state is going through one of the most 8
                                                                                                                                                      erious economic
             federal lands will eventually be tapped. The Society stands                                  recessions in its history. The result      in many cases is lost
             ready to work with oil and gas companies to help them develop                                dreams and destroyed careers.
             environmentally sound methods of exploration and extraction that
             are suitable for thegreat percentage of land, both public and                                     The situation on the Arctic Refuge obviously calls for
             private, on which such activities need not be prohibited                                     bold and courageous political leadership at both the state and
             completely. Audubon will continue to insist, however, that                                   national levels. For politicians to be holding out the promise
             exploitation of resources on public lands be carried out                                     that yet another great oil bonanza lies beneath the Arctic
             carefully in a manner that protects the environment and                                      tundra just waiting to be exploited only postpones the day when
             wildlife. Audubon will continue to oppose oil and gas                                        all Americans must begin to live within their means by
             exploration in any situation where government agencies      or energy                        implementing cost-effective conservation measures.        I
             companies move hastily, without fully assessing the 1                                                                                                 .6
             environmental and economic effects of activities or       providing                               On page 6 of its assessment report, Interior states,
             adequate safeguards for their implementation. This       appears to
             be one of those cases.
                                                                                                                  'Oil and gas development will result in widespread,

             NAS Testimony on 1002 Revort
             January 5, 19B7                                                                            u.'! ry
             Page 15

                    long-term changes in wildlife habitats, wilderness                                     Range.   R-qardl@sq ^f hnw
                    environment, and Native community activities. Changes                                  are some oil and gar, com-pa.-hies which wi_ waDL LC,
                    could include displacement and reduction in the Porcupine                              this last stretch 6f north RIOPP Arctic land unimpacted     Ly
                    caribou herd."                                                                         man.  What the Ccnaress doer; with zeq
                                                                                                                                                   ard to this fraqile
                    We agree but do not believe that it is in the best                                     area will be an indication of hOw wisely we are eicing to
                                                                                                           conserve the nation's natural resources in the future. We
             stratiZgic, economic or conservation interests of the United                                  'Can afford to make this Range the -last place to go" in
             States to recommend making such sacrifices on the finest Arctic                               the search for energy and we should. We urge the Senate
             wildlife and wilderness sanctuary in the world at a time of a                                 to study the arguments on both sides of this issue, for we
             world oversupply of oil and with hundreds of millions of acres                                believe strongly that aside from high emotions which have
             of other federal and state lands available   for exploration.                                 surrounded the debate on this issue, the facts support
                                                                                                           protection for the Range at this time...' (Report of the
                    it has been said by many that we are  now at our Last                                  Committee on Energy and Natural Resources, United States
             Frontier in Alaska.   This has different meaning to different                                 Senate, No. 96-413, November 14, 1979, page 421.)
         9   people. To some it offers opportunity for resource development
          L  and.the jobs and material benefits delivered. To others, it is                                The National Audubon Society therefore strongly opposes
        cc
        0)   wildlife and wildland spectacles which constitute a heritage    to                     leasing of the coastal plain for oil and gas devr_-Io6 ent at this
                                                                                                                                                           m
             be preserved for generations of Americans. The decisions we                            time, and recommends that the U.S. Fish and Wildlife service be
             make on the Arctic Refuge theretore are not simply about oil                           directed to manage the entire Arctic Refuge consistent with the
             fields and caribou herds.   They are decisions that strike to   our                    conservation purposes for which it was established.
             very deepest concerns as a nation.
                                                                                                           Your consideration of our comments and recommendations is
                    The National Audubon Society  feels the Department of the                       greatly appreciated.
             Interior is making a serious mistake in recommending that the
             coastal plain of the Arctic Refuge be sacrificed to industrial
             development. The facts convince us-that America can achieve
             energy security without exploiting the last great arctic coastal
             wilderness in the United States.

                    We believe that U.S. Senators Howard Metzenbaum and Paul
             Tsongas were right when in the 1979 debate on the Alaska Lands
             Act they stated.

                       "It appears as if the "forbidden fruit" syndrome is
                    operating with regard to the Arctic National Wildlife

    	CANADIAN WILDLIFE FEDERATION /LA FEDERATION CANADENNE DE LA FAUNE

    February 5, 1987

    U.S. Fish and Wildlife Service,
    Attention: Division of Refuge
    Management,
    2343 Main Interior Building,
    18th and C Streets, N.W.,
    Washington, D.C.
    20240 U.S.A.

    Dear Sir/Madam:

    Please find enclosed the submission of the Canadian Wildlife
    Federation on the issue as to whether or not the 1002 area on
    the Arctic Refuge Coastal Plain in northeastern Alaska should
    be opened up for oil and gas activity.

    Yours Sincerely,

    Stephen Hazell,
    counsel

    SH/Sb
    Encl.

    1673 carling avenue Ottowa Ontario k2A 3Z1
    1673 ovenue carling, Ottawa (ontario) K2A3Z1 Tel (613) 725-2191

    SUBMISSION OF THE
    CANADIAN WILDLIVE FEDERATION
    TO THE U.S. DEPARTMENT OF THE INTERIOR
    REGARDING THE
    DRAFT ARCTIC NATIONAL WILDLIFE REFUGE, ALASKA
    COASTAL PLAIN RESOURCE ASSESSMENT

    WHO WE ARE

    The Canadian Wildlife Federation (CWF) in Canada's largest
    non-governmental conservation organization with over 500,000
    members and supporters, as well as affiliates in each of the
    twelve provinces and territories of canada. ince the 1960s,
    CWF has closely monitored northern wildlife and conservation
    issues with special emphasis on petroleum development. The
    Federation was instrumental in the establishment of the Task
    Force on Northern Development, and the establishment of the
    Canadian Arctic Resources Committee in 1971.

    The Canadian Wildlife Federation was involved in proceedings
    surrounding the proposed Mackenzie Valley Pipeline in the
    Canadian Northwest Territories, which was to transport oil
    from the canadian Arctic along the Mackenzie Valley to
    Alberta. CWF action included participation in both sets of
    National Energy Board hearings on the Mackenzie Valley
    Pipeline, the creation of the Public Interest Coalition and
    the maintenance of an on-going secretariat to coordinate
    action during the hearings. The CWF also intervened in a
    1971 lawsuit in U.S. courts concerning the construction of
    the Trans-Alaska Pipeline to represent the interests of
    Canadian wildlife.

               Summary                                                                                        The Recommendation states that "Development would proceed
                                                                                                              with the goal of no net loss of habitat quality" (p. 170),
               The Canadian Wildlife Federation wishes to express to the                                      whereas the Report concludes this goal is impossible in that
               Government of the United States our deep concern about the                                     an unavoidable impact of Alternative A would be "Loss of
               draft Arctic National Wildlife Refuge, Alaska, Coastal Plain                                   habitat values on approximately 78,000 acres of caribou
               Resource Assessment (the 1002 Report), and our profound                                        calving habitat ... " (p. 131-32).
               disagreement with the draft Recommendation of the Secretary
               of the Interior (chapter VIII) that the Congress enact                                         The Recommendation states that nmost adverse environmental
               legislation making the entire 1002 area of the Arctic Refuge                                   effects would be minimized or eliminated through
               available for oil and gas leasing.                                                             mitigation..."      This    Is  not   a   fair   or    reasonable
                                                                                                              interpretation of the 1002 Report; mitigation measures are
               The CWF has three major concerns about the draft                                               not possible or were not proposed for three species that
               Recommendation of the Secretary and the 1002 Report.          First,                           would be most heavily affected by development -- Porcupine
               the Recommendation of the Secretary of Interior contradicts                                    caribou, lesser snow geese and polar bear (p. 111).
               to the point of misrepresentation statements about the
               impacts of petroleum development on wildlife and the                                           The Recommendation declares that adverse impacts on the
               environment in preceeding chapters of the 1002 Report.                                         Porcupine caribou herd (PCH) can be mitigated using the
                                                                                                              lessons learned at Prudhoe Bay, noting that the "Central
               Second, the 1002 Report neglects that migratory and itinerant                                  Arctic caribou herd has Increased substantially during the
               wildlife species of Alaska/Yukon such as caribou, polar bear,                                  period that development has occurred within the heart of its
               lesser snow geese, fish and marine mammals are shared by the                                   range (p. 169).   This statement is belied by the 1002 'Report:
               United States and Canada.     Development of the 1002 area will                                "because of the greater density of PCH on their calving
               have significant adverse impacts          on such transboundary                                grounds, the PCH would interact with oil development much
               species shared by the two nations,           not to mention the                                more extensively and intensively than the CAH (Central Arctic
               traditional use of those        species by Canadian aboriginal                                 herd) has interacted with oil development in the Prudhoe Bay
               people.                                                                                        area.   Analogies comparing the events of current development
                                                                                                              on the CAH and effects of potential 1002 area development on
               Third,    acceptance and       implementation      of the      draft                           the PCH must be drawn with caution" (p. 106).
               Recommendation by the Government of the United States would
       CD      be a clear signal to Canada and Canadians that the United                                      The factual contradictions between the Recommendation and the
       00      States does not view bilateral efforts to conserve shared                                      remainder of the 1002 Report are so numerous as to lead the
               natural resources, such as the Porcupine caribou, to be of                                     CWF to suspect that the serious adverse impacts on wildlife
               great importance.                                                                              described in the Report were purposefully downplayed in order
                                                                                                              to enhance the arguments for the full development option,
               The Canadian Wildlife Federation urges the Government of the                                   Alternative A.
               United States to protect the 1002 area by establishing it as
               a wilderness under Alternative E.
                                                                                                              Shared Resources

               Secretary's Recommendation                                                                     An uninformed reader of the Secretary's Recommendation could
                                                                                                              be forgiven for wondering what possible interest Canada and
               The CWF is distressed by the contradictions            between the                             Canadians have in a domestic U.S. issue about whether or not
               draft Recommendation of the Secretary of Interior and other                                    a potential Alaska oilfield should be explored and developed.
               chapters of the 1002 Report. The Recommendation ignores or                                     For the Recommendation does not make even a passing reference
               glosses over statements identifying serious environmental                                      to the fact that the United States and Canada        share many of
               impacts on wildlife and concludes--contrary to the evidence                                    the wildlife resources of the North Slope. Aboriginal
               of the 1002 Report--that "the Prudhoe Bay experience leads                                     Canadians harvest 80% of the annual take of Porcupine
               one to be optimistic about the ability to explore and develop                                  caribou; these Canadians will bear the brunt of an American
               the hydrocarbon potential of the             1002 area without                                 decision to develop the 1002 lands.        According to the 1002
               significant deleterious effects on the unit's wildlife                                         Report, the full-scale leasing and development of the 1002
               resources." These conflicts are discussed in detail in the                                     lands will lead to a major Porcupine caribou population
               Government of Canada's position paper         on the 1002 Report,                              decline and change in distribution of 20 to 40%.
               but a few of the more striking are summarized here.

                                              2                                                                                              3

               Unfortunately,   the draft 1002 Report itself ignores or
               underestimates the impacts of petroleum development on the
               Canadian aboriginal communities of the Mackenzie river and
               northern Yukon regions. The wildlife, especially the caribou,
               are critical to the largely subsistence economy of these
               aboriginal communities; a significant decrease in abundance
               of transboundary species could have catastophic economic and
               social effects, and.might result In overexploitation of other
               species.

               The International Porcupine Caribou Agreement

               There is growing awareness in Canada, the United States and
               other nations that sovereign rights to develop and use shared
               natural resources must be tempered and limited by
               international measures that ensure the conservation of such
               resources in perpetuity. Canada and the U.S. were the       first
               nations to agree in the Boundary Waters Treaty of 1911 to
               limit their exploitation of transboundary water resources for
               mutual benefit. The Migratory Birds Convention of 1916 and
               also the Great Lakes Water Quality Agreements of 1972 and
               1978 are striking examples of the success that can be
               achieved by International cooperation in conservation.

               The as yet unsigned International Porcupine Caribou Agreement
       9       (initialled by chief negotiators of Canada and U.S. on
               December 3, 19861 is the most recent example of the clear
               understanding in both nations that bilateral cooperation is
       CD      the key to conserving the shared natural resources of the two
       (0      nations. The proposed Agreement recognizes that the Porcupine
               caribou are a unique and irreplaceable resource that must be
               conserved for the use of future generations.       The proposed
               Agreement would establish a joint board to advise U.S. and
               Canadian governments on conservation measures that should be
               implemented to conserve the caribou.

               It need hardly be stated that the proposed Agreement and the
               draft Recommendation are Irreconcilable.

               The acception and implementation by the United States of the
               Secretary of Interior's draft Recommendation would be a clear
               signal to Canada and Canadians that the United States does
               not view the proposed Agreementand bilateral efforts to
               conserve shared natural resources to be of great Importance.

               The Canadian Wildlife Federation trusts that this is not the
               case.  We urge the United States Government to designate the
               1002 area as wilderness.

                                            4

    ~0

                DO YOU WANT TO MAU PUBLIC ~COM~qM~q"S?

                if you would like to speak at the hearing today, please fill In the blanks
                below and turn It in to one of the Fish and Wildlife Staff members present.
                You need not complete this shoot to submit written comments. Thank you.

                                                                                                                                      PRESENTATION
                                                                                                                                         PUBLIC HEAR
                .Please print                                                                                                C~*~4 THE ~4~*~41~L~CA SEC~T~qI

                Ham       ~@~4~/~y~l ~e~qs~-
                                                                                                                                        Anchor~q7~g~o, A
                ~~ll~in~a Address         Ale ~S~'~t ~r~i I At .~0~'~1 ~0~qF                                                                          J~a~n~u~a ~y ~2q5~q1

                                                                                                                                                  by

                Check appropriate box b~elow~t
                 ~qC3 1 an here to offer my own views.
                                -or-                                                                                                       V~ic~*-Chal
                      1 a~m speaking foe  ~4q6~4~VA~l~e~'~Z a ~8qY~a~4qe~,~,~ql ~-~q!~A~qt~qA~,~.~8qw~#~,r                                                          Economic D~&~V~*~1~o~p~qm~q*
                                               e~at~e~r~na~m~e of organization you represent)
                                                                                                                                   Counc~l~i for Yu~qk

                                                                                                                                      -2-

                         (MR/MS CHAIRMAN/PERSON, DEAR PANEL MEMBERS)i                                         MY REASON FOR BEING     80 ANXIOUS TO MEET THIS
                                                                                                              PANEL TODAY, IS NOT     ONLY BECAUSE MANY OF MY

                                                                                                              PEOPLE IN THE YUKON SHARE FAMILY TIES WITH

                                                                                                              MANY OF OUR ABORIGINAL ALASKAN NEIGHBOURS,

                                                                                                              BUT ALSO BECAUSE WE FREQUENTLY          SHARE   THE
                         IT IS WITH A   GREAT DEAL OF ANTICIPATION THAT                                       SAME RESOURCES.
                         I . HAVE BEEN   LOOKING FORWARD TO SPEAK, ON
                                                                                                              BY THIS I MEAN CERTAIN WILDLIFE RESOURCES
                         BEHALF OF THE COUNCIL FOR YUKON INDIANS,
                                                                                                              WILDLIFE WHICH DOESN'T KNOW OF BOUNDARIES BUT
                         BEFORE THIS PUBLIC HEARING    TODAY.
                                                                                                              FREELY CROSSES BETWEEN ALASKA AND THE YUKON,
                         ALLOW HE, FIRST OF ALL,    TO COMMEND THE UNITED                                     SUCH AS THE MIGRATING PORCUPINE CARIBOU HERD,
                         STATES INTERIOR DEPARTMENT     FOR TOE IMPORTANT                                     BECAUSE IT REG    UIRES A LARGE HABITAT TO
                         FORUM I.T HAS PROVIDED HERE.                                                         SURVIVE.

                         FOR YOUR INFORMATION, THE     COUNCIL FOR YUKON                                      AMONG . THE MUTUAL PROBLEMS OF ABORIGINAL
                         INDIANS    IS    AN   UMBRELLA     ORGANI ZAT I ON                                   PEOPLE ON BOTH SIDES OF OUR BORDER, I AM
                         REPRESENTING     APPROXIMATELY     6,000      YUKON                                  CERTAIN, PERHAPS THE MOST COMMON IS THAT IN
                                                                                                              THE RECENT PAST WE OFTEN HAD TO REFUTE
                         INDIANS, WHO ARE CURRE141LY NEGOTIATING, WITH
                                                                                                              ARGUMENTS FROM OUR GOVERNMENTS AND INDUSTRY
                         THE GOVERNMENT OF CANADA, A COMPREHENSIVE
                         LIAND CLAIM SETTLEMENT IN THE YUKON.                                                 THAT WE NO LONGER NEED OR USE OUR      TRADITIONAL
                                                                                                              WILDLIFE RESOURCES AS WE ONCE     DID ...

                                            -3-                                                                              -4-

                      LET ME ASSURE YOU,    THI S IS SIMPLY   NOT'  SO.

                      HUNTING,, FISHI,NG AND   TRAPPING BY NATIVE                                     ONE OF THE KEY ELEMENTS TO THE SUCCESSFUL

                      NORTHERNERS ARE FAR FROM    BEING'THE   HISTORIC                                SETTLEMENT OF THE YUKON INDIAN LAND CLAIM IS

                      RELICS 0R CULTURAL LEGACIES SOME CRITICS     TRY                                MY PEOPLE'S GUARANTEED ACCESS TO WILDLIFE,

                      TO MAKE THEM.                                                                   BOTH IN TERMS OF HARVEST AND MANAGEMENT

                                                                                                     @RIGHTS. THE GOVERNMENTS OF CANADA AND YUKON

                      QUITE TO    THE   CONTRARY,   OUR   HARVEST   OF                                RECOBNIZE THIS FACT.

                      WILDLIFE RESOURCES IS AN ON-GOING, LECITIMATE

                      ECONOMIC ACTIVITY. TRANSLATED INTO HARD CASH                                    TO THE COMMUNITIES IN THE NORTHERN YUKON,

                        (IF WE MUST PUT A PRICE TAG ON IT) - THE                                      BUT FIRST AND FOREMOST TO OLD CROW, THE

                      WORTH OF THE ANNUAL SUBSISTENCE ECONOMY TO                                      SURVIVAL OF THE 150,000-STRONG PORCUPINE

                      THE YUKON AMOUNTS TO MILLIONS OF DOLLARS.                                       CARIBOU HERD IS, OF COURSE, JUST AS CRUCIAL.
                      WHI,LE ITS SOCIAL VALUE CANNOT BE PUT INTO

                      MONETARY TERMS, OUR SUBSISTENCE ECONOMY      HAS                                REGARDING THE     PORCUPINE CARIBOU,    WE    CAN

                      REMAINED CENTRAL TO THE YUKON INDIAN WAY OF                                     REPORT SIGNIFICANT RESULTS.

                      LIFE.

                                                                                                      THE FIRST MILESTONE (BY OCTOBER 1985) WAS A

                      IN PARTICULAR, THE IMPORTANCE OF THE                                            'MADE IN CANADA' PORCUPINE CARIBOU HERD

                      PORCUPINE CARIBOU HERD TO NORTHERNERS HAS                                       AGREEMENT. . IT WAS STRUCK BETWEEN THE YUKON
                      BECOME EVIDENT TO ALL THOSE WHO HAPPEN TO                                       AND NORTHWEST TERRITORIES, AND BETW9EN THREE

                      LIVE   IN COMMUNITIES WHOSE ABORIGINAL                                          LEVELS   OF   GOVERNMENT   AND   THREE    NATIVE

                      RESIDENTS DERIVE THEIR NUTRITION FROM THE                                       ORGM41ZATIONS.

                      SEASONAL HARVEST OF THE HERD.

                                             -5-

                      WITH THE SIGNING OF THIS AGREEMENT, THE                                           AND THIS BRINGS HE TO THE PURPOSE OF THIS
                      ABORIGINAL    PEOPLE   OF   THE   TWO    CANADIAN                                 HEARING.

                      TERRITORIES ACHIEVED A MAJOR ROLE IN TERMS OF
                      THE MANAGEMENT OF THE HERD. THIS PROGRESSIVE                                      THE PORCUPINE CARIBOU CALVING    GROUNDS, AS WE
                      EVENT, WE KNOW, WILL     ENSURE THAT THE HERD                                     ARE WELL AWARE, FALL INTO THAT FAIRLY NARROW
                      WILL SURVIVE FOR.MANY   GENERATIONS TO COME.                                      AND ECOLOGICALLY FRAGILE STRIP OF COASTAL
                                                                                                        'PLAIN BETWEEN THE BRITISH MOUNTAINS AND THE
                      THE SECOND MILESTONE    (BY DECEMBER 1986) WAS                                    BEAUFORT SEA ... WHEREBY THE L    .ARGER PORT I ON
                      THE SIGNING!, OF THE    TENTATIVE. DRAFT OF     A                                 OF THE HERD'S CALVING. GROUNDS LIE        IN THE
                      CANADA      UNITED STATES AGREEMENT FOR THE                                       ALASKAN ARCTIC WILDLIFE REFUGE.

                      INTERNATIONAL   MANAGEMENT.  OF THE PORCUPINE
                      CARIBOU  HERD.                                                                    THE  'UNITED  STATES RESOURCE ASSESSMENT' IN

                                                                                                        FRONT OF ME,   LADIES AND GENTLEMEN, PROPOSES.
                      I AM  PERSONALLY  CONCERNEDp HOWEVER, THAT    THE                                 FULL LEASING ... OR, WITH OTHER WORDS ... THE
                      LATTER AGREEMENT DOESN-T INCLUDE PROVISIONS                                       OPENING OF  THE ALASKAN COASTAL PLAIN FOR OIL
                                                                                                        AND    GAS    EXPLORATION     AND     PRODUCTION
                      PERTAINING TO THE UNITEDSTATES'    PROPOSALS TO
                      OPEN UP THEALASKAN COASTAL PLAIN    FOR  Of L AND                                 ACTIVITIES.

                      GAS DEVELOPMENT.

                                             -7-

                      IN MY MIND, THIS MEANS THAT A LOT OF NORTHERN                                    BEYOND THE     IMPACTS   014 CARIBOU,     ADVERSE
                      PEOPLE WILL SUFFER - VERY MUCH so, I Am                                          IMPACTS, WE ARE TOLD, CAN BE A14TICIPATED FOR
                                                                                                       WATER FOWL, MUSKOX AND POLAR BEARS.
                      AFRAID, SINCE THE REPORT GOES ON TO ADMIT TO

                      THE REAL POSSIBILTIES OF NEGATIVE IMPACTS ON
                      THE PORCUPINE CARIBOU HERD AND OTHER WILDLIFE                                    IN PLAIN LANGUAGE, THE REPORT TELLS THAT THE
                                                                                                       PORCUPINE CARIBOU HERD, FOR ONE,.          Is IN
                      RESOURCES.
                                                                                                       SERIOUS DPJ46ER OF BEING DRASTICALLY REDUCED.

                      MORE SPECIFICALLY,     I UNDERSTAND THE REPORT
                      TO SAY THAT OIL AND GAS DEVELOPMENTS MAY                                         PERHAPS AS ALARMING        ...  THE    HERD,    IF
                      AFFECT   7fr/. OF THE TOTAL ALASKAN PORCUPINE                                    DISTURBED, MAY CHANGE ITS HIORATORY PATTERNS.
                      CARIBOU CALVING GROLlNDS ...     (I URGE YOU TO                                  THIS MEANS, THAT THE HERD COULD BYPASS THE
                                                                                                       COMMUNITY OF OLD CROW, AND TO DO SO AT SUCH A
                      EXAM I P4E THIS PERCENTAGE FIGURE IN VIEW OF NO,
                                                                                                       DISTANCE THAT IT WOULD HAVE THE SAME RESULT
                      OR AT    LEAST VERY LITTLE, OTHER AVAILABLE
                      REPLACEME14T HABITAT).                                                           AS A REDUCTION OF THE HERD ITSELF.

                      WITH RESPECT TO A PROJECTION OF CARIBOU                                          FOR OLD CROW IN THE NORTHERN YUKON, CARIBOU
                                                                                                       IS AND HAS BEEN, SINCE THOUSA14DS OF YEARS, MY
                      POPULATION DECREASE, I FURTHER UNDERSTAND THE
                                                                                                       PEOPLE'S LIVELIHOOD.     FOR YUKON INDIANS ANY
                      REPORT TO SAY, THAT BETWEEN 10% P14D 40% OF
                                                                                                       DISTURBANCE TO THE PORCUPINE CARIBOU HERD IS
                      THE HERD MAY POSSIBLY BE AFFECTED.
                                                                                                       THEREFORE UNACCEPTABLE.

    			-9-
    FOR THE RECORD, LET ME MAKE MYSELF PERFECTLY
    CLEAR: OIL AND GAS LEASES GRANTED ON THE
    ALASKAN COASTAL PLAIN, AND WITHIN THE HERD'S
    CALVING GROUNDS, ARE EQUALLY UNACCEPTABLE TO
    US.

    I SPOKE EARLIER OF THE SHARING, BY ALASKAN
    AND YUKON ABORIGINAL PEOPLE ALIKE, OF
    MIGRATORY WILDLIFE RESOURCES. WHAT WE ARE
    REALLY TALKING ABOUT, ARE OUR INTERNATIONAL
    WILDLIFE RESOURCES.

    IN THEIS SENSE, MY PERHAPS HOST IMPORTANT
    POINT IS THAT THE UNITED STATES RESOURCE
    ASSESSMENT REPORT HAS FAILED TO EXAMINE THE
    TRANSBOUNDARY EFFECTS OF ALASKAN OIL AND GAS
    ACTIVITIES. ON THIS LAST ACCOUNT, AS WELL,
    THE REPORT ITSELF IS UNACCEPTABLE TO US.

    			-10-
    LET ME CLOSE BY SAYING, THAT PRIOR TO
    ARRIVING HERE AS AN INTERVENOR BEFORE THIS
    PANEL, I HAVE SCRUTINIZED MY ARGUMENTS AND
    MOTIVES CAREFULLY.

    IF YOU WILL, ALASKA AND THE YUKON ARE
    NEIGHBOURS SHARING THE SAME BACKYARD. I
    THEREFORE APPEAL TO YOU, AND ON BEHALF OF
    YOUR YUKON INDIAN NEIGHBOURS, TO GIVE OUR
    CONCERNS THE ATTENTION THEY DESERVE. I
    APPEAL TO YOU TO ACKNOWLEDGE US AS YOUR
    CANADIAN PARTNERS IN THE MANAGEMENT AND
    PRESERVATON OF OUR WILDLIFE RESOURCES ON
    WHICH, WHETHER YOU LIKE IT OR NOT, WE DEPEND
    ON BOTH SIDES OF THE BORDER.

    I FULLY BELIEVE THIS TO BE AN ATTAINABLE
    OBJECTIVE.

    THANK YOU.

                                                                                                        fl)4ende*
       'De                  Oers                                          -                                       OF WILDUR
                        OF WILDLIFE                       January 23, 1987                                   study (rather than usGs) was reaffirmed; (2) some Information
                                                                                                             which would otherwise not be available was made public; and, (3)
                                                                                                             this draft assessment was released for public comment. hearings.
              Mr. William Horn, Assistant Secretary                                                          and review.
              Department of the Interior
              18th and C Sts., NW                                                                                 Following the court ordered release of the draft resource
              Washington, D.C. 20240                                                                         Assessment for public comment with a very short comment period of
                                                                                                             60 days over the Thanksgiving and Christmas/Channuka holiday
              Re: Draft Arctic IN13tional KUdlife     RefpggA AlAska-L Coastal 21"1.                         season. Defenders and several other goups requested that the
              Resource Assessment and Legislatiy-e ZDviropmental Impact Statement                            public comment deadline be extended. The comment deadline was
                                                                                                             subsequently extended to early February 1987.
              Dear Mr. Horn:                                                                                    Recently  . the Department of the Interior. in yet a further
                  A careful review of the Resource Assessment confirms Defenders                             attempt to block meaningful public input on the draft assessment,
              of wildlife's position that the wisest and best use of the Arctic                              requested the Appeals Court to review its December 24 decision in
              National Wildlife Refuge coastal plain is to protect the                                       favor of public participation and DOI*s responsibility to respond
              outstanding wildlife and wilderness values of this area.          In the                       to comments.    The actions by the Department of the Interior are
              long run it is not In the conservation. economic or national                                   inconstructive, strike at the roots of our democratic system. and
              security interests of the United States to develop this area; in                               give everyone including conservationists a reason to be skeptical
              fact just the opposit is true. We strongly recommend that this                                 of the Reagan administration's position regarding the need to
              area be placed in the National Wilderness Preservation System.                                 lease and develop the coastal plain of the Arctic National
                                                                                                             Wildlife Refuge.
                 These comments are submitted on behalf of Defenders                   of
       9      wildlife and the Fund for Animals. Defenders is a national, non-                                  This skepticism is only increased by the Administration's
              profit organization dedicated to protecting,            conserving,     and                    pocket veto of the National Appliance Energy Act of 1986 (passed
              enhancinq this country's rich abundance and diversity of wildlife                              overwhelmingly by both houses of Congress), and its opposition to
              and wildlife habitat.         On behalf of its over 80,000 members                             establishing fuel efficiency standards for automobiles and
              Defenders is pleased to submit these comments on the Draft ArCti                               continuing the 55 mile per hour speed limit. Futhermore.
              Nati2n I     Wildlife ft1mgetL     Alaska,     Coastal J!lal      ftfip-u"s                    Department of the interior officials are conducting secret
              Asseastotnt md "e isL
                                      atIve EnvixonpentAl    Iml?act filffittDmt   (draft                    negoiations to trade away the subsurface of the refuge coastal
              assessment).                                                                                   plain to private interests and DOI's subsurface geologic
                                                                                                             information is available to everyone except the public. All in
                   We commend the dedicated professionals of the Fish and                                    all, the Department of the Interior's actions do not describe an
              wildlife Service (FWS), Bureau of Land management (BLK), and U.S.                              open administration. putting their cards on the table for public
              Geological Survey (USGS) for their efforts in preparing this                                   review.   Rather, secrecy appears to be the byword of the
              draft assessment.                                                                              administration.

                   Furthermore. as evidenced by our participation in the suit                                   The Arctic-National wildlife Refuge. the second largest refuge
              brought by conservation organizations to ensure the opportunity                                in the National Wildlife Refuge System. is the most outstanding
              for meaningful pubic comment on this draft, we appreciate the                                  wildlife sanctuary in the world. It is truly the crown jewel of
              opportunity for public participation in the planning process and                               the National Wildlife Refuge System.       in conjunction with the
              believe that it is critical to the development of a final document.                            adjacent Norther Yukon National Park, this international
                                                                                                             wilderness and wildlife area Is truly      outstanding:    a priceless
                   Unfortunately, Freedom of Information Act requests had to be                              international treasure to present and      future generations. These
              filed to find out what the Department of the Interior was doing                                attributes of the refuge are clearly put forward in the Resources
              with regard to the future of the Arctic Refuge, and several                                    Assessment which states:
              lawsuits (some of which are still ongoing) were necessary to
              ensure that the Alaska National Interest Lands Conservation Act                                              The Arctic Refuge is the only conservation system
              (ANILCA) and the National Environmental Policy Act (NEPA) were                                          unit that protects, in an undisturbed condition, a
              followed.                                                                                               complete spectrum of the various arctic ecosystems in
                                                                                                                     North America (p. 45).
                   To date, environmental organizations have won all the suits
              filed against   the Department of the Interior (DOI) regarding the
              Arctic National Wildlife Refuge. The major results of this
              litigation includes: (1) EWS's primary jurisdiction over the
         1244 NINETEENTH STREET, NW 9 WASHINGTON, DC 20036 *"(202) 659-9510                                                                      2

                                                                                                          efilloels
                 Of WILDUFF                                                                                   or WILDLIff

             Criticisms of Secretary's Recommendations                                                    the problem of American dependence on oil imports and need for
                                                                                                          energy resources. However. this conclusion is an Illusion. and
                Although some important aspects and issues of the draft                                   misleads the American public rather than dealing with the long
             assessment need clarification and others are completely                                      term problem. Significantly. the draft fails to look at alterna-
             unsubstantiated, many of its shortcomings center on what was left                            tives for meeting U.S. energy needs in the future.       The final
             unsaid.                                                                                      report should correct these problems.

                One of the most serious problems of the draft report that                                    The second part of the Secretary's recommendation. that
             needs to be corrected is that the Secretary*s Recommendation                                 development. 'could be done in an environmentally responsible
             (Chapter VIII) to lease the entire coastal plain of the Arctic                               manner based on lessons learned at Prudhoe Bay. on the 1002
             National wildlife Refuge for oil and gas development is                                      area ... and elsewhere* is contradicted by the draft assessment's
             unsubstantiated and makes a mockery of the work that went into                               discussion of environmental consequences that leasing the entire
             the body of the draft assessment. Specifically. the statement        in                      1002 area and will have on the wildlife that Inhabit this
             the Secretary's Recommendation that *development of its potential                            pristine wilderness.
             oil and gas resources could make a significant contribution to
             the economy and security of the Nation. and could be done in an                                  Specifically. page 106 cautions against comparing the
             environmentally responsible manner based on lessons learned at                               experiences of the Central Arctic caribou herd and Prudhoe Bay
             Prudhoe Bay. on the 1002 area ... and elsewherew rings hollow when                           development with the Porcupine caribou herd and possible 1002
             one reads the entire report.    in fact. the report contradicts                              development. The density. dynamics, movement, and traditions of
             this statement.                                                                              the herds are different as is clearly pointed ut in the document.
                                                                                                          Page 112 states that the wchanges in habitat availability and
                First. the recommendation to lease the area     for development                           value from development. combined with increased harvest, could
             relies heavily on the argument that it will significantly improve                            result in a major population decline ... I of the Porcupine caribou
             our nation's national security.    However, the report fails to                              herd.
             analyse this statement and lacks any facts to back up the
             statement.   Chapter VII states that if any oil is found in the                                 The report points out the adverse affects that leasing the
                                                                                                          entire ar;a will have on other wildlife:
         4   1002 area, at-its high point of production (the year 2005). it
             will satisfy only four percent of U.S. oil demand.      That leaves
             roughly 96 percent of oil consumed by the U.S. coming from                                       1. Muskoxen - nearly 75% of high use    calving habitat could be
             elsewhere. Thus the draft report fails to demonstrate that                                   lost and could result in a major decline     of the herd (p. 113).
             development of the Arctic Refuge coastal plain will either make                              And, major negative effects on muskoxen population could occur
             the U.S. energy self-sufficient. or be able to "significantly                                (25-50% of population may decline or change distribution (p.114).
             reduce the economy's vulnerability to world oil market changes*
             as stated on page 164. These false statements must be corrected                                 2. Polar Bears - because of the small number of bears the
             to reflect the report itself.                                                                population can sustain little mortality.     Moderate impacts can be
                                                                                                          expected. The study notes that development is not likely to
                Furthermore. the draft report fails to look at any                                        effect the overall survival of the species so long as similar
             comprehensive planned approach to U.S. energy needs.       Such an                           intensive development does not occur along the entire north coast
             approach would rely on conservation and alternatives      to oil and                         of Alaska and Canada.    However, the study fails to analyse
             gas that will make the United States less vulnerable      to world oil                       cumulative impacts of development in arctic Alaska and Canada.
             market changes. Even the National Energy Policy Plan developed
             by the Department of Energy in 1985 states that energy conserva-                                3. Snow geese - major reduction or change in distribution from
             tion has proven to be the most expeditious way to reduce the                                 loss of habitat and loss of feeding areas. Number of geese
             need ;or new or imported energy resources; and in fact it now                                staging in 1002 area is expected to reduce by 50%.
             contributes more to balancing our national energy ledger than
             does any single fuel source." Defenders believes that measures                                  These impacts on the wildlife. described in the draft
             to increase energy conservation, such as the recently vetoed bill                            assessment, are significant. The report also fails to
             that would have reduced energy consumption by major appliances                               demonstrate how development could take place in an
             need to be implemented and examined in this report as an alterna-                            Senvironmentally responsible manner" with regard to water and
             tive to achieving energy security before one begins to cry wolf                              gravel resouces and air and water pollution.      In fact. again.
             about the national need to develop the Artic Refuge.                                         just the opposite is true: the report demonstrates that one would
                                                                                                          not be acting in an environmentally responsible manner if they
                 The draft suggests that the only way to fill the U.S.       need                         agreed to this type of development on the refuges's coastal
             for energy resources is to develop the coastal plain      of the                             plain.
             Arctic Refuge. The refuge is put forward as a virtual panacea for

                                               3                                                                                             4

                  Oe                                                                                             WitDUFF
      Ir @em WILDUFf
            other Criticisms of the Draft Assessment                                                         Furthermore. instead of Just giving the 19% and 26% figures
                                                                                                          the draft assessment should show that these percents are simply
               Besides this considerable lack of support in the assessment                                two possible financial and economic scenarios. The assessment
            for the Secretary's recommendation for full-scale leasing and                                 should provide a spectrum of percentages in order to give a full
            development of these refuge lands. there are several other -                                  analysis of the   si tuation. For example. the draft assessment        _.
            serious shortcomings in the resource assessment for the coastal                               should include a probability distribution for prices and costs as
            plain of the Arctic National Wildlife Refuge:                                                 well as field sizes.
               1. Failure to look at alternative energy policies and other                                   The effect of the high oil price assumptions by DOI is to
            ways to achieve national energy security. The National                                        project a much higher profitability rate for the oil-producing
            Environmental Policy Act demands that alternative ways to medt                                projects than would be the case for an oil price estimate In
            objectives (meeting the national need for energy appears to be                                keeping with MKS projected growth rates.
            the goal of this environmental impact statement) should be
            examined. A thorough analysis of alternative energy programs and                                 S. According to the draft assessment (p. 165) the value of the
            policies that would make development of these lands unnecessary                               Net National Economic Benefit from the average field size of 3.2
            is needed.                                                                                    billion barrels is likely to be $14.6 billion. The 95th
                                                                                                          percentile shows that the NNED (with optimistic economic
               2. Failure to justkfy leasing the area in light of there only                              assumptions from a field size of 9.2 billion barrels will be $9.4
            being a 19% chance of discovering oil and gas.                                                billion. To get the total expected value of the NNEB from these
                                                                                                          field sizes. the DOI should have multiplied by the marginal
               3. Failure to develop a comprehensive and rigorous economic                                probability (19 percent), to yield values of $2.8 and $1.8 bil-
            analysis, including how leasing and development during a time of                              lion respectively for the NNES.     These are the values that should
            depressed market value for leases and oil due to an oversupply of                             be used to estimate the monetary benefits that are derived from
            oil, will benefit the national economy.                                                       oil and gas production in the 1002 area.      Furthermore. keeping in
                                                                                                          mind the point made in #3, if the NNEB is calculated using an oil
               4. Failure to develop a realistic assessment of the marginal                               price estimate that is too high. the benefits of producing oil
            probability of economically recoverable oil and gas being found                               will be over-estimated, and the resulting balancing of the costs
            on the coastal plain of the refuge. This failure results in an                                and benefits of the project will be misleading.
            overestimate of the Net National Economic Benefit. The (NNEB is
            based on several assumption including the minimum field size                                     6. Failure to explain why the United States should develop and
            likely to be economically produced, and the future oil price.) In                             expend its oil resources. during an oil glut (when prices are low
            the most I ikely scenai ro. the draft assumes that by the year 2000                           and oil readily available).      Furthermore, the assessment should
            the price of oil will be $33.00 per barrel (p. 72) in 1984                                    explain why. with the current low oil price the U.S. wouldn't
            dollars. To reach this value the price would have to grow at an                               better serve its national security interests by purchasing more
            average rate of 40 per year (starting from an oil price of        about                       oil for the nation's Strategic Petroleum Reserve. and saving U.S.
            018 per barrel).                                                                              oil.
               The Mineral Management Service of the Department of the                                       7. Failure to release for public review geologic data critical
            Interior uses three oil price growth rates in calculating @the                                to determining the possible resources of the 1002 area. The
            margional probability of economically recoverable oil being found                             federal government. state of Alaska. and oil industry have the
            in OCS areas: 0, 1. and 2 percent per year (KKS - Proposed                                    information, only the American public does not have the same
            Program 5-Year Outer Continental Shelf Oil and Gas Leasing                                    advantage.
            Program for January 1987- December 1991, Detailed Decision
            Document. Feb. 1986. Appendix F). The 4 percent growth rate used                                 8.  Failure to address the effects of. and ensure the control
            by DOI in this draft assessment is twice the highest growth rate                              of air and water pollution and other toxic chemicals (drilling
            assumed by the MMS.    (Using the optimistic assumption of an oil                             muds. and oil spills). such as those found at Prudhoe Bay. on the
            price of 040.00 per barrel means that the yearly growth rate is                               wildlife population of the refuge if it was developed.
            approximately 4.9 percent.)    Why has the Department of the
            interior used growth rates in this draft assessment which are                                    9. Failure to demonstrate how water and gravel supplies will
            higher than that used by the MKS? Defenders recognizes the                                    be obtained without damaging the environment.       in light of the
            uncertainty of estimating future prices of oil, but believes that                             following statement found on page 75 the water and gravel issues
            this assessment should follow the standard proceedure used by the                             need to be much more fully analysed: 0 ... specific locations and
            NKS.                                                                                          sources of water and gravel for exploration and development
                                                                                                          activities have not been identified; it is understood that these
                                                                                                          resources. especially water, are not readily available on the

                                               5                                                                                             6

      "-@efenders                                                                                 '-De
                                                                                                        fqiOers
                OF WILDLIFE                                                                                OF WILDLIFE
           1002 area."                                                                                 wildlife could be saved if it moved elsewhere or adapted to the
                                                                                                       development.   Rather the wildlife must be saved in its wilderness
              10. Failure to analyse the cumulative impacts of development                             setting. This refuge is.not the place to see if we can manage
           from oil and gas leases, including: Beaufort sea OCS (Sale 97)                              the wildlife and keep up its numbers while development occurs.
           21.2 million acres; adjacent state lands - over one million                                 the rest of the north slope has already been devoted to that
           acres; and, lands in Canada. These cumulative impacts must be                               course. The refuge was established to protect wildlife in
           addressed in the environmental Impact statement.                                            wildlands and that continues to be its greatest value to this and
                                                                                                       future generations.
              11. Failure to deal comprehensively with the Native villages
           that will be affected by development. Although. Kaktovik is                                    We agree with the Interior Department's statement thats
           discussed in some detail, Arctic Village and Venetie in Alaska,
           and Old Crow and other villages in Canada are hardly mentioned.                                moil and gas development will result in widespread, long-term
           exceptto say that effects on them will be secondary and                                        changes in wildlife habitats. wilderness environment. and
           therefore are not discussed in the assessment. Furthermore, the                                Native community activities. Changes could include displace-
           list of contributers to the report lacks either an anthropologist                              ment and  reduction in the Porcupine caribou herd.0 (p. 6)
           or a sociologist.
                                                                                                           However, this statement only points out more clearly that
              12. Failure to explain why it will take 10-15 years to bring                             development  of this area should not occur. we should not "change*
           the 1002 area on line when Prudhoe only took nine years.                                    the wildlife habitat or the wilderness environment of this area.
                                                                                                       Furthermore, Defenders believes that there to no need for further
              13. Failure to discuss the proposed land trades. the effects                             exploration of the area. because this area should not      be
           this will have on the areas why the Department of the Interior                              developed, and If practices to conserve energy and find
           believes that this would be the best route to go if the area were                           alterntives are implemented -- it may never have to be developed.
           opened, and what other options DOI has looked at or is                                      Defenders of Wildlife therefore strongly urges the Department of
           considering.                                                                                the interior to recommend that the entire 1.5 million acre area
                                                                                                       of the Arctic National wiidife Refuge be designated as part of
              14. Failure to discuss the Northern Yukon National Park, and                             the National Wilderness Preservation System.
           the international treaties applicable to the wildlife from this
           area.                                                                                          We greatly appreciate your consideratio of these comments.

              15. Failure to consult with the    Canadian government before
           releasing the draft document, even though Section 1005 of ANILCA                                                          Sincerely,
           expressly requires consultation.                                                                                          6?g@w
              16. Failure to discuss the Porcupine caribou herd agreement
           with Canada currently being considered and the need to                                                                    Amy Wlbred
           cooperatively manage this international wildlife.                                                                         Alaska Specialist
              17. Failure to analyse when Prudhoe Bay reserves will demi-                              AS:dlt
           nish. given that West Sac and Milne Point other known reserves
           are not being developed at this time.

              18. Failure to mention that in Alaska. less than 6 percent of
           U.S. oil reserves are estimated to be under designated or
           potential wilderness areas. including the Arctic National
           Wildlife Refuge. Congress made sure that those lands with the
           greatest potential for oil were excluded from wilderness
           designation or potential designation.

           Conplusion:

              Oil development in this crown jewel of the National Wildlife
           Refuge System will result in the loss of its wilderness character
           and in the decline of its wildlife. Defenders of wildlife
           believes that the crux of this issue is not to see how much

                                              7                                                                                           8

    Comments of Amy Skilbred, Alaska Specialist for Defenders of Wildlife
    before the U.S. Department of the Interior, Regarding the Draft Arctic
    National Wildlife Refuge, Alaska, Coastal Plain Resource Assessment, January
    9, 1987.

    	Good day. I am Amy Skilbred, Alaska Specialist for defenders of
    Wildlife. Given the time constraints on oral statements for this hearing I
    will briefly summarize defenders main concerns with the Draft Arctic
    National Wildlife Refuge, Alaska, Coastal plain Resource Assessment.
    Defenders will be submitting more detailed written comments by the
    January 23 deadline.

    	Before getting into our concerns I commend the staff of the Fish and
    Wildlife Service, Bureau of Land Management, US Geological Service, and
    Mineral Management Service for the considerable time and effort they have
    put in developing this draft assessment.

    	One of the major biatant problems with the report is that it does not
    substantiate the Secretary's Recommendation (Chapter VIII) to lease the
    entire coastal plain of the Arctic National Wildlife Refuge for oil and gas
    development.

    	Specifically, the statement in the Secretary's Recommendation that
    Development of its (the 1002 area's) potential oil and gas resources could
    make a significant contribution to the economy and security of this
    Nation, and could be done in an environmentally responsible manner
    based on lessons learned at Prudhoe Bay, on the 1002 area and elsewhere"
    rings hollow to someone who has read the entire report.

    	The recommendation to lease the area relies heavily on the argument
    that it will significantly improve our nation's national security Let's look at
    exactly how significant the report says the contribution to the economy and
    security of the Nation" will be if development proceeds. Chapter VII shows
    that if any oil is found in the 1002 area, at its high point of production
    (2005), it will only satisfy 4.1 percent of U.S. oil demand. That leaves
    roughly 96 percent of oil consumed by the US coming from elsewhere To
    say that this would be a significant contribution to the economy, or that it
    would contribute significantly to National _______ highly subjective at
    best.

    	_______ any additional  barrel of oil produced may reduce US
    _________ ___ _ barrel of foreign imports but developemnt of ___ ___

    plain of the Arctic National Wildlife Refuge will not make the U.S. energy
    self-sufficient, nor will it be able to "significiantly reduce the economy's
    vulnerability to world oil market changes" as stated on page 164.

    	To tell the Amaerican public that this is the case is misleading. only a
    comprehensive and planned approach to U.S. energy needs emphasizing
    conservation and alternatives to oil and gas will make the united states less
    vulnerable to world oil market changes.

    	It is interesting to note the references that are made to the National
    Energy Policy Plan developed by the Department of Energy in 1985. This
    Plan states that energy conservation has proven to be the most expeditious
    way to reduce the need for new or imported energy resources; and in fact it
    now contributes more to balancing our national energy ledger than does any
    single fuel source."

    	Conservation of oil resources should be the cornerstone to any national
    energy policy. HOwever, the conclusion of the report does not mention the
    role conservation would play rather it stresses the overriding national need
    and national security interests in developing the 1002 area and puts forward
    the coastal plain of the refuge as a virtual panacea to the problem of
    American dependence on imports. Development of the Arctic Refuge will not
    solfe natinial security  questions which arise because of the U.S. dependence
    on imports.

    	Defenders believes that measures to increase energy conservation
    such as the recently vetoes bill that would have reduced energy
    cunsumption by major appliances (saving approximately 1 billion barrels of
    oil by the year 2000) need to be implemented before one begins to cry wolf
    about the natinal need to develop the Arctic Refuge.

    	The second part of the secretary's recommendation states that
    development "could be done in an environmentally responsible manner
    based on lessons learned at Prudhoe Baly , on the 1002 area and elsewhere"
    and goes on to say that "although, circumstances within the 1002 area may
    be somewhat different, the evidence derived from the Prudehoe bay
    experience leads one to be quite optimistic about the ability to explore for
    and develop the hydrocarbon potential of the 1002 area without significant
    _________ effects on the unit's wildlife resources. These statements again
    fail to _________ anyone who has read the report that ________ __________
    will not be greatly affected by development in. In fact, the statement is
    contradicted by teh discussion of environmental consequences of leasing the
    entire 1002 area (page 112) which states that ______  _______________.

    availability and value from development, combined with increased harvest,
    could result in a major population decline" of the PCH.

    	The same chapter also goes to lengths to make it claer to the reader
    that the dynamics, wand density differencese between the PCA and the CAH
    (page 106) caution against one drawing any conclusions about the effects
    leasing the entire 1002 area will have on PCH, from CAH'S experiences at
    Prudhoe Bas, as appears to be done in the Secretary's Recommendation.

    	The draft chapter of the Secretary's Recommendation appears almost
    to have been developed separately from the assessment itself.

    	Besides the lack of support for the conclusion in the assessment itself.
    there are several other omissions and inadequacies in the report. Including:

    	1. Cumulative impacts of development are not addressed. Several
    places in the assessment mention possible off shore development in the
    Beaufort Sea and the probability of additional State and private development
    if the refuge is opened to leasing. According to the National Environmental
    Policy Act these cumulative impacts must be addressed in an environmental
    impact statement.

    	2. The draft fails to include the Frisked" estimates throughout the
    chapter assessing the oil and gas potential of the 1002 aera. The assessment
    cites a document by the Mineral Management Service called Estimates of
    undiscovered, Economically Recoverable oil and gas Resources for the outer
    continental shelf as of July 1984. This MMS document consistently gives the
    "marginal probability of hydrocarbons" along with the risked Mean" when
    comparing areas that have yet to be developed. The draft assessment fails
    to do this in Figure III-2, and Table III-1 Thus skewing the information.

    	One of the most sailant points about any possible development in the
    1002 area is that there is less than a one in five chance of finding anything
    This point is underplayed throughout the document and not even mentioned
    in the executive summary or the Secretary's Recommendation. Only if this
    condition is met will any oil be recovered from the refuge's coastal plain.
    The odds are one in five. a crap shoot that industry may well be willing to
    take, but not necessarily a gamble with a unique national treasure that
    should be allowed

    	By factoring in this 19 percent marginal probability the risk
    probability is ______ _____ ______ ______ ______ ______ ______ _____

    sharply reduced form 3.2 billion barrels to 0.6 billion barrels (barely two
    months worth of oil at present rates of US consumption)

    	3. The most liekly and optimitic economic scenarios for developement are
    based on crude oil market price of $33 and $40 per barrel in the year 2000 given
    today's price of $18 per barrel and using the mineral management service's greatest
    estimate of growth ( increase in barrel price) 2% $33.00 per barrel will not be
    reached until the year 2023. In fact DOI has used an estimate of 5.1% and 5.9%
    growth per year respectively, contrary to MMS'S customary practice of using 0.1
    and 2% growth.

    	4. The graft assessment fails to deal comprehensively with the
    Native vilalges that will be affected by development. Although, Kaktovik is
    discussed in some detail Arctic vilalge and venetie in Alaska, and Old crow
    in Canada are hardly mentiioned, except ot say that effects on them will be
    secondary and therefore not disucssed in this assessment. We believe that
    this critical factor in assessing the impacts of developing the coastal plain of
    the refuge needs to be discussed. FUrthermore, the list of contributers to the
    report does not include either an anthropolgist or a sociologist, leaving on to
    question the importance placed on the effect development may have on
    subsistence.

    	5. Besides the effects on the caribou, already mentioned and the
    thorough job done in the report, muskoxen and snow geese and polar bears
    in the 1002 area stand to be aversely affected by development.

    	Based on a thorough review of the report and other information
    Defenders of Wildlife believes that the 1002 area of the Arctic National
    Wildlife Refuge should be recommended for inclusion in the National
    Wilderness Preservation system, as its highest and best value is for the
    wildlife found in this pristine and unique arctic ecosystem.

                                                                                                                                                                                              Page 2

                                                                                                                      The draft report does not mention much of the effects of natural gas
                                                                                                                      development other than the effects would not be much greater than oil alone
                                                                   January 19, 1987                                   since gas was not expected to be economically recoverable in the next 30
                                                                                                                      years. Congress should have more information than that if it is to decide if
                                                                   Sandy O'Brien                                      gas leasing should occur with the oil leasing process.
                                                                   Conservation Chairperson
                                                                   Dunes Calumet-                                     7he effect of the inevitable accidental spills of crude oil and refined
                                                                   Audubon Society                                    petroleum Products is minimized in the report. The 1978 spill of 658,000
                                                                   5603 Mississippi St.                               gallons and the 1979 spill of over 200,000 gallons mast have at least killed a
                                                                   Hobart, IN 46342                                   great deal of vegetation. The consequences to the abundant coastal marine
                                                                                                                      fish, birds, and wildlife of a spill there would be major. 7he 50,000 barrel
            U. S. Fish and Wildlife Service                                                                           maximum spill design of the valve locations an TAPS still allows for a large
            Division of Refuge Management                                                                             spill. Detgcting and trying to clean up a spill would be very difficult during
            2343 Main Interior Building                                                                               the frequeA fog, blowing snow, and whiteouts of the 1002 climate.
            18 and C Streets MW
            Washington, D.C. 20240                                                                                    The Native Inuplat Eskimos in Kaktovik would suffer the loss of their
                                                                                                                      traditional subsistence way of life with the oil development of the 1002 area.
            Dear Sire and Hadams:                                                                                     Although they have recently entered partly into cash economy, they can still
                                                                                                                      pursue their traditional culture and subsistence without oil development. The
            "As letter pertains to the draft Arctic National wildlife Refuge, Alaska,                                 monetary benefits to those individuals who get jobs during the development
                                                                            So       has a
            Coastal Plain Resource Assessment. The Dunes Calumet Audubon Society                                      could easily be outweighed by the loss of the traditional life of the group,
            mimber of concerns about the oil and gas leasing and this draft report.                                   including the aesthetics of the wilderness they now use. The rnupiat of Canada
            "The 1002 area is the most biologically productive part of the Arctic Refuge                              who.depend on the Porcupine Caribou hard would be affected too.
            for wildlife and is the center of wildlife activity on the refuge" and                                    Major to moderately severe effects from oil development on caribou, muskoxen,
            virtually the entire 1002 area would qualify as wilderness wider the Wilderness                           wolves, wolverines, brown bea a, polar bears, snow geese, golden eagles, and on
            Act the draft report states on page 46. Although the mean conditional estimate                            vegetation, wetlands, and terrain types as described In the report are too
            Of economically recoverable oil is an impressive 3.2 billion barrels, there is                            great of a price to pay for the benefits of oil from the 1002 area of the
            an 60 Percent chance that no economically recoverable oil will be found. Even                             Arctic Refuge. The scientific value of having undisturbed arctic ecosystem to
            under the 3.2 billion barrel full leasing estimate, only 4.17 percent of                                  study would be lost as well.
            national Oil demand is Projected to be filled by the 1002 area during its peak
            of production in the year 2005. The 1002 area is projected to provide only                                The draft report, althougb It acknowledged the importance of vegetation and
            0.91 Percent of national demand in the year 2000. While it could be helpful,                              briefly described 17 cover types and 6 terrain types, did not mention anything
            the 1002 area can hardly free the u.s. from the economic and national security                            about the botanical diversity of the 1002 area. Only about six vascular plants
            hazards of foreign oil dependence. While the mitigation recommendations in the                            were mentioned specifically, and five of these were by common name. It is
            draft report seem very thoughtful, we feel the 1002 area is too valuable to                               difficult to convey the biological worth of the 1002 area without adequate
            risk in gas and oil development. Ite Arctic Refuge has just one coastal plain.                            description of the flora in the report.
            Other area such as the Alaskan state lands west of the Caming River could be
            found to be productive and able to take over when the Prudhoe Bay fields                                  Itiank you for noting our comments on the &aft report and opposition to oil and
            decline.                                                                                                  gas leasing.

                                                                                                                                                           Very sincerely yours,

                                                                                                                                                           Sandy O-Brien
                                                                                                                                                           Conservation Chairperson
                                                                                                                                                           Dunes Calumet Audubon Society
                                                                                                                                                           5603 Mississippi St.
                                                                                                                                                           Hobart, IN 46342

    	ENVIRONMENTAL DENFENSE FUND

    	444 Park Avenue South
    	New York, NY 10046
    	(212) 686-4149

    				February 3, 1987

    	U.S. Fish and Wildlife Service
    	2343 Main Interior Building.
    	18th and c Streets, N.W.
    	Washington, D.C. 20240

    	Attn: Division of Refuge Management

    	Gentlemen:

    	Enclosed are the comments of the Environmental Defense
    Fund on the Draft Arctic National Wildlife Refuge, Alaska,
    Coastal Plain Resource Assessment.

    		Sincerely,

    		Micheal oppenheimer
    		Senior Scientist

    ND/la
    Enclosure

    	COMMENTS OF THE ENVIRONMENTAL DEFENSE FUND
    			ON
    	DRAFT ARCTIC NATIONAL WILDLIFE REFUGE, ALASKA,
    		COASTAL PLAIN RESOURCE ASSESSMENT.

    			November 1986

    	These comments of the Environmental Defense Funde on the proposed Draft
    ANWR costal Plain Resource Accessment are limited to duscussion of potential
    impacts of development on air quality. acid deposition, and the consequences
    thereof. We shall argue that air quality-related impacts are potentially
    significant. The assessment is characterized by a near total absence of
    discussion of such impacts, and reports no air quality modeling. It is thus
    seriously deficient.

    	1. The Draft assesment is virtually devoid of discussion of potential
    impacts of development on air quality.
    	The assessment is seriously deficient in this regard. In particular,
    there is no discussion of the possible consequences for biota of low levels of
    air pollution below the MAAQS. Nor is there any discussion of the size or
    consequences fo the deposition of these pollutants into the terrestrial
    environment. Nor is there any discussion of potential impacts of such
    deposition on equatic ecosystems. Nor is there discussion of mitigating
    alternatives involving monitoring or technological control of emissions.

    	2. potential ambient levels of ozne (0) are significant in terms of
    impacts on teritorial ecosystems.

    	Ozone is a well known phytotoxin. Although studies of ozone effects on
    plant species common to ANWR area are lacking, it may be assumed that the
    effects of ozone noted for a wide range of other species, both annual and
    parrenial, will occur. These effects include reduction in photosynthesis
    and visible leaf damage. It is suspected that ozone contributes to long term
    growth reductions observed braodly for forests in the eastern U.S.

    	3. protected concentrations of ozone are significant in this context.
    	No hydrocarbon and carobon monixide emissions from development
    activities may be expected to increase ozone concentratons. Annual mean
    ozone measurements during 1979-80 at APrudhoe Bay indicate an increase of 3-4
    ug/m3 due to activity at the site with total annual means exceeding 40
    ug/m3 (about 23 ppb) ANWR development may be smaller than that at Prudhoe
    Bay; an air emissions ratio of 1/3 is estimated for the two sites. A rough
    estimate suggests that incremental 03 concentrations NAAr the ANWR site
    may be larger than 1 ug/_ abover background values. The effects of such
    Increases are not considered in the assessment. Nor is any air quality
    modeling presented for the specific site involved. FUrthurmore, the measured
    value characterize a period of low activity at prudhoe Bay. Aiar quality
    modeling based on 1986-87 activity levels at Prudhoe Bay indicate factor of 10
    increases for __ compared to 1979 measured values. Although moedels are
    conservative and no_ increaes cannot be translated easily into
    concommitant 03 changes, much higher no- concentrations may mean such
    higher 03 both at the site and downwind.

    		-2-

    	Even incremental increases of 1 ug/3m must be considered as significant
    sicne no damage threehold for plants due to ozone has been developed. In
    addition, the observed background values at Prudhoe Bay, as elsewhere, are
    large, so that biological consequences may occur for small pollutant
    concentration increases. for instance, observed damage to some plants in much
    less extreme environments has been observed for total ozone levels as low as
    40 ppb in regions where background levels may be considerably higher than
    those in the Arctic. Thus relatively small anthorpogenic ozone
    increaments may cause biological change.

    	4. The Assessment contains no air quality modeling of the downwind
    increases in ozone.
    	Ozone is a secondary pollutant which forms in pollutant plumes as
    transport occurs away from the source. Maximum incremental ozone
    concentrations may occur tens or hundreds of miles downwind. In thsi case,
    such concentrations could occur on the north slope of the Brooks Range.

    	5. Potential impacts of no3 concentrations and related acid desposition
    are significant in terms of impcats of terrestrial and aquatic systems.

    	Large increases in local acid deposition may occur due to no2 emissions
    at the site. No2 is a known phytotoxin as well as a source of percipitation
    and surface water acidification, Based on teh Prudhoe Bay measurements no2
    increments on site of 0.3-1.0 ug /x3 in annual mean concentration may be

    				-3-

                 expected. Using a dry deposition velocity of I cms' I this increase can be                             terrestrial species including lichens. For low concentrations and Arctic
                 converted to an incremental deposition value of up to 3 kg N02/ha-yr. N02                              species, considerable uncertainty exists on potential impacts.�L Again,
                 will be largely converted to nitric acid before deposition to soils and in                             local plume impaction as well as downwind effects may be important. No air.
                 surface water. Wet deposition of NO, from these emissions will also                                    quality modeling or discussion of downwind impacts is presented.

                 contribute to acid deposition. Based on the Prudhoe Bay measurements, total

                 acid deposition at ANWR may be equivalent to as much as 5.0 kg/ha-yr sulfuric                          6. In symmaKy. _dM Assessmen contains almost Do 4jgQMUAjM 21 and Po

                 acid deposition. These values are somewhat below thresholds for episodic                               quantitative assessment 21 AW deposition and &U Sluality relate impacts.

                 total acidification of lakes in sensitive drainage basins (o-9 kg/ha-yr).                                   These impacts are potentially very significant.

                 However, if model values of NO, concentrations from 1986-87 operations at

                 Prudhoe Bay are scaled.to the ANWR site, dry deposition alone far exceeds

                 threshold values for acidification of surface waters on an annual or episodic

                 basis. In the Arctic, transientpools of meltwater may be Important

                 environments for some animals, and sources of food for others. Since food
         2       chain disruptions occur when pH drops to only about 6.0, even partial
         CA      acidification from these emissions may have substantial environmental impacts.
                 NO2 is a relatively important source of acidification in such environments
                 because snowmalt.occurs in periods of low biotic activity when soils are

                 frozen. Thus, the NO emissions expected at the ANWR site must be
                                      2

                 considered significant. Again, no modeling is available for downwind
                 concentrations. Based on the Prudhoe Bay model values, some acidification

                 also may occur for waters at higher altitudes on the North Slope. Since no
                 modeling is presented, no quantitative conclusion is possible.3L

                     With respect to terrestrial ecosystems, negative Impacts have been noted
                 for N02 in specific, and acid pollutants in general, for a variety of.

                                                       4                                                                                                      5

                                                  REFERENCES

                 1.  F.H. Bormann. Air Pollution and Forests: An Ecosystem Perspective,
                     Bioscience 33, 434. 1985; D. Wang. F.H. Bormann, and D.F. Karnosky,
                     Regional Tree Growth Reductions Due to Ambient Ozone: Evidence From
                     Field Experiments. Environ. Sci. Tech IQ. 1122, 1986.

                 2.  W.E. Wastman, oxidant Effects on Californian Coastal Sage Scrub,
                     Science 203, 1001.1979.

                 3.  M. Oppenheimer, Thresholds for Acidification: A Framework for Policy and
                     Research, EDF. Kay. 1986.

                 4.  Arctic Haze and Its Potential Climatic-and Ecological Effects, Energy
                     and Resources Group, U. of Ch. Berkeley. 1986.

    			FREINDS OF THE EARTH
    		530 7TH STREET. S. E. WASHINGTON. D.C. 2003
    	`			(202) 543-4312

    	COMMENTS AND TESTIMONY OF

    	FRIENDS OF THE EARTH

    REGARDING THE U. S. DEPARTMENT OF INTERIOR'S

    	DRAFT ARCTIC NATIONAL WILDLIFE REFUGE
    	COASTAL PLAIN RESOURCE ASSESSMENT
    		AND REPORT TO CONGRESS

    		PRESENTED BY

    	CYNTHIA E. WILSON
    	EXECUTIVE DIRECTOR OF

    	FRIENDS OF THE EARTH

    		AT THE
    	U. S. DEPARTMENT OF INTERIOR
    		WASHINGTON DC

    	JANUARY 9, 1987

    COMMITTED TO THE PRESERVATON RESTORATION, AND RATIONAL USE OF THE ECOSPHERE

    Testimony on Draft Coastal Plain Resource Assessment
    		January 9, 1987

    My name is cynthia E. Wilson. I am the Executive Director of
    Friends of the Earth. By way of background, I was an assistant
    to interior secretary Cecil D. Andrus during the Carter
    adminisgtration and coordinated all of the Department's work on
    the Alaska Lands issue. The Arctic Wildlife Range was one of the
    areas which received an enormous amount of attention, and after
    careful consideration President Carter and Secretary Andrus
    recommended that the entire area be designated wilderness.

    Prior to that, during eight years as the Washingotn represent-
    ative of the National Audubon Society, I worked on teh various
    Alaska related issues-- the TAPS pipeline, the proposals for the
    gas pipeline, and the Alaska Native Claims settlement Act--
    which arose during that period.

    I have read the draft coastal plain Resource Assessment and
    frankly was not in the least surprised to find that full scale
    development is recommended despite the speculative nature of the
    information about potential oil and gas. Let as state out
    position clearly. Having read the information presented in the
    assessment, we remain opposed to development in the Arctic
    National Wildlife Refuge.

    The report attempts to minimize the potential impact of
    development on the porcupine caribou herd by claiming that the
    TAPS pipeline project had "minimal impact on wildlife resour-
    ces, " and projecting that experience to the porcupine herd. as
    a matter of fact, displacement of the central Arctic herd from
    traditional calving grounds as a result of oil development at
    Prudhoe has been well documented. (1) Most of the caribou who
    pose for pictures along the pipeline are bachelor buills. whose
    behavior and requirements are quite different from cows with
    calves.

    Even if you accept the characterization of "minimal" impact--
    which is subject ot dispute--this a classic case of comparing
    apples and oranges, The fact is that the porcupine herd is
    migratory, while the central Arctic herd is not. The costal
    plain in ANWR is relatively narrow and bounded by the Brooks
    Range on one side and the Beaufort Sea on the other. The
    concentration of caribou on the ANWR calving grounds is fourteen
    times greater than the concentration of caribou on the calving
    grounds of the Central Arctic herd. In a classic understatement,
    the report on page 112 states. "Given the geography of the
    calving areas and the current densities ( of the porcupine herd)
    in those areas, the availability of suitable alternative habitats
    is not apparent."

    Although the calving grounds are only a fraction of the herd's

    entire range, they are clearly the most crucial fraction. if this
    area is disrupted. the impacts could be severe. Calving grounds
    are selected because they offer a unique comination of
    conditions that favor survival. These include early snow molt.
    earlty growth of new plants, cl______ to insect relief habitat
    and lack of predators. These conditons are not present in many
    parts of the Refuge:

    The 1002 report does not show the complete calving grounds of the
    porcupine herd, which includes the entire 1002 area. However, it
    does show the high use of the area between the Hulsbuls and
    Aichilik Rivers. The places of concentrated calving activity
    vary from year to year and in some years, therer are no
    "concentrated" areas.

    During years when snowmelt is early, calving takes place north of
    the foothills, out onto the coastal plain. The conflicts with
    oil development in those years would be extreme. Since calf
    survival rates are higher when calving takes place north of the
    foothills (2) The impact of oil development on the caribou
    population would be higher in these years. This does not appear
    to have been considered in the 1002 report.

    Right after calving, the caribou cow's energy reserves are at
    their lowest. At the same time, millions of mosquitoes hatch out
    and become a severe problem. Their haraesment drives small
    "nursery bands" of caribou cows with calves into huge aggregates
    in an attempt to escape. In some years, tens of thousands of cows
    with calves gather near the coast south of cowden Bay one of the
    proposed drilling sites.

    To escape the insects, caribou move almost continually, Access
    to forage and habitat which provides relief from insects is
    crucial at this time, and insects contribute to the high death
    rate for calves. Research at prudhoe Bay has demonstrated that
    large mosquito harassed groups of caribou do not readily cross
    beneath elevated pipelines (3) Disturbance from oil exploration
    and development activities would add stress at a point in the
    caribou's life cycle when additional stress cannot be tolerated.

    We beleive the proposal to lease the 1002 area, but delay work on
    the area described as "concentrated calving grounds" is simply a
    sop for public relations purposes. Once development begins in
    the Refuge, the impacts on the herd will likely be irreversible.
    Who will enforce the sripulations that are supposed to mitigate
    the impact--Where is the aray of enforcement personal which
    would be required and--ust as imprtant--once the oil companies
    have started work in the refuge, how will the interiro department
    resist the pressure to lease the concentrated calving area?
    Gives how little we really know despite the years of information
    gathering, it seems unlikely that any firm conclusions can be
    drawn in the few years it will take to develop the bulk of the
    coastal plain.

    In addition to the effects of the oil exploration and development
    on the wildlife resources, we are concerned about the effects on
    traditional subsistence users depenedent on the caribou. The
    indigenous people of Alaska and Canada have an ancient
    relationship with the caribou which is expressed by the
    Athabaucan people as "Every caribou has abit of the human heart
    in him and every human sa a bit of caribou heart."(4)

    Oil development would reduce access to subsistance areas used by
    the village of Kaktovik, including loss of hunting opportunities
    in approximately one half of the 1002 area. Closure of a 3 mile
    corridor on either side of roads, pipelines and developed areas
    was recommended in a workshop of caribou biologists sponsored by
    the Fish and Wildlife Service. Further restricting and caribou's
    hunting season was also recommended. (5)

    I would also like to touch on one of the most glaring flaws in
    the 1002 report-- the use of a price per barrel of $33 and $40
    in making calculations. Although we realize that by the time the
    Refuge could be developed, it is posible that prices will rise
    from today's $18 per barrel . But the fact that the viability of
    this proposal is premised on these prices shows the biss of his
    administration. Actually, when you look at the probability
    figures, and the industry's track record in predicting where
    glant fields will be found, you realize that the outcome is
    really a gamble.

    The Reagan administration has votoed legislation which would set
    energy afficient standards for appliances and diamantled
    virtually every energy conservation program, and then has the
    gall to tell us that we used to open up america's premier
    wilderness area because of national security. Baloney, if the
    administration is serious about reducint dependence on foreign
    oil, then it would be seriously working to promote energy
    conservation--instead of dismantling the solar collectors on the
    White House roof with great fanfare.

    In the mid-seventies, we heard the same national security
    arguments when the energy industry attempted to stampede congress
    into ramming a gas pipeline through the Arctic Wildlife Range. A
    coalition of environmental groups and leaders from the midwest
    managed to stem the hysteria and ultimately legislation was
    passed which set up a process for carefully selecting another
    route. But the irony is, ten years later that pipeline still
    hasn't been built and yet somehow we have managed to survive.

    I have had the exhilerating experience of flying over the Arctic
    Refuge and seeing the vast herds of caribou. It is a sight i
    will never forget, and one which i hope future generations will
    have the opportunity to enjoy. It makes absolutely no sense to
    tear up this wilderness area on the chance that it may contain
    economically recoverable quantities of oil--especially when
    according to the report (p.30) fields in East Texas and elsewhere
    still have greater reserves which would be far easier to extract.

                   The American people are willing and able to practice conservation
                   If our leaders show the way until alternative forms of energy
                   are given more priority and-an energy conservation  program to In
                   place, the only real reason to open the Arctic Refuge Is greed.

                   References:

                   1. Dau, J.K. and Cameron, R.D., 1985, "Effects of a road system
                   on caribou distribution during calving: 4th International
                   reindeer/ caribou symposium," Whitehorse. YT, 1985.

                   2.  Hauer F. J. and others,1983 in Garner, G. W.and Reynolds. P.
                   E., editors. i982 update report. baseline study of fish, wildlife
                   and their habitats, U.S. FWS.

                   3.    Curatolo j.A. and Murphy, S. H.. 1983, Caribou responses to
                   the pipeline/road complex to the Kuperak oil field. Alaska, 1982.

                   4. Slobodin, R., 1981, "KutchLin," In North American Handbook:
                   Smithsonian Institution.

                   5. Report of the Caribou impact Analysis Workshop. Arctic
                   National Wildlife Refuge. November 19-20, 1985* U. S.FWS,
                   Fairbanks, 1986.

    ~0

               DO YOU W~qM~qR TO M~M~qM PUB~qUC COMMITS~?                                                               GRE ENPEAC~2qE U.S.A.

                                                                                                              P.O. Box 104432
               If you would like to speak at the hearing today, please fill In the blanks                     Anchorage. Alaska 99510
               below and turn It in to one of the Fish and Wildlife Staff members present.
               You need not complete this sheet to submit written comments. Thank you.

               Please print
               Name     ~k~1~q?~1~qn~0qA4 ~2qZ~o~l~qy~ql~e-~q@~6qZ
               ~a~L~ng~Addre~a~s                                                                                                                        TESTIMONY OF

                                                                                                                                                     CINDY LOWRY
                                                                                                                                             ALASKA  FIELD REPRESEN
               Check appropriate ~b~az below:                                                                                                          GREE~MPEACE
                 ~13 1 &a here to offer my own view.
                                   ~r~q-
                 ~qE~3~1~-~1 as speaking for
                                        ~qI~q-~Pl~ea~s~e enter dam of organization you represent)                                                            BEFORE THE

                                                                                                                                             FISH AND WILDLIFE SE

                                                                                                                                                 HEARING ON THE

                                                                                                                                  ARCTIC NATIONAL WILDLIFE REFUGE,
                                                                                                                                  COASTAL PLAIN RESOURCE ASSESSMENT
                                                                                                                                  DRAFT LEGISLATIVE ENVIRONMENTAL I

                                                                                                                                                 JANUARY 5. 1987

              My name is Cindy Lowry and I'am the Alaska Field Representative for GreenDeace,
              an international environmental organization dedicated to the protection of the
              natural environment and marine ecosystems. Our organization has offices in 17
              countries and a membership of over 600,000 in the United States alone, including
              1600 Alaskans. I am pleased to have this opportunity to present Greenpeace's
              comments on the Draft 1002 report and recommendation to Congress regarding the
              coastal plain of the Arctic National Wildlife Refuge.

              Greenpeace is opposed to oil and gas development in environmentally sensitive
              areas, a category in which the arctic coastal plain certainly belongs. The
              report's recommendation to lease the entire coastal plain is absurd in that
              it fails to adequately address the detrimental impacts of oil development to
              the ecosystem as a whole. Not only is the onshore area at risk due to the
              inherent adverse environmental affects associated with development, but also
              the sensitive marine ecosystem offshore is placed in jeopardy as well.     In
              addition, the report is lax in evaluating the cumulative effects of oil and
              gas development of offshore lease sale areas in both federal and state waters.
              We are also concerned that development of the coastal plain could accelerate
              the lease sale process in Outer Continental Shelf (OCS) waters.
              As an example of the report's %@dequacy. we make reference to its description
              of environmental consequences to marine mammals found on page 119. One
              sentence is allowed for "mitigation" of environmental Impacts for seals and
              whales which states "No mitigation beyond that already outlined for other
              species." We find it highly unlikely that all marine species react alike
              to oil exploration activities. It is evident by this section alone that
              not enough is known about the effects of oil development on marine species
              that inhabit both the nearshore waters and the coastal plain itself.

              Experience has shown that oil development brings with it a type of onshore
              Industrialization that communities are just beginning to understand. Oil
              refineries and transfer -facilities deplete fresh water supplies and encroach
              on coastal wetlands and wildlife habitats. These facilities as well as
              offshore operations themselves have also become major contributors to
              steadily worsening air quality conditions. What is known and what remains
              uncertain both point to an inevitable decline and possible annihiliation of
              thesubsistence lifestyle of the Inupiat.

              In summary, the costs and risks to the environment inherent,in oil and gas
              development outweigh any potential gains from the production of oil and gas
              on the coastal plain. The possibility of a few days of oil resources for
              the country simply do not warrant the risk of destroying this unique, fragile
              arctic environment and the adjacent sensitive marine ecosystem.

              The U.S. government needs to develop a national energy plan. To continue
              using the ploy of national security and defense as a means of exploiting
              environmentally sensitive areas is unconscionable. Clearly, if the govern-
              ment does not perceive the necessity to develop a national energy policy
              whereby the efficient use of existing reserves is promoted and alternative
              technologies to reduce the need'for oil are developed, then they should not
              object to the public demanding that environmentally sensitive areas be
              excluded from oil development. We urge that the unique arctic coastal
              plain be given the fullest protection in that of federal wilderness designation.

                                                                                                      USFWS                              -2-                February 6, 1987

                    INTERNATIONAL PORCUPINE CARIBOU COMMISSION        ALASKA                                subsistence access - like the problems in Anaktuvuk Pass and
                                        P.O. Box 200908                                                     Noatak.
                                   Anchorage, Alaska 99520
                                                                                                      2.    Your analysis failed to define the critical calving and
                                       February 6, 1987                                                     post-calving grounds of the Porcupine Caribou Herd. This.is
                                                                                                            essential information and must be addressed. In fact, by
                                                                                                            mapping just your *core" calving areas as *Resource Im lands#
          U.S. Fish & Wildlife Service                                                                      you're hiding from people the truth about what lands are
          AMf: Division of Refuge Management                                                                essential habitat for Porcupine caribou. Instead# you should
          2343 Main Interior Building                                                                       define those lands used by the Porcupine Caribou Herd for
          18th and C Streets, N.w.                                                                          calving and post-calving activities which together are critical
          Washington, DC    20240                                                                           to the future health and survival of this herd. From what our
                                                                                                            old people tell us and also from your own Fish and Wildlife
                                                                                                            Service studlear this essential habitat is much larger than the
          SUBJECT: Comments on Draft 1002 Report to Congress                                                "core" calving area you defined in your map and report. You
          Gentlemen:                                                                                        must address this issue honestly if people are to believe your
                                                                                                            reports.
          Thank you for the opportunity   to review your Ora-ft Report to Congress                    3.    For many yearst your Department has rejected or failed to act on
          on the Arctic National Wildlife Refuge Coastal Plain Resource
          Assessment.                                                                                       many Native allotments within the Arctic National wildlife
                                                                                                            Refuge. You are recommending to open some of the most sensitive
                                                                                                            areas of this Refuge to exploration and possible development
          The IPCC1a responsibility in to speak for the interests of those                                  activities while still many# many allotments have not been
          people in northeast Alaska and northwest Canada who rely upon the                                 granted yet. This shows again the disregard that your
          Porcupine Caribou Herd for subsistence.                                                           Department has held for the Native people who live In this
                                                                                                            region. We strongly recommend that the Department of interior
          First, you must know that our people are really angry about this                                  favorably adjudicate any outstanding Native allotment
          report.  It is unacceptable as written.     We hope that our comments                             applications within the Arctic National Wildlife Refuge.        In
          will help the Department do a better job in its Final Report to                                   addition, allotment applications which were not accepted or
          Congress.  At this time the IPCC does not have a position for or                                  which were rejected because of conflicts with the Wildlife
          against any alternative In the report. Our only purpose Is to                                     Refuge should be re-adjudicated so that the Native people of the
          encourage you to meet your responsibilities to deal in good faith                                 region may make a fair claim on those lands to which they would
          with the Native people of northeast Alaska and to help Congress and                               be entitled If it had not been a refuge.
          the general public to understand the importance of these decisions on
          our peoples. our specific comments and recommendation follow:                               4.    Please expand the discussion of no-hunting corridors around
                                                                                                            development areas, including (a) a map of the areas that would
          1.  With the exception of KaktovIkv your report falls to recognize                                be affected If these unwarranted no hunting zones were approved;
              or analyze the importance of Porcupine carib@u to the many other                              and (b) a fuller discussion of why the Department feels
              villages of Alaska and of northwest Canada who utilize the PCH
              for subsistence.                                                                              justified In restricting Native subsistence hunting activities
                                                                                                            near oil developments in ANWR while permitting many more people
              We believe it is   essential that your final report describes the                             to hunt near oil developments on the Kenai Wildlife Refuge.
              full range of use of Porcupine caribou by local communities. For                        5.    How would the numbers for 'economically recoverable oil
              those communities with a substantial dependence upon Porcupine                                resources" be affected if the price of oil did not go up as much
              caribou for subsistence (e.g., ArcticlVillage, old Crow and                                   as $33 (say $24 to $28)?
              Venetia)# you should fully describe their use of and dependence
              upon Porcupine caribou, and how they would be affected if the                           6.    Under "standard for environmental protection' (pl2), you say that
              herd declined or shifted its movement patterns away from village                              development will be "conducted in a responsible manner that
              hunting areas.                                                                                results In no unnecessary adverse affecta.1 Does this change in
                                                                                                            any way your existing requirements that activities be
              The report must analyze the possible effects each alternative                                 *compatible" with the purposes of the ANWR including conserving
              could have on our culture# on alcoholism, and on the future of                                 he Porcupine Caribou Herd? The IPCC strongly believes that any
              our communities. This should include all the alternatives,                                    activity within the range of the Porcupine Caribou Herd should
              including what effects the Wilderness alternative might have on

             USFWS                             -3-                 February 6, 1987

                  be compatible with the health and producivity of the herd and
                  the subsistence needs of local people.

             Thank you for the opportunity to comment. The IPCC will carefully
             look at your final report to Congress. It will be a big help to our
             people if it evidences an understanding of all the issues involved in
             this decision before it is discussed in Congress.
             S 1 7 :e@ 71@)r7'
             for Jonathon Solomon,  Chair
             International Porcupine Caribou Commission

    ~0

               DO ~~U WANT TO MAKE PUBLIC COMMENTS?

                                                                                                                                      ARCTIC NATIONAL WI~LDLIF
               If you would like to speak at the hearing today. please fill ~t~o the blank&
               below and turn it In to one of the Fish and Wildlife Staff members present.                                     ~DF~C~I~S~I~ON~5 FOR T~O~E)AY-RE~S~O~UR~qC~qE
               You need not complete this *beet to submit written commute. Thank you.

               Plea~~e~'prin~t

               NAM
               ~~~ll~u~a Address ~q6~q@~qj~8qs I    ~4qP~q/ 0 ~A~l ~e~-~- ~i~-~qe                                                                                        Testimony Give
                                 ~,~q4~,~V~e~-                                                                                                                 to
                                                                                                                                  U~1~41TED STATES FISH AND WIL
               Check appropriate bus ~b~e~l~o~w~s
                      ~1 an here to of~f~er~m~y, own view.                                                                                                   by
                                --or-
                      I an speaking for ~q1~A~t~f~q@~q0~'~v~-~1Y~Af~"~-~)~1~V~1~1~A~- ~6qA~-~4~-~f~O~C~IA~-~r~l~d~r~( ~q0~/~;~@~:
                                        (please ~s~qi~a~t~er name of organization you represent~q)                                                             of
                                                                     e~T ~r~-~0~Q~.~0~q4 ~I~q-~O~8qR
                                                                                                                                           GEOPHYSICAL SERVICE

                                                                                                                                               ~5~8~01~-~S~l~i~v~er~ado

                                                                                                                                            Anchorage. Alaska

                                                                                                                                                  on ~be~r~s~a I ~f of

                                                                                                                          INTERNAT~InNAL AS~SOC~IAT~I~ON~O~F GE~qO~q!

                                                                                                                                                         In

                                                                                                                                                 Anchorage. Ale

                                                                                                                                                         on

                                                                                                                                                  05 January I

                                                                                                        We agree with the writers of the report when they say that any
                                              ANWR

                                                                                                        adverse environmental      effects    of additl0FIftl   geological     tind

                                                                                                        geophysical exploration would be negligible.             On page 99    the
                         DECISIONS FOR TODAY--RESOURCES FOR TOMORROW
                                                                                                        report says those effects could be expected to be the same              as

                                                                                                        during the 1984 and 1985 seismic surveys. and on Page III It says
              I am Lonnie 0. Brooks. Marketing Manager of Western U.S. for                              the effects from those surveys were negligible.               The summer
              Geophysical Service Inc.. the company that conducted most of the                          following those surveys. the USFWS ANWR      .Assistant Manager, along
              geophysical field work that formed t        .he base for the petroleum                    with two other persons. hiked across the Coastal Plain with a map
              resou@ce evaluation Included in the 1002(h) report.              I am a                   of the seismic lines in hand.            The hikers crossed 15 of the
              geophysicist. registered In the State of California.           I appear                   seismic lines and were able to detect visually only 7 of them.
              before you today testi,fying on behalf of the International
              Association of Geophysical Contractors. better known as the IAGC.                         The stage Is being set for a very emotion charged Public de"te
              The IAGC Is an association whose members do virtually all the                             about the 1002 study area. Because of that it Is likely that not
              geophysical exploration for oil and gas In the free world.                                all of the discussion about the Department's 1002(h) report will
                                                                                                        be based on the evidence.         In 1971   J.E. Seriungetuk published a
              The IAGC Is strongly supportive of the recommendation of Assistant                        book called Give or        Take a. Century in which the following
              Secretary Horn concerning the development of oil and gas In                               statement appeared:      'There has been a great outcry from the oil
              Alaska's Arctic National Wildlife Refuge           and commends that                      company combine. that    the proposed pipeline. which would destroy
              recommendation to Secretary Hodel for Inclusion In the final                              Alaska's environmental    Integrity. Is needed In order to make jobs
              version of the ANILCA 1002(h) report that will be sent to                                 available for the native people."       This statement was made during
              Congress.   We believe that recommencla   tion to be required by the                      the heat of the debate over whether or not to build a pipeline to
                                                                                                        carry crude oil from Alaska's North Slope to an Ice free port in
              evidence presented In the report.      Without question the 1002 area
                                                                                                        South Central Alaska.        It was quite typical of the kind of
              of the Refuge Is one of the best places left In the world to look
              for oil and gas. We are very fortunate that It Is located In the                          emotional outpouring that occurred during that process from many
              United States and should not pass up this gift with which we have                         good people of good will.      The Trans Alaska Pipeline was destined
                                                                                                        to make the development of the oil fields of North Alaska
              been provided.
                                                                                                        possible. and Mr. 5enungetuk's forecast was that It would destroy

                                                                                                      Herd In a development scenario. the authors of the report have
           Ai8SKa's environment.     but forecasts such as that of catastrophic
                                                                                                      stated In the first Parac                                       "Because
           consequences    of   the    construction    of the pipelirse proved                                                  praph of page 106 the followings
           inaccurate.                                                                                of the greater density of PCH [Porcupine Caribou Herd) on their
                                                                                                      calving grounds, the PCH.would Interact with oil development much
           We are I Ikely to hear a great deal of the same kind of rhetoric                           more extensively and Intensively than the CAH has.interacted with
           during the debate over whethe  Ir or not to open the Coastal Plain of                      oll development In the Prudhoe Bay area." Even if         Ione were to
                                                                                                      assume that such a statement Is true. the link between that
           Alaska's Arctic National Wildlife Refuge to additional exploration
           for and development of petroleum resources. Quite likely much of                           hypothesis and a negative.impact o  .n the animals of the PCH Is very
           that rhetoric     will be     emotional    in  nature and extremely                        tenuous, because there has been no demonstration that a herd's
           exaggerated with respect to Possible           negative consequ  .ences.                   Interaction with facilities or anything else has any Impact on the
           Ironically. one of the        principal causes of concern          among                   behavior of Individuals In that herd. The authors make It seem as
                                                                                                      though they were talking about ants, not large mammals.
           professional    environmentalists during       the debate    over the

           construction of the pipeline and the associated development of the
           ollfield at Prudhoe was the caribou            that use the region.                        That habitat losses will occur Is Probably correct. That those
                                                                                                      losses will be major In the unqualified sense of paragraph 3 of
       9   principally the Central Arctic Herd.           Ironic because another
           caribou herd, this time the Porcupine Caribou Herd, Is the focus                           page 107 of the report Is          not supported by the evidence
           of most concern and because not only did a decline In the range                            accumulated during t  .he years of interaction between the Central
                                                                                                      Arctic Herd and the development facilities at Prudhoe -Say and the
           and size of the Central Arctic Herd not occur as a result of
           Prudhoe development. but the herd has more than doubled In size                            Trans Alaska Pipeline. Even less supportable Is the conclusion In
           since that development.     In the second paragraph of page 106 of                         paragraph 4 of page 112 that      the loss of habitat will possibly
           the 1002(h) report. the     authors go to some length to attempt to                        Ilead to decline or displacement of the Porcupine Herd    .on the order
                                                                                                      of 20 to 40 percent. That projection needs to be understood as a
           explain why the Central Arctic Herd did not 6ecline following
           development. ignoring      the fact     that the     Problem for the                       possibility that Is only minutely probable In the mathematical
           antidevelopment enthusiasts Is not to explain a lack of a decline,                         sense when reasonably projected from the data available.            That
           but to explain why the herd grew from 6000 animals to 14,000                               also Is the case with the statement In the second paragraph on
           between 1978 and the present.          In protesting projectl    .ons of                   page 112 which says that "the availability of suitable alternative
                                                                                                      habitats Is not apparent." That statement Is in stark      contrast to
           Central Arctic Herd experience Into the future of the Porcupine

             the data In the report.       The map of Plate 2A shows the major                             the documented evidence of the experience of the CAH, one Should
             insect relief area@, either to be In the Brooks Range foothi I Is out                         conclude that the PCH would not be expected to be significantly

             of the area proposed for development or, on the coast where                                   adversely Impacted by a petroleum development scenario with

             proposed mitigation measures would limit development operations to                            ,appropriate mitigation measures,      Including monitoring of the PCH
             thos e that are absolutely essential such as port             facilities.                     Interactions with petroleum activities.

             Additionally. that map shows large portions of high           use calving
             areas not to be where facilities are proposed and             significant                     We support the testimony presented by the Alaska Oil and Gas
             portions of those     calving grounds to be completely        outside the                     Association, and further hold that It would be a national tragedy
             1002 'area. Therefore      a fraction of the habitat of a     fraction of                     to foeego the benefits that would accrue directly and indirectly
             the PCH would be* affected.         for which there are       alternative                     to a I I Amer I cans from the deve I opment of the o I I and gas resources

             habitats within the PCH rangel                                                                that may underlie the 1002 study area of the Coastal         Plain of the

                                                                                                           Arct.Ic National'WildIffe Refuge. The benefits to so many should

             The so called core calving    area is called that because It has been                         take their proper place when wei      ghed In contrast to benefits to a
             used for calving in only      5 out of the    last 1.4 years. But that                        few who oppose development In favor of preserving the privilege of
         0
             5ame rigure neCe55ariiY implies that 64%       of the time the caribou                        an elite few, who have the time and resources to invest in

             have preferred to calve somewhere else. That completely destroys                              obtaining recreational access to an extremely remote region of

             any contention that that area is Irreplaceable In the life cycle                              Alaska's northland and want to enjoy that area without seeing any
             of the herd. To support a claim that caribou can only calve one                               signs of development. Developm        Ient of the 1002 study area of the
             place one must be able to show they do not calve othe'r places, and                           Coastal Plain will Involve a minuscule amount of the total area of
             that obviously is not the case. The same rigors ofthe scientific                              ANWR. leaving an area bigger than the state of West          Virginia for

             method are applicable to         the biological     sciences that are                         the special use of elitist outdoor recreationists.

             applicable to the physical sciences.      When one subjects less rigor
             and objective analysis to the living renewable surface resources,                                                                   Respectfully submitted.

             that are more easily observed and measured. than one does for the                                                                   INTERNA I AL ASSOCIATION OF
                                                                                                                                                 EOP - At CONTRACTORS
             non-renewable subsurface resources, that are less easily observed

             and measured, then a blas results that fuels the Irrational
                                                                                                                                                 Lonnie 0roc,k  Chairman
             emotionalism. From the data displays In the 1002(h report, and                                                                      Alaska Reg4  Governm@ntal
                                                                                                                                                 Affairs Committee
                                                                                                                                                 N ERNA     A       A  N OF
                                                                                                                                                         L@AL         T'0
                                                                                                                                                                      RS
                                                                                                                                                               'OCI
                                                                                                                                                      @A _CONT@  ACCTO
                                                                                                                                                 IETP
                                                                                                                                                 0

                                                                                                                                                 Lnnie ID Srck ' h.   Irman
                                                                                                                                                 A
                                                                                                                                                 Ias   r,
                                                                                                                                                 k  Re   L    Governminta  I

                                      National Audubon Society                                                            Divison of Refuge Management
                                                                                                                          January 23, 1987
                NA110NA1 CANIA1 0111(i M.11-UNNS)1%%N1AA%1,*Q1. S1 %S11INGION. 1@ t 210.11  11.111111I.NP,                Page 2

                                                                                                                          it is because this paper, which has stood the test of peer review, is so
                January 23, 1987                                                                                          significant, that we feel it must be Incorporated into the record of these
                                                                                                                          proceedings to assist the appropriate officials as they make recommendat ions
                                                                                                                          for a final decision and position on this issue of vital concern to all of us.

                                                                                                                          Thank you for your consideration.

                Division of Refuge Mana ement                                                                             Sincerely,
                2343 Main Interior Builling
                l8th and C Streets, N.W.
                Washington, DC 20240
                                                                                                                          Brock Evans
                Dear Sirs:                                                                                                Vice President for
                On January 9th, Mr. Peter A.A. Berle, President of the National Audubon                                     Natipnal Issues
                Society, testified in the Department of Interior auditorium on the subject of                             IOIIF
                the Draft Arctic National Wildlife Refuge Coastal Plain Resource Assessment.                              Enc.
                At the time of his testimony, he made a motion to submit to the formal record
                of these proceedings a research paper prepared by staff scientists for the
         9      National Audubon Society, t itled "Oil and Gas Resources on Special Federal
         Is     Lands: Wilderness and Wildlife Refuges," as published In the Annual Review of
         OD     Energy 1986, Volume 11, pages 143-61.
                Mr. Berle's motion was accepted by the hearing officer, and therefore, on
                behalf of Mr. Berle and the National Audubon Society, I hereby enclose a copy
                of that paper with, again, our formal request that it be incorporated into the
                full record of these proceedings as If read by Mr. Berle.
                Ibis is not a lengthy document, but it is extremely significant in the context
                of the escalating debate about whether it is appropriate to open the Coastal
                Plain of ANWR to limited or full exploitation for potential oil and gas
                resources. As Dr. Beyea shows, less than six percent of Alaska's oil is
                projected to lie within all Alaska wilderness, desi  gnated and potential
                including the coastal pl-aTn- of the Arctic National Wildlife Refuge. President
                Berle emphasized this and related research findings in our formal statement,
                and noted that Audubon has prepared a National Energy Plan which points out
                our energy needs for the future can easily be met without further exploitation
                of any protected or potential wilderness, or other protected areas, such as
                National Wildlife Refuges.

                                               14MY/ A,  Pap.,

    OIL AND GAS RESOURCES
    ON SPECIAL FEDERAL
    LANDS: WILDERNESS AND
    WILDLIFE REFUGES

    ALEX STEGE' AND JAN BEYEA

    National Aubudon Society, 950 Third Avenue, New York, NY 10022

    Of all federal lands in the United States, wilderness and wildlife refuges
    are where pressures for resource exploitation most often conflict with
    environmental and conservationist objectives. Arguments in favor of fed-
    eral leasing of thes areas to energy developers have been bolstered by
    improvements in exploration methods, major oil price increases in the
    1970s, the need to alleviate US dependence on foreign oil, and the expec-
    tation that previously unexplored federal lands would contain large oil
    and gas reserves. Advocates of energy exploitation, critical of increases in
    the amount of restricted land, have claimed that environmental restrictions
    on fedearl lands "lock up" significant energy reserves.
    	The federal following discussion critically examines this claim in light of recent
    reports indicating that very small amounts of oil and gas are located in
    regions where development is prohibited or severely restricted due to
    environmental regulatons. We compare the significance of the environ-
    mental effects of oil and gas activities with the smallness of the recoverable
    oil and gas resources estimated to lie in wilderness lands, wildlife refuges,
    and other special, federally owned areas.
    	In order to describe the sensitive federal lands which are of primary
    concern in this paper and to clarify uncertainties arising from overlapping
    land categories, we begin with a few definitions.

    'current address: center for the Biology of Natural Systems, Queens COllege, Flushing.
    NY 11367.

    0362-1626/86/1022-0143502.00              143

    144 STEGE & BEYEA
    DESIGNATED WILDERNESS

    The Wilderness Act was established by Congress on September 3, 1964

    to assure that an increasing population, accompanied by expanding settlement and
    growing mechanization, does not occupy and modify all areas within the United States
    and its possessions, leaving no lands designated for preservation and protection in their
    natural condition(1).

    This Act, along with the Federal Land Policy and Management Act of
    1976, initiated the National Wilderness Preservation System. The wil-
    derness system consists today of 88.5 million acres of land that the federal
    government has formally designated as wilderness2 (see Table1) Des-
    ignated wilderness, most of which is in Alaska, covers only 3.8% of the
    total US land area, including 17% of all National Forest land 49% of all
    National Park land, 21% of all National Wildlife Refuge System land.
    and 0.1% of all Bureau of Land Management land. (See Appendix E in
    Stege & Beyea (2) for listings of acreages of designated and potential
    wilderness under the jurisdiction of each of the four agencies)
    	Wilderness includes much of the country's most beautiful, biologically
    complex, unique, and primitive lands. Though sometimes labeled"single
    use"federal lands, wilderness areas in fact serve the public in many ways
    The protection afforded wilderness lands is vital for many fish and wildlife
    habitats, wtershed protection areas, historic preservation sites, and scien-
    tific study areas. Wilderness areas are also used for hiking, fishing,
    camping, and canoeing, and they offer the spiritual lift of peaceful sur-
    roundings. Public use of wilderness lands has increased dramatically;
    awareness of the fragility of these areas and concern for their protection
    have heightened correspondingly.
    	on designated wilderness, surface exploration(no drill holes) is allowed
    "if such acrivity is carried on in a manner compatible with the preservation
    of the wilderness environment" (3) as determined by the appropriate
    government agency (National Forest Service or Department of the
    Interior). Designated wilderness is also open to energy development in

    	'As defined by teh wilderness Act(1) wilderness is "an area of undeveloped Federal
    land retaining its primeval character and influence, without permanent improvements or
    human habitation, which is protected and managed so as to preserve its natural conditions
    and which I generally appears to have been affected primarily by teh forces of nature, with
    the imprint of man's work substantially unnoliceable; 2. has outstanding opportunities for
    solitude or a primitive and unconfined type of recreation; 3. has at least five thousand acres
    of land or is of sufficient size as to make practicable its preservation and use in an unimpaired
    condition; and 4 may also contain ecological, geological, or other features of acientific,
    educational, scenic, or historical value."

    	146 STEGE & BEYEA

    areas where mineral rights are held by private owners and in areas leased
    from the federal government before the December 31, 1983, leasing dead-
    line established by the Wilderness Act. Otherwise, designated wilderness
    is now closed to oil and gas activities by statute.

    POTENTIAL WILDERNESS

    As a part of the wilderness review process set up by the Wilderness Act
    and the Federal Land Policy and Management Act (17), the Departments
    of inteior and Agriculture must review certain roadless lands under their
    jurisdictions and report to the president on each area's "suitability or non-
    suitablility for preservation as wilderness"(18) These lands, under various
    stages of review, are grouped into the classification"potential wilderness"
    They include several federal land categories that have been identified as
    having wilderness qualities, but have yet to be formally designated as
    wilderness by Congress. Table 1 shows that there are about 129 million
    acres of potential wilderness in the United States (80 million in ALaska),
    or 5.5% of the total US land area.
    	According to the wilderness Act, the wildeness qualities of potential
    wilderness must be protected to allow for possible future designation. The
    legislation establishing certain Natioinal Park Service, National Wildlife
    Refuge System, Bureau of Land Management, and National Forest Service
    lands that are listed as potential wilderness usually has similar require-
    ments. How these restrictions on energy development are interpreted by
    the agency officials depends largely on the land management polocies of
    the existing administration. The current polocies of the Departments of
    Interior and agriculture allow, within the guidelines of their interpretation
    of the mandated restrictions, oil and gas leasing, exploration, and possible
    development on potential wilderness lands that are not closed by other
    legislation.
    	For a more complete definition of potential wilderness broken down by
    federal agency, as well as a description of regulations and polocies restrict-
    ing oil and gas activities in each of the potential wilderness land categories,
    see Appendix A in (2)

    NONWILDERNESS WILDLIFE REFUGES AND
    OTHER SPECIAL NONWILDERNESS LANDS

    Although 90% of all National Wildlife Refuge System lands are designated
    or potential wilderness 9.0 million acres of the refuge system in the con-
    tiguous 48 states are not (19). Created by a series of acts culminating with
    the 1966 National Wildlife Refuge System Administration Act (20), the
    National Wildlife REfuge System was designed "primarily"to protect fish

                                                                                RESOURCES ON SPECIAL LANDS              147                                                                                            148  srEGE & BEYEA
                                           and wildlife resources. The system is under the jurisdiction of the Fish and                                                                                                bypassing these regulations (that is, the loss of special values for which
                                           Wildlife Service (Department of the Interior) and consists ofjust over go                                                                                                   these lands were set aside).
                                           million acres, 77 million of which are in Alaska.                                                                                                                           Some of the immediate, short-term environmental impacts of oil and
                                              On about 5 million of the 9 million acres of National Wildlife Refuge                                                                                                    gas exploration on wilderness and other special federal land include:
                                           System land outside of designated and potential wilderness, oil and gas                                                                                                     I ,increased soil erosion and siltation of streams (from deforestation,
                                           leasing is prohibited by statute (12). Leasing of the remaining 4 million
                                           acres is not prohibited by statute. according to current Interior Department                                                                                                road construction, off-road vehicle travel. and landslides triggered by
                                           interpretation, although the Secretary of the Inte'rior must first determine                                                                                                explosions used in scismic exploration),
                                           "that such uses arc compatible with the major purposes for which such                                                                                                       2. disruption of surface and groundwater flow (by surface compaction.
                                           areas were established" (21). Nevertheless. the Department or interior                                                                                                      well drilling, and the extradtion of large amounts of water for drilling
                                           continues to follow its policy, established in 1958, prohibiting oil and gas                                                                                                activities) (24).
                                           leasing on wildlife refuge land in the lower 48 states (22).                                                                                                                3. persistent loud noises (e.g. from networks of seismic exploration sites.
                                              Unlike the Wilderness Act, which specifies that wilderness must be                                                                                                       where there often are continuous detonations of small explosions) (25).
                                           roadicss and undeveloped, the legislation establishing the National Wild-                                                                                                   In addition to the above impacts, the production or oil and gas causes
                                           life Refuge System does not define how to determine the "compatibility"                                                                                                     air and water pollution from (a) oil, grease, and other contaminants left
                                           or oil and gas development with the purposes of the refuge. This lack of                                                                                                    on the ground surfacei (b) -11 blowouts and subsequent evaporation or
                                           definition gives the Secretary ofthe Interior considerable leeway in deciding                                                                                               burning ofthe oil, (c) mudpit flooding or leaching, and (d) pipeline ruptures
                                           what activities should be allowed in nonwildemcss wildlife refuges.                                                                                                         or leaks (23@.
                                              Other environmentally sensitive federal lands that are of concern in this                                                                                                Although brief in duration, many of these effects can nevertheless cause
                                           paper include the nonwilderness parts of the National Park System (5.3                                                                                                      long-lasting or permanent destruction or wildlife habitat, depending on the
                                           million acres), Forest Service National Monuments and National Rec-                                                                                                         success or reclamation. Overall, roads may be the single most destructive
                                           reational Areas (1.6 million acres), and Bureau of Land Management                                                                                                          features of development. They make up a significant percentage of the
                                           (BLM) National Recreation and National Conservation Areas (9.7 million                                                                                                      area around oil and gas fields and greatly augment erosion. Roads also
                                           acres). Of these 15,6 million acres. 3.2 million are restricted by statute and                                                                                              create dust and noise, rragment wildlife habitat, including hunting and
                                           3.2 million have water supply and control as the dominant use (5). The                                                                                                      migration routes. make possible wildlife injury, or death from vehicular
                                           remaining 9.2 million acres are apparently available for oil and gas leasing                                                                                                collisions, and increase uncontrolled human access to adjacent areas (26).
                                           subject to compatibility with their dominant use.        .                                                                                                                  As an alternative to road construction, the use of helicopters for trans-
                                              Another special federal land category that has restrictions on dcvcl-                                                                                                    porting equipment necessary for oil and gas exploration into mmote or
                                           apmert is the W;IA --A                     System --U= ; -.-- _-16 -                                                                                                                                                         -    Vc
                                                                                                                                                                                                                       sensitive areas cu- be less environiment tailly destiucti . Helic-r-
                                           small area, largely within areas that fall in other federal land categories.                                                                                                is expensive, especially when heavy drill-rig equipment is needed for larger
                                           the Wild and Scenic River System is not included in the tables or remaining                                                                                                 well sizes, and road access almost always becomes necessary during the
                                           analysis.                                                                                                                                                                   development and production stages (25). This low-impact alternative to
                                              For a mom complete description of nonwildemess wildlife refups and                                                                                                       road access may become more viable with future improvements in heli-
                                           other special nonwilderucss lands, including regulations and policies                                                                                                       copter technology.
                                           restricting oil and gas development. am Appendix A in (2).                                                                                                                  The sensitivity of wildlife to human interference and habitat destruction
                                                                                                                                                                                                                       depends to some extent on the timing and duration of the interference.
                                           ENVIRONMENTAL IMPACTS OF OIL AND GAS                                                                                                                                        and the species of wildlife involved. Some species have unusually narrow
                                           EXPLORATION AND DEVELOPMENT                                                                                                                                                 requirements for particular rood, water, or cover. Many species with such
                                                                                                                                                                                                                       narrow "niches" am unable to adapt to changes in the environment.
                                           The following discuWan attests to the need for stringent environmental                                                                                                      particularly changes that occur during nesting, reproduction. Of Other
                                           regulations restricting energy development on wilderness, wildlife refuges,                                                                                                 sensitivi periods. In addition. minor disturbances that occur continuously
                                           and other special federal lands. By evaluating the environmental effects of                                                                                                 or repetitively may allow insufficient time for recovery. Periodic habitat
                                           oil and gas activities. we will bring to light some of the social costs of                                                                                                  destruction from repeated human encroachment. made possible by new

                                                                                                           RESOURM ON SPECIAL LANDS                    149                                                                                        150  STEGE & UVEA
                                                                  roads and stimulated every time the price of energy resources incre               ,ases,                                                                                        from surrounding lands. in addition, increasing human populations and
                                                                  can permanently scar an area and cause wildlife to disappear from it.                                                                                                           urbanization will result in greater numbers seeking solitude and primitive
                                                                     Disturbances that occur over a long period of time or cover a large                                                                                                          experience through recreational use of wilderness lands. Finally, growing
                                                                  area are usually caused by the "secondary effects" of expanding human                                                                                                           human populations will also bring increased demand for soil and water
                                                                  populations attracted by energy development. Often overlooked. these                                                                                                            conservation. All then considerations heighten the value of remaining
                                                                  secondary effects can cause greater detrimental impact than the more                                                                                                            undeveloped, unpolluted land.
                                                                  short-lived. intensive disturbances from the energy facilities themselves.                                                                                                      The importance of setting aside some federal lands as a safety valve
                                                                  Some of the effects of bringing large numbers of people into previously                                                                                                         gainst development was recognized by the Congressional leaders who
                                                                  undeveloped lands include an increase in urbanization. consumption of                                                                                                           :gassed the acts establishing the Wilderness and Wildlife Refuge Systems.
                                                                  limited water supplies, use of off-road vehicles. and construction of                                                                                                           However, the conflict between exploitation and preservation of wilderness
                                                                  additional roads, power lines. and other utility corridors (27).                                                                                                                and wildlife refuges continues. This conflict has been upheld by a polarity
                                                                     The effects wrought by influxes of people into areas where energy or                                                                                                         of values and by notions that the United States must choose between
                                                                  minerals are being extracted have been an important part of the historic                                                                                                        energy and environment. A close look at recent studies by the US Geo-
                                                                  process of rapid, unplanned development that has resulted in the per-                                                                                                           logical Survey (USGS) and others, giving energy resource estimates for
                                                                  manent low of wilderness quality in over 95% or the land area in the lower                                                                                                      onshore and offshore holdings, however, dispels the idea that such a choice
                                                                  48 states.                                                                                                                                                                      must be made.
                                                                     The remaining lands with wilderness qualitities are particularly sensitive
                                                                  to the effects ofoil and gas development, because they am generally found                                                                                                       OIL AND GAS RESOURCES ON WILDERNESS LANDS
                                                                  in remote areas with extreme climates, unstable hillslopes, and fragile
                                                                  vegetation. Then conditions not only make wilderness lands more sus-                                                                                                            Consider the case of oil and gas resources on wilderness lands (both
                                                                  ceptible to surface disturbance but also often create insurmountable diffi-                                                                                                     designated and potential). Table 2 shows an estimate of the amount of
                                                                  culties in reclamation. For example, landslides and other landscape scars                                                                                                       known and projected oil and gas located in the lower 48 states. This table
                                                                  often cannot be revegetated because the initial slope failure enhances                                                                                                          and other resource estimates in this paper am based primarily on figures
                                                                  Continued downhill movement of soil. The disturbed hillslope becomes a                                                                                                          traceable to 1980 data gathered by the USGS during its last complete
                                                                  conveyor belt ofmgtcrial that eventually reaches streams and fillsin gravel                                                                                                     assessment or US resources (28). These 1980 figures have been updated to
                                                                  beds vital for fish spawning. Rcvcptation is particularly difficult in arctic,                                                                                                  account for production losses subsequent to 1980. In the case of offshore
                                                                  alpine, and desert areas because plant recolonization and mgrowth is                                                                                                            resources, additional revisions have been made to account for recent
                                                                  extremely slow--sometimes taking hundreds of years or more. In some                                                                                                             (reduced) estimates of undiscovered oil and gas on the outer continental
                                                                  areas where soils; have taken thousands of years to form in balance with                                                                                                        shelf made by the Minerals Management Service (29). All adjustments are
                                                                  the coexisting plant life and climatic conditions, soil layers lost by erosion                                                                                                  described in Appendix 6 of (2).
                                                                  cannot redevelop.                                                                                                                                                               The breakdown of the total onshore oil and gas estimates according to
                                                                     The destruction of wildlife rcfugc and wilderness qualities by oil and gas                                                                                                   wilderness and other federal land Categories was derived primarily from a
                                                                  activities would last far longer than the short-term energy supply that, as                                                                                                     study prepared for The Wilderness Society by Economic Associates Inc.
                                                                  will be shown below, might be extracted from these regions. Furthermore.                                                                                                        (30)? The results of -Me wilderness Society's study of onshore resources
                                                                  the imponance ofwildernew and wildlife refuges and the demand for their                                                                                                         are consistent with a draft study prepared by the Scientists' Institute for
                                                                  use am expected to increase with time for a number of reasons. First of                                                                                                         Public Information (32).
                                                                  all, technological growth and expanding populations in this country will                                                                                                        To account for changes in wilderness acreage by the 98th Congress since
                                                                  undoubtedly result in the continued exploitation or less-developed areas                                                                                                        o The aparate figures presented by The wiwcfrms Society for the           states in the
                                                                  outside the remaining islands of protected federal lands. Such growth will                                                                                                      Waver 49 can be compared in so *PPM'imte "Y with A "caut specialized USGS report on
                                                                  decrease the area offering services similar to those orwilderness and wildlife                                                                                                  the oil and V, potmusl orwitkruen IBU& in eleyna vgatcrn mates (31). Agreement
                                                                  refuges. As the availability of land suitable for wildlife habitat diminishes,                                                                                                  the two acts of figum appears to be good. orith the USGS ropon prorctins io-a Moore*
                                                                  many animals will die out since the carrying capacity of protected areas                                                                                                        eniumucs for both designated and potential wildcrocin lands. Although a direct COmPati*00
                                                                  cannot increase to accommodate large influxes or animal populations                                                                                                             between the two studics cannot be made became different nmbcFs Of states VVEM included

    ~0

                                                                                                                    RESOURCES ON SPECIAL LANDS                    ~151

                                                                                    TAW I Quads of US ad and gas ~n~u~o~u~r~qm ~a~ti~n~tated to He on or off
                                                                                    the aborts o~(tb~e Iowa 48 s~t~s~9~qW

                                                                                                                           Petroleum       Natural ~PS

                                                                                    O~n~s~b~o~r~e an"
                                                                                    ~F~We~qW land
                                                                                       Designated ~W~i~W~a~m~e~s~e
                                                                                        ~0~2 ~an~i~f~f~io~n acres~)                 ~6 ~(~1~1~1~/~6~)        ~3 ~(0.~7%~)
                                                                                       Potential wilderness'               8  ~(1~.7%)        ~8 ~(~1.~1%)
                                                                                        (49 million acres)
                                                                                       Other onshore ~f~e~el~er~a~l I~s~u~i~l~"       77 (1~6~.~0~%)
                                                                                        ~(~3~8~1 ~O~W~H~M ~M~C~qM)                                     69 (9.5%)
                                                                                    No~nf~ed~e~rn~al ~lan~d~@                      ~J~2~0 (66.7%)     ~511 ~410.1%)
                                                                                    Offshore areas-                        69 ~(~1~4A%)       1~36 ~(~1~8~-6~1~%)
                                                                                                                                                                                                                             ~c
                                                                                       Total                               4~8~0 (100%)      ~7~N ~0~0~0~%~)

                                                                                    ~4~oc~l~u~d~e~s ~M~o~so~u~tic~a~f~t ...                  ~wA ~p~o~u~n~i~W (~a~ad~b~e~o~w~w~d~)
                                                                                                                                                                                                                                                                                       ~q3~qr
                                                                                    ~q@~z~s, him -~1- Accuses am tam ~f~t~e~e~n Table L O~d and ~a~n ~O~pm
                                                                                    ~q@ ~c~o~uv~ert~ed to ~Q~u~a~& ~u~s~ag the Following co-r~a~o~s fi~K~l~o~n: ~S 6 ~q~n~s~h Per
                                                                                            accounts A~s~so~d~q@ I= Oft modified and ~u~p~d~M~u~l to ~so-~A~r~d for
                                                                                    ~l~o~@er~,~ll~m~u~s            ~q-~p~@~h~-~g~odwi~ng~d.9~$ib~C~o~o~p~m.Ad~)~q@
                                                                                    to T~b~a W~A~d~er~n~e~w, ~So~m~et~y~'~s o~d ~o~d ps ~q@~-~- (a ~w~dd~q@ are d~6c~u~m~a~l in
                                                                                    Appendix ~3 ~o~(~qM
                                                                                                                                                                                                                                                                                ~IL
                                                                                    on ~0     (~qM ~Ib~qm ~%~t~W~w~e~s In" ~b~q- d-~m~u~r~n~e~ed to ~s~o~m~m I- ~P~-
                                                                                    ~*~x~n~a~s~.~i~nc~e 191~0 A~4~&~b~-~A ~a~dj~u~st~M~i~n~s to the o~f~f~i~d- -~1- - ~-~-~&
                                                                                                                              ~.~. fid~q" o~f~f~i~l~qm od ~a~n~d ~S~us
                                                                                    uses ram ~e~a~un~s~u~s for
                                                                                    ~q@ ~4~2~9~)~. ~B~.~Me~J~u~n~n~i~c~ut~s ~q- ~d~e~s~u~f~l~ed ~h~i ~A~p~r~e~a~h. ~B~f~(~U
                                                                                    Includes offshore rt~s~e~a- a both ~qW~e~r~a~l ~a~n~d state ~w~a~t~u~L

                                                                       The Wilderness Society         I~a study w~a~s published, a~di~m~im~c~nt~s have ~b~e~e~n~k
                                                                       made to the federal resource estimates given by them [see Appendix 8 of
                                                                       (2~q)~q1.                                                                                                                                                                                %
                                                                         A~s can be concluded from Table 2, designated and potential wilderness
                                                                       areas together hold only 2.9% of the oil a~nd 1~.8% of the natural gas
                                                                       resources in the lower 48 state&. This comes as no surprise since wilderness
                                                                       areas cover only 4. 1 % of the land area in those states (see Table 1). The
                                                                       map in Figure 1~. which shows designated and potential wilderness arm

                                                                                                                                                                                                                              ~r~L
                                                                       in t~h~e definition of ~"We~qm~- use di~f~t~q. ~i~s p~r~o~j~e~e~t~i~o~n~s on probably d~u~e to d~k~I~f~e~r~e~n~t
                                                                       or had the      ~I~n~trApp~en~d~; C ~a~f~(2~)~). Had ~t~* VSG~S ~i~b~l~orn~a~s~s study been ~a~mor~c~o~ur~np~l~e~M
                                                                                    am ~n covered ~ma~stb~od geographically the ~a~n~n examined to *A study by ~T~h~e
                                                                       ~W~ild~e~ro~e~s~s Society, its fi~s~e~n~es could haw bun used directly to Table ~3. N~q~~qW~qM do
                                                                       ~sp~pr~o~z~i~n~u~f~t ~a~p~o~c~a~m~au~t found for the West in the two studies s~u~g~g~c~a~u that ~t~h~e m~etb~odo~lo~g~y
                                                                       used by T~h~e ~qW~d~er~n~e~a~s Society c~a~n reasonably b~e ~m~p~ect~al to give ~v~W~W results ~f~o~r wilderness
                                                                       area o~v~u~A~e t~h~e Stan analysed by U~S~GS.
                                                                                                                                                                                                                                      ~8q@~'~q.~- ~qa~4qs~qi

                                                                                                                                                                                                                                     lie

    	RESOURCES ON SPECIAL LANDS  153

    in black, makes plain the confinement of wilderness to a small fraction of
    the lower 48 states land area (see Appendix c of (2) for a discussion of the
    methodology used to create the map)
    	The most recent energy/wilderness controversy in the lower 48 states
    concerns a relatively small amount of energy in the "overthrust Belt" that
    cuts through Idaho, MOntana, Wyoming, and Utah. Despite implications
    to the contrary by some energy companies, the total likely amount of
    energy resources in designated and potential wilderness parts of this region
    is almost certainly trivial from a national security perspective. It amounts
    to less than 3 "quads" of oil and 5 quads of natural gas, according to
    another study commissioned by The Wilderness Society(33) Three quads
    of oil represents about a five-week supply at current US oil consumption
    rats (34) The amount of oil and gas estimated to lie under designated
    wilderness land in the overthrust belt is, of course, even smaller.
    	Table 3 gives estimates of both known and projected energy resources
    in Alaska. Even there, only 5.6 and 8.6% of oil and gas resources, respec-
    tively, are estimated to lie in designated or potential wilderness lands,
    including the Arctic National Wildlife REfuge. Although the percentage
    of Alaska's land remaining as wilderness is large, the small percentage of
    oil and gs in these areas suggests that most Alaska wilderness lies outside
    of known or poetential oil- and gas-producing areas.
    	Table 4 combines the figures for the lower 48 and Alaska and gives the
    oil and gas estimates for the entire United States. It can be seen from this
    table that the amount of oil estimated to be recoverable on all land
    designated as wilderness is 9 quads out of a total of 624 quads--that is
    1.4% of the total. Nine quads of oil is less than a four-month supply for
    the United states. The situation for natural gas is similar; 1.1% of the total
    US supply is estimated to be located on lands designated as wilderness, an
    amount that equals a six-month supply at current consumption rates (34).
    	on a per-million-acre basis, the amount of oil and gas located on land
    designated as wilderness is projected to be only 41% of that of an average
    area in the United Staets This is not coincidential, since there are strong
    pressures, in choosing federal wilderness areas, to exclude land that
    appears highly promising from an energy standpoint.

    A quaid is a unit of energy equal to 1 quadrillion bius (british thermal units) equivalent
    to about 5.6 billion barrels of oil, or 1.03 trillion cubic feet of natural gas.
    	This study is somewhat out of date but the combined estimates for resources in
    designated and potential wilderness acreage should still be approximately correct.
    	There are 2,352 million acres of oushore land in the UNited Staets (16) Table 4 indicates
    that 1175 quads of oil and gas are located on thsi land, ie. 0.5 quads per million acres. In
    contarst only 0.2 quads of oil and gas per million acres are projected to lie on designated
    wilderness land.

                                                                                                                    RESOURCES ON SPECIAL LANDS                       155                                                                                            156       STEGE & VEYEA
                                                                          Should all the land under study as potential wilderness be designated                                                                                                                     um are cited on the large oil and gas resources estimated to [it on all
                                                                       formally as protected wilderness, the              .total energy resources lost to the                                                                                                       federal lands.
                                                                       nation would be trivial from a national perspective. The amount of oil and                                                                                                                       It can be seen from Table 4 that the amount of resources on federal
                                                                       gas on wilderness land per million acres would still be only 42% of the                                                                                                                      lands is large, totaling over one-third of all projected US oil and gas
                                                                       average amount located on other US land. The total amount of oil and                                                                                                                         resources. If the comparison is restricted to potential (undiscovered)
                                                                       gas "locked up" would amount to 3% ofprojected US resources, not even                                                                                                                        resources. the projected percentage on federal lands turns out to be even
                                                                       enough for a 10-month supply ofoil or a 16-month supply ofgas at current                                                                                                                     higher. But to infer that wilderness restrictions will prevent them resources
                                                                       consumption rates. Clearly, the nation would lose a small fraction of its                                                                                                                    from being tapped is unreasonable. As can be calculated from Table 4,
                                                                       energy if it were to complete the Wilderness preservation System and                                                                                                                         wilderness restrictions to energy exploration, leasing and development will
                                                                       permanently prohibit oil and gas leasing on potential wilderness.                                                                                                                            prevent extraction oftess than 10% of the oil and gas resources controlled
                                                                          From an economic perspoctive, oil companies would be foregoing about                                                                                                                      by the federal government. Arguments that the United States must@ for
                                                                       $500 per acre in oil and gas wealth to keep designated and potential                                                                                                                         energy security, trade away the quality of its lost wilderness lands have no
                                                                       wilderness wild for all time (assuming energy prices equivalent to $50 per                                                                                                                   basis.
                                                                       barrel of oil).'                                                                                                                                                                                 Thus, barring the highly -likely event that the total USGS estimates
                                                                          As has been shown in Tables 2 through 4, relatively little oil and gas                                                                                                                    pro- significantly in-te" the evidence presented clearly supports the
                                                                       is estimated to lie under wilderness lands. Because the strength of the                                                                                                                      position that the 9 quads of oil and 9 quads of natural gas estimated to
                                                                       conservationist argument hinges on the low oil and gas figures, the obvious                                                                                                                  he under land already legally designated as wilderness can remain under-
                                                                       counterargument is that the estimates could be low and that exploration                                                                                                                      ground forever without significant loss of US energy supply. The same
                                                                       should be allowed in order to check the USGS estimates. It is our con-                                                                                                                       reasoning holds true for the 13 quads of oil and 14 quads of natural gas
                                                                       tention that any exploration ofthese arm should be made by nonintrusive                                                                                                                      estimated to lie under wilderness land that has yet to be formally designated
                                                                       methods, without hcaVyeqUipMenL Requiten nts for resource assessment                                                                                                                         as wilderness. The tens to hundreds of years required for surface res-
                                                                       are considerably less demanding than those for actually locating specific                                                                                                                    toration oftieveloped land overwhelmingly dwarf the very brief time scale
                                                                       oil and gas reserves. Examples include satellite survey, aerial photography,                                                                                                                 over which the United States could be supplied by energy extracted from
                                                                       geological sampling, geochemical surveys, and certain forms of geo-                                                                                                                          wilderness lands.
                                                                       physical surveys (e.g. gravity meters). Nonintrusive methods are currently                                                                                                                       When this country was first settled by Europeans, almost all of the
                                                                       inadequate for confirming existing USGS estimates, but that situation will                                                                                                                   land area corresponding to the 48 states was wilderness and teemed with
                                                                       no doubt change in the future. Fifty years from now, technologies for                                                                                                                        Wildlife. The unrestrained pressure of civilization has steadily eroded wil-
                                                                       identifying natural resources will have surpassed the crude methods avail-                                                                                                                   derness areas to a small percentage of the lot". I% in the lower 48
                                                                       able to energy companies today.$ With such a small percentage of US                                                                                                                          states. Although development has consumed forever almost all ofthe lower
                                                                       land remaining as wilderness, it would seem wise for the nation to be                                                                                                                        49, our wilderness resources can still be preserved in Alaska (where nearly
                                                                       patient in confirming the USGS estimates.                                                                                                                                                    37% of the land area remains as wilderness). To those who value wilder
                                                                          If the USGS reports show such a small percentage of energy resources                                                                                                                      ness, it is critical that the nation's last remaining fragments are safeguarded
                                                                       estimated to be on wilderness lands, how has the wilderness "lockup"                                                                                                                         from development. Unless the nation maintains the sanctity of all wil-
                                                                       misconception gained credence? One reason is that wilderness, non-                                                                                                                           derness areas by completing the Wilderness system and giving potential
                                                                       wilderness, and offshore locations are not always distinguished when fig-                                                                                                                    wilderness the same protection now enjoyed by designated wilderness,
                                                                                                                                                                                                                                                                    much of that small percentage will disappear.
                                                                          'The discounted, net present value would be less then S500 M acre. In making this
                                                                       calculation, we define the economic value of the oil and gas to equal its market value minus
                                                                       the cost of production. We assume that it will cost, on average, 70% of the market price to                                                                                                      'It is true that the estimates For any one wilderness arets are uncertain. (M 95%
                                                                       locate am! extract oil seal gas in wild== regions. The market prim of natural gas is                                                                                                         wnfidmou upper limit for a given area may be a factor or two to three higher than the
                                                                       assunied to be 701A of the price of oil on a purely themmil basio.                                                                                                                           average estimate.) But it is highly unlikely that all the individual estimates would be uniformly
                                                                          'For instance, Nobel Prim-inning physicist Sheldon Glashow has proposed that                                                                                                              low. Thus, the percentage error in the total wilderness figures will be smaller than the
                                                                       neutrinos, which can pene"te deep into the earth. might be used to locate resources (35).                                                                                                           tage ersnr in estimates for individual wiklemen art"-

                                                                                                 RESWRCES ON SPECIAL LANDS               157                                                                           158      STEGE & BEYEA
                                                            OIL AND GAS RESOURCES ON SPECIAL                                                                                                                           offshore areas that are permanently off limits to energy development by
                                                            NONWILDERNESS LANDS                                                                                                                                        statute are 1.9 million acres within two National Marine Sanctuaries off
                                                                                                                                                                                                                       the coast of California (36). We anticipate that, subject to lease stipulations
                                                            Then are 8.2 million acres of special nonwilderness lands, administered                                                                                    to protect biological and other nonencrgy resources. the vast majority
                                                            by the National Wildlife Refuge Systern, the Forest Service. and the Park                                                                                  of offshore areas will eventually be explored and developed for energy
                                                            Service, that am dosed to oil and gas activities by statute. On another 13.2                                                                               purposes-
                                                            million acres, including 8.7 million acres of BLM land, leasing is allowed                                                                                    At present, there is no offshore  .biological resources inventory and criti-
                                                            whenever the Secretary of the Interior or Agriculture determines that the                                                                                  cal areas review process analogous to the wilderness review process for
                                                            W and gas activities are compatible with the purposes of the area [we                                                                                      determining areas that should be placed permanently off limits to oil and
                                                            Appendix A of (2)]. In practice, a large percentage of these 13.2 million                                                                                  gas development. The National Marine Sanctuaries Act (37) does not
                                                            acres could be ruled out for energy activity indefinitely. by administrative                                                                               prohibit leasing in marine sanctuaries or require periodic review oroffshore
                                                            policy or future legislation or court decisions.                                                                                                           areas for inclusion in the sanctuary system. (See Appendix A of (2).1 Until
                                                              Consequently. it is of interest to estimate the amount orenergy resources                                                                                such a review process is established, it would be prudent to proceed
                                                            involved in all 21.4 million acres of these special nonwilderness lands.                                                                                   with offshore leasing slowly enough for site-specific environmental impact
                                                            Although separate estimates of oil and gas for this acreage am not avail-                                                                                  assessments.to dcterminc what valuable noncncrgy resources might be
                                                            able, it is reasonable to expect diet land excluded by Congress, or restricted                                                                             jeopardized by oil and gas development, and where Leasing should be
                                                            by die Department of the Intcri" or the Department of Agriculture will                                                                                     delayed or prohibited. Delaying offshore leasing would not be costly to
                                                            contain Ins oil and gas per million acres than does average US land. If                                                                                    the government in the long run. In fact, since off-shom lea        are expected
                                                            this is the casr, then less than 5 quads of oil (two manths' supply) and less                                                                              to become much more valuable over the next few decades, such delays
                                                            than 6 quads of natural gas (approximately four months' supply) will be                                                                                    should result in significantly more money for the government when these
                                                            at stake.                                                                                                                                                  areas are eventually leased.
                                                                                                                                                                                                                          There are compelling environmental reasons for delaying offshore dcvcl-
                                                            OIL AND GAS RESOURCES IN OTHER                                                                                                                             opment in areas with extreme climatcs, such as "pack-ice" regions of
                                                            FEDERAL LAND (ONSHORE)                                                                                                                                     Alaska. Hem, drifting ice creates such a hostile setting for workers and
                                                            Most of the federally controlled onshore oil and gas resources am cstinutted                                                                               equipment that current oil extraction. transportation. and spill control
                                                                                                                                                                                                                       technologies are unable to ensure reasonable protection of the environment
                                                            to he within the category "other onshom fixicral land" in the tables. The                                                                                  from oil spills. The authors of one major study state, " We doubt that there
                                                            bulk of this land is open to energy development. although some of die                                                                                      will ever be a completely satisfactory response to cleaning up an amtic
                                                            area may be subject to environmental requirements that increase the cost                                                                                   offshore oil spill other than preventing it from occurring" (39).
                                                            or exploring and drdling for oil and gas resources. This increase in cost                                                                                     'Me effects of both large oil spills and chronic low-level discharges from
                                                            due to environmental regulations may delay extraction until such times as                                                                                  normal drilling and production operations on the sensitive and econ-
                                                            the overall economics become more profitable. Eventually. lowered costs                                                                                    ornically valuable biota inhabiting arctic and subarctic regions are largely
                                                            due to improvements in exploration technologies and production                                                                                             unknown. 'Me same is true of other so-called frontier areas. One option
                                                            processes, coupled with increases in energy prices. will offset the cost of                                                                                is to proceed only after sufficient research has been performed to allow
                                                            environmental regulations and allow development to continue. We expect                                                                                     an informed assessment of the risks and benefits or oil exploration and
                                                            that virtually all 101 quads of oil and 85 quads of gas remaining in this                                                                                  development. For die moment. exploration in frontier areas could be
                                                            nonspecial land category will eventually be available to energy companies.                                                                                 restricted to placcs dose to deposits that have already been located, and
                                                                                                                                                                                                                       where demonstrated oil spill containment and cleanup capability exists.
                                                            OIL AND GAS RESOURCES IN OFFSHORE AREAS                                                                                                                       Despite the argument for gradual, site-specific leasing of offshore areas
                                                            Mom total oil and gas resources are estimated to fie in offshore holdings                                                                                  (with stipulations to ensum adequate environmental protection), the fed-
                                                                                                                                                                                                                       eral government has been attempting to lease virtually ft entire US Outer
                                                            than in all the other federal land categories combined. At present, the only                                                                               Continental Shclf-ahnost a billion acrcs-by 1992. In response to the

    	Reagan administration's policy of large-scale, area-wide leasing, Congress
    has passed temporary moratoria on iol and gas leasing off much of the
    California coast, around Georges Bank off the coast of Massachusetts,
    and along a buffer strip off Florida's Gulf coast.
    	Nevertheless, temporary moratoria will not be extended forever and
    should give way to permanent prohibition on oil and gas leasing in
    sites identified by a critical offshore areas review process. Even without a
    comprehensive review process, sufficient evidence already available indi-
    cates that certain offshore regions should never be leased because of their
    importance as fisheries or because of their proximity to vulnerable coastal
    ecosystems-coastal marshes, coral communities, and pristine beaches.
    For instance, Bristol Bay in Alaska and Georges Bank supply a significant
    portion of the world's fish protein and are prime candidates for being put
    off limits to oil and gas leasing by statute.
    	As a result of excluding 1. Bristol Bay and Georgwes bank, 2. certain
    regions off the california coast and 3. miscellaneous other sites that might
    be identified by an offshore areas review process we estimate that perhaps
    13 quada of oil and 10 quads of natural gas will be permanently unavailable
    for development ( or about 11% of offshore oil and 6% of offshore gas
    resources, or 1.6% of total US oil and gas resources). Thus, if permanent
    restrictions come out of an offshore reveiew process they are likely to be
    modest.

    CONCLUSION

    Based on the analysis presented in this paper, we expect that more than
    94% of US oil and gas resources will eventually be available to energy
    companies (see Table5). 10 This does not , however, mean that energy
    exploitation can be given free rein in areas that are open for development
    The case with whcih ecosysttems can be damaged by development necessi-
    tates careful vigilance over the environmental impacts of energy activities
    in all areas. Laudable progress has been made in the past decade by some
    of the larger oil companies that have accepted the need to seriously pursue
    mitigation methods. Nevertheless, oil and gas companies would be wise
    to expand their efforts to develop environmentally sound methods of
    exploration and extractio that are suitable for the great percentage of
    land, both public and private, on which such activities need not, or will
    not, be prohibited completely.
     "Although not shown directly in Table 5, percentage resource availabilites can be
    calculated for land categories other than total US resources using figures given in earlier
    tables. The results indicate that(a) 92% of all offshore resources. (b) 76% of ombore federal
    lands, and (c) 85% of all federal resources should eventually be available to energy companies.

    160    STEGE & BEYEA

    	There will always be proposals to use environmentally valuable land
    such as wilderness and wildlife refuges for energy and mineral devel-
    opment. The pressure of proposals for develoment in these areas cannot
    be relieved by granting one-time access. Each time the price of energy or
    minerals jumps, or whenever a new technology allowin recovery of
    formerly inaccessible resources is developed, engineers have an incen-
    tive to return to an area for a closer look. Plans for development in
    environmentally sensitive areas, shelved due to economic or technological
    constraints, may be revived decatdes later. Only statutory protection, such
    as that granted by inclusion in the wilderness system, can provide long-"
    term protection.
    	A nation, like ours, with a 200-year history should look at the wilderness
    and wildlife preservation issue in a time fram that spans hundreds of
    years. not mere cecades. Only with such a perspective can we pass on to
    succeeding generations these living laboratories of natural history that are
    still intact. Wilderness Society chariman Gaylord Nelson has said, "The
    ultimate test of man's conscience may be his willingness to sacrifice some-
    thing today for future generations whose words of thanks will not be
    heard"(39).
    	Table 5 Summary of long-term availability of US oil and gas resources (if
    permanent restrictions to development were placed on designated and potential
    wilderness, special non wilderness onshore lands, and critical offshore areas)
    							oil      	gas
    						      (quads)     (quads)
    areas that are or may be restricted
    wilderness						22    	23
    special nonwilderness				6		7
    critical offshore areas				13		10
    total							41 (6.6%)	40 (4.7%)
    all other areas					583(93.4%)	805 (95.3%)

    Total estimated US resources			624 (100%)	845 (100%)

    Source: Economic Associates, Inc, (30) modified and updated as described in Appen-
    dix B in (2)

    Special nonwilderness areas include 21.4 million areas, most of which (62%) have no
    statutory restrictions on oil and gas development (5) Energy resources for thsi acreage
    were (over) estimated using a ratio, derived from reference (30) for oil and gas resources
    per million acres of total us land.

    These figures are base on our estimate of offshore areas that need to be placed
    permanently off limits to development, using the most recent estimates available for
    undixcovered federal offshore oil and gas resources (29). 23 quads represents 7.8% of all
    estimated offshore oil and gas resources.

    				RESOURCES ON SPECIAL LANDS       161
    Literature cited

    1. The wilderness Act. 1964. See us code.
    title 16, section 1131(a)
    2. Stege, A., Beyes. J. 1985. oil and gas
    Resources on Federal Lands; Wilder-
    ness and Wildlife Refuges. New York:
    National Audubon Society. Sciences
    Division
    3. The Wilderness Act. 1964. See Ref 1,
    section 1133(d)(2)
    4. US Natl Park Service. 1983. Acreage in
    Each National Park and Affiliated Area
    os of September, 1983. Washington, DC:
    US Dept. Interior
    5. Scietists Inst. for public information
    (SIPI), 1982. Draft Report on Oil and
    Gas and Public Lands, Appendix B. New
    York
    6.US Natl. Fish and wildlife Service.
    1984 Acreages of wildlife REfuges and
    other protected Areas by State and Unit
    as of September 30. 1984. Table 10.
    Washington, DC; US Dept. Interior
    7. US House subcommittee on Public
    Lands and National Parks. 1984 Na-
    tional Wilderness Preservation system,
    a table provided by Andrew Wiessner.
    Washington, DC
    8.US Natl. Park Service. 1984 Status of
    the Wilderness program, a table pro-
    vided by Jeff CHidlaw, Washington, DC
    9. Deleted in proof
    10.Alaska National Interest Lands Con-
    servation Act(ANILCA. 1980. pub L.
    96-487, Section 1317
    11. Deleted in proof
    12. 43 Code of Federal Regulations. 1985.
    Section 3101.5-1
    13. Deleted in proof
    14. Skillbred, A. 1984. The Watt/Clark Re-
    cord; The environmental Policies of the
    Reagan Administration-Alaska. Wash-
    ington. DC: The WIlderness Society
    15. US Dept. Interior. 1981 Energy RE-
    sources on Federally Administered lands,
    pp. 12-13 Washington, DC
    16. The international Atlas. 1979. p. 1-8, 1-
    11 New YOrk: Rand MCnally
    17. 43 US code. 1986, Section 1782
    18. The Wilderness Act. 1964, See Ref. 1,
    section 1132(b)
    19. Us Natl. Fish and Wildlife service.
    1984. See Ref. 6, Tables 1,2,10
    20. 16 US code. 1985 Section 668
    21. 16 US Code. 1985 Section 66*dd(d)
    22. Kloepfer, D. 1984. The Watt/Clark Re-
    cord: The environmental Policies of the
    Reagan Administration-The National
    Wildlife Refuge System, pp. 15-20.
    Washington DC: The wilderness
    Society
    23. Scientists INst. for public information
    (SIPI) 1982. See Ref 5, Chapter 2.
    Section D
    24. Plaza, P 1983 Impacts of Energy
    Development on Wildlife, pp. 2-3 New
    York; National Audubon Society
    25. Scientists Inst for public information
    (SIPI) 1982 see REf 5 Chapter 2 Sec-
    tion C
    26. Plaza. P. 1983. SEE Ref 24. p. 11
    27. Plaza P 1983 see ref 24. pp. 79-80
    28. DOlton G. L., Carison, K. H., Char-
    pentler R.R. Coury, A. B. Crovelli, R.
    A.,et al . 1981. Estimates of undiscovered
    Recoverable conventional Resources of
    Oil and Gas in the United States pp. 22.
    25. US Dept Interior, Geological Survey
    Circular 860.
    29. Cooke. L. 1985 Estimates of Un-
    discovered , Economically REcoverable
    Oil and Gas Resources for the Outer
    Continental Shelf, US Dept. Interior,
    Minerals Management Service as of July
    1984, OCS Report MMS 85-0012
    30. Economic Associates, Inc 1983 Dis-
    tribution of potentially producible petro-
    leum and Natural Gas in the United
    States (Revised estimates) Washington,
    DC: perpared for the WIlderness So-
    ciety.
    31. Miller, B., ed. 1983. petroleum Potential
    of WIlderness Lands in the Western
    United States, USGS circular 902-1-p.
    Table 3 page P-12
    32. Scientist Inst. for public information
    (SIPI) 1982 sec ref. 5. Tables 3-7
    33. Economic Associates, inc. 1982. Poten-
    tially Producible Petroleum and Natural
    Gas in the Untied States and the Wes-
    tern overthruss Belt. Washington, DC;
    prepared for the WIlderness Society
    34.US Dept. Energy 1984 Monthly Energy
    REv. Energy inf. Admin. report number
    DOE/EIA-0035(84/10). pp. 22-29
    35. Waldrop. M. M. 1983. Neutrino ex-
    ploration of the earth, SCience 220: 1142
    36. Tinney, R. 1981 The oil drilling pro-
    hibitions at the channel Islands and pt.
    Reyes-Farallon Islands National Marine
    Sanctuaries: Some costs and Benefits.
    Washington, DC: Cent. Environmental
    Education.
    37. 16 US Code, 1985. Chapter 32, section
    1431-4
    38. Weeks, W.F., Weller, G. 1984, Offshore
    oil in the Alaskan arctic, Science 225:
    371-78
    39. Nelson, G. September, 4, 1984. Ah,
    wilderness sasve it. New York Times,
    editorial

              National Audubon Society

                                                                                                                          My name is Peter A.A. Berle, and I am the President of the National
                                                                                                                      Audubon Society. I am testifying on behalf of the Society, including its

                                                                                                                      SSO,000 members nationwide. 2,600 of whom are in Alaska.

                                                                                                                          After carefully examining the "Resource Assessment Report" for the coastal
                                         TESTIMONY ON BEHALF OF THE
                                          NATIONAL AUDUBON SOCIETY                                                    plain of the Arctic National Wildlife Refuge, we are convinced it is not in

                                                                                                                      the long-ters conservation, economic or national security Interests of the

                                         AT A PUBLIC HEARING ON 7HE                                                   United Statos to open the coastal plain to leasing at this time. we urge,
                                                                                                                      therefore, that no leasing or land exchanges be permitted by Congress, and
                                WAFT ARCTIC NATIONAL WILDLIFE REFUGE, AiASKA                                          that the U.S. Fish and Wildlife Service be directed to protect and manage the
                                      COASTAL PIAIN RESOURCE ASSESSMENT
                                                                                                                      entire Arctic National Wildlife Refuge consitent with the conservation

                                                                                                                      purposes, including.wilderness protection, for which it was originally
                                                     BY                                                               established by Congress.
                                              PETER A.A. BERLE
                                                  PRESIDENT

                                                                                                                          We wish.to commend the many dedicated resource professionals In the U.S.
                                              WASHINGIM, D.C.                                                         Fish and Wildlife Service, U.S. Geological Survey and Bureau of Land
                                               JANUARY 9, 1987
                                                                                                                      Management who gathered information for the assessment report. often at great
                                                                                                                      personal risk.and sacrifice. Because of their many contributions. the

                                                                                                                      outstanding wildlife and wilderness values of the coastal plain have been

                                                                                                                      reconfirmed and understood better than ever before.

                                                                                                                          As one of the oldest and largest conservation organizations in the United
                                                                                                                      States, the National Audubon Society has a long history of involvement in the

                                                                                                                      Arctic National Wildlife Refuge. We recognize it as a very special national

               treasure. Uedicated iriends in conservation, including Ciiaus and.04argaret                             by development interests. The questions must be asked: Where will the
               %brie, worked long and hard for its establishment in 1960 to preserve a                                 compromising stop? Aren't there any public wilderness lands along the arctic
               portion of the. eastern Rrr-ks Range of arctic A)arka for its nutstanling                               coast of Alaska that should be considered sacrosanct?
               wilderness values. Thus, unlike many other refuges in the system, the Arctic
               .Refuge was established not out of a singular need to conserve wildlife, but to                             it is also important to note that this 18 million-acre refuge is the
               preserve for all time the spectacular wilderness ecosystem of northeastern                              second largest unit in the National Wildlife Refuge System, and the largest
               Alaska as.a whole. Audubon strongly supported-this far-sighted action, and so                           and most spectacular arctic wilderness sanctuary for wildlife in the world.
               too enlargement of the refuge In the Alaska National Interest Lands Act of                              wildlife species of particular national and International concern Include the
               1980 (ANILCA). Over the years we have worked with other conservationists to                             180-thousand-member Porcupine caribou herd (whose calving ground is on the
               protect the refuge from a series of threats from development interests; for                             refuge coastal plain), polar bears, grizzly bears. nuskox, Dail sheep, wolves,
               example, we opposed construction of an oil pipeline across the coastal plain                            wolverines, snow geese, peregrine falcons and other migratory birds. and
               in 1968-73, and opposed construction of a gas pipeline in the same place in                             arctic char and grayling.
               the years 1914-77.
                                                                                                                           When considered in conjunction with the North Yukon National Park that
                   in this debate over the future of the Arctic Refuge and its coastal plain.                          adjoins it on the east, the Arctic Refuge constitutes an International
               it is vitally important to realize that major compromises have already been                             commitment to the protection of wild nature. Major Industrial developments on
               made on Alaska's North Slope between development and conservation interests.                            either of these units Is clearly incompatible with their purposes.

               7bese compromises have resulted in current land jurisdictions that essentially
               make almost 90 percent of the slope potentially available for oil and gas                                   We agree with the Department of the interior ( on page 4S of the draft
               leasing. 7his is not to mention the additional 24 million acres of nearshore                            assessment report) that:

               (state) and offshore (federal OCS) lands available in the adjacent Beaufort
               Sea. A were Z million acres of the entire North Slope has been committed to                                      117be Arctic Refuge is the only conservation system unit that
               conservation purposes in the Arctic Refuge. Now most of that is under siege                                 protects, in an undisturbed condition, a complete spectrum of the
                                                                                                                           various arctic ecosystems in North America."

                                                                                                                       and   on page 46) that:

                                                     -4-                                                                                                     _S_

                       "T'he 1002 area Is the most bloiogicanyproductive part of the                                      4. Failure to justify full leasing when Prospects for discovery of even
                  Arctic Refuge for wildlife and is the cent'er of wildlife activity on                               one maIjor economically recoverable oil field on the coastal plain is only 19
                  the refuge. Caribou migrating to and irom the 1002 are3 and the
                                                                                                                      percent ( pages 49 and 68), and with the market value of leases depressed
                  post-calving caribou agg@egatlon offer an unparalleled spectacle."
                                                                                                                      because of the world oversupply of oil.

                  Despite these outstanding natural.values,  and the fact that the chance for
                                                                                                                          S. Failure to conduct a-comprdheasive economic analysis to show how the
              discovery of an economically recoverable oil  field is only 19 percent, the
                                                                                                                      benefits to the Alaska and national economies can be optimized from leasing,
              Department of the Interior is recommending that the entire-coastal plain be
                                                                                                                      both in the short and long term.
              made available for leasing to the oil industry. The department has left us    no
              reasonable alternatjve but to oppose its recommendat ions because of the
                                                                                                                          6. Failure to provide evidence   that the Department will ensure that air
              following seriousshortcomings in its resourceassessment process for the
                                                                                                                      and waier quality w1l be protected from toxic chemicals and other pollutants
              coastal plaint
                                                                                                                      such as those creating problems in the Prudhoe Bay oilfield.
                  1. Faiiu're to point out that the compromise to establish the Arctic
         L    Refuge in 1960 to preserve its unique wildlife, wilderness and recreation                                   7. Failure to  .explain how adequate water and gravel supplies will b.e
                                                                                                                      obtained after finding that 11   specific locations and sources of water and
              values resulted in the remainder of Alaska's vast North Slope and adjacent
                                                                                                                      gravel for exploration and development activities have not been identified; it
              offshore waters being made available I forIoil explor.ation.                                            is understood that these resources, especially water, are not readily
                                                                                                                      available on'the 1002 area," (page 75).
                 .2. Failure to release for public review and comment geologic information
              critical to the 1002 assessment process., Ibis gives those who could profit                                 8. Failure to explain why it wouldn't be in the strategic interests of
              from exploiting refuge resources adavantage over those who actually own those                           the Unit.ed states to purchase more foreign oil at current low prices for
              resources -- the American people.
                                                                                                                      addition to our nation's "Strategic Petroleum Reserve" rather than lose income

                                                                                                                      to the federal treasury by further flooding a depressed lease market through
                  3. Failure to reveal its proposed land trades with various Alaska Native                            opening the Arctic Refuge.
              corporations and the State of Alaska, and to demonstrate how such trades will

              serve in the public interest.

                                                                                                                                                            -7-

                                                                                                                          14. Failure to hold public.hearings in all Alaskan communities that will.
                    9. Failure to evaluate cumulative impacts on the Arctic Refuge from oil
               and gas lease sales on more than a million acres of adjacent state lands                              be directly affected by the proposed action, and to make an adequate number of
               (Camden Bay, Demarcation Point and Prddhoe Bay uplands) and 21.2 million acres                        copies of the assessment report available in a timely manner.
               of OCS leases (Sale 97) In t;e Beaufort Sea scheduled for July 1987. 7he                                  Unfortunately. a series of citizens' lawsuits pro Ived necessary during the
               latter sale, just off the refuge coast, is the largest oil and gas.lease sale
                                                                                                                     assessment process to assure that the law was followed, and citizen monitoring
               ever held in the Artic Ocean.

                                                                                                                     of government activities was required as well to learn of industry activities
                                                                                                                     taking place on the Arctic Refuge.   IAnd, despite the magnitude of resources at
                  10. Failure to thoroughly discuss alternative energy policies-thatif
               Implemented could make the nation energy secure without exploiting the Arctic                         stake and the ser.lousness of the consequences of the decision on people both
               Refuge.                                                                                               in Alaska and throughout -the nation, the Department of the Interior chose not
                                                                                                                     to maki this -report available for public review and comment. A citizen
                  11   Failure to assure that scarce refuge staff and funds will not be                              lawsuit was necessary to make the report available. 1hen, after being'forced
                                                                                                                     to release the report for public review, the Department abbreviated the
       9M      diverted fro; refuge conservation programs to monitor and regulate industrial
               activities an the coastal plain. (Since the coastal Plain resource assessvent@                        comment period to 60 days over the Christmas holiday period. 7his is not the
               was initiated in 1982,,nore than 90 percent of the refuge budget has been                             way a democracy like ours should work.
               devoted to the 1002 assessment process, resulting In the almost total neglect
               ofIthe overall refuge conservation program.)                                                              in fact, it is clear to us that the Department of interior has already
                                                                                                                     shown such a bias on this sensitive matter that it is hard to believe that
                 12. Failure to recognize.that a Morth Yukon National Park adjoins the                               these hearings are anything more than pro forma proceedings. One example   of
               Arctic Refuge and that-the United States has responsibilities to cooperate                            this-strong and obvious prejudgement of the Issue is an article written by,
                                                                                                                     Assistant Secretary Wrn for the December issue of Alaska GDastuction and Oil
               with Canada In protecting shared wildlife resources.                                                  magazine. This article, obviously prepared well before the public release of
                 13. Failure to address the need for cooperat IIve management of-the                                 the report In late November, explains to the oil industry and others how to
                                                                                                                     influence the Congress to vote to open up the Refuge.
               Porcupine caribou herd with Canada through the international management
               agreement that has been negotiated over the past several years.

                                                                                                                                                               -9-

                   Further evidence of bias is not    necessary   but unfortunately it exists                          lands in the United States. It shows    that proper planning and policy
                  in the form of an extraordinary and unprecedented "press release" of the                             development at the federal level will   enable the United States to produce more
               "Ala:ika Support Industry Ullancu." This document appeared on the same table                            goods.and services while actually improving the environment. 1he
               as the Department of Interio@ press release on the report, Just outside the                             environme ntal pay-off will be cleaner  air, purer water, and less pressure to
               briefing room inside the Interior Building, where Mr. Norn was allegedly                                exploit wilderness lands and wildlife   habitat such as that in the Artic Refuge.
               presenting.the report to  the public forthe first-time. Such a rel    ease
               prepared by a presumably  non-governmental body, wholeheartedly.indorsing    an                             True, the Audubon Plan requires the introduction of regulatory me   .asures
               allegedly secret report  that no one had yet seen, is clear evidence to us that                         that correct imperfections in the  marketplace, such as efficiency standards
               the oil industry and I ts supporters had been carefully consulted and                                   for home appliances and fuel economy standards for automobiles. Such'reliance
               coordinated with.long before the report was shown to the rest   of the   American                       In our Plan on modest measures to  promote cost-effective  conservation stands
               people.                                                                                                 in, contrast to the approach taken by the Administration,  which holds that
                                                                                                                       conservation should be left solely to the marketplace, no matter how far
                   In addition to Audubon's lonst history of  involvement in wildlife                                  economists tell us individual markets- are operating from  the cost minimum, no
               conservation, another major priority goal of   the Society is to "promote                               matter how much energy is being wasted as. a result. When   this blindspot
               national strategies for energy development and use, stressing conservation and                          toward energy conservation is combined with the Administration's skepticism
               renewable energy resources." In an effort to achieve this goal, we have                                 towards environmental protection, it is perhaps not surprising that the
               developed an energy plan with input from energy experts in industry,                                    -Administration makes drilling in wilderness areas one of  the pillars of its
               government and the academic community. Ihis was done in the realization that                            energy policy. Fortunately, the recent bipartisan show of support in Congress
               energy is a major factor in determint  .ng the quality of human life. it                                for appliance efficiency standards indicates that,the Adminstration is out of
               furthers the production of goods and services, but its production and use can                           touch with the country when it comes to tolerance of modest conservation
               seriously impact the quality of  the environment.                                                       regulations. We are confident that a Presidential veto of the appliance bill
                                                                                                                       in the upcoming session will be overridden by Congress.* We are also confident
                   The Audubon  Fhergy Plan is a prac tical, step-by-step alternative to the                           that, when the choice is clearly Out, Congress will decide to enact additional
               Administration's energy policy of exploiting the last remaining. wilderness                             conservation legislation in order to preserve our national treasures such as
                                                                                                                       the Arctic Refuge (as well as to save consumers money).

                 In the meantime. and, as long as this Administration refuses to take                                  Congress. if so, the tactic is. likely to backfire by completely alienating
             reasonable administrative and leeislative action to promote cost-effective                                those organizations willing to not prejudge the matter in advance. Certainly,
             energy conservation, we will have no choice but to oppose attempts tev npell  tite                        this has been the effect on the National Audubon Society.
             Arctic Refuge to oil and gas development. Audubon has worked hard.
             particularly at the statq level, to get appliance efficiency standards                                        The major undiscovered deposits of oil and gas on federal land holdings
             enacted. in New York, we initiated the process that led Governor Cuomo to                                 are thought to lie off the coast of the lower 48 states and Alaska. Thus, in
                                                                                                                       the next two decades, as known onshore reserves are depleted. offshore
             introduce a tough efficiency standards bill last year. Wssachusetts Audubon
             played a similar role in getting a bill introduced (and passed) in                                        development will become more important. Relatively little offshore land is
             Massachusetts. Audubon ambers are well aware that preservation of wildlife                                permanently off-limits to energy development.
             and protection of the human environment requires wise husbanding of our energy
             resources.                                                                                                    7be fact that all federal lands have not yet been leased does not mean
                                                                                                                       that development is proceeding too slowly. 7hese leases will be much more
                                                                                                                                                                If the goverment were to lease all
                 Audubon has been actively involved in efforts to develop a long-range                                 valuable ten to twenty years from now.
             comprehensive management plan for the Arctic Refuge. However, we have not                                 these lands at once. flooding the market, it would get an unfairly low
             been party to any actions that would preempt a thorough review of the mandated                            economic return for the taxpayers.

             assessment report. waiting to judge it on its merits. waiting to see if there
             might be any places where exploratory drilling could be allowed without                                       Judged in this context, the Reagan Administration is making a serious
             risking serious interference with wildlife and the wilderness quality of t he                             mistake in rushing to lease virtually the entire U.S. Outer Continental Shelf
             land. HDwever, instead of a complete and objective report with viable                                     (OCS) -- almost a billion acres -- and onshore prospects as well. 'The
             management options, we found the 1002 report biased. contradictory, and                                   practice of offering tons of millions of acres of public lands each year at a
             lacking essential information. The only possible excuse for this report is                                time when oil prices are depressed raises very serious questions about whether
             that Interior must not really be serious, but is floating a totally                                       the entire federal leasing program Is amounting to a giveaway to the oil
             unreasonable position in the hopes of maximizing its bargaining power in                                  industry.

                                                                                                                           By flooding the market with lease offerings, it is clear that the
                                                                                                                       administration is helping to drive the price of leases down, thereby providing

                                                       _12-
                the oil industry with an opportunity to lease large acreages at bargaia-                                    meaningful environmental impact analyses. Additionally, they make it
                basement prices. Evidence of this downward pr   essure on lease prices is                                   .extremely difficult for states like Alaska to conduct rati  onal development
                overwhelming:                                                                                               planning.

                        The average bid or acre under the Reagan Administration's 5-year                                        in Alaska, less than 6-percent of oil resources are estimated to lie
                program has been less than half that under the Carter program ($1,092 per acre
                versus $2,381 per acre), (Washington Post, November 8, 1983.) Before-Interior                               beneath designated or potential wilderness lands, Including those In the
                went to areawwide leasing in 1982, the average,price per acre for OCS lease                                 Arctic National Wildlife  IRe fuge. Clearly, 0ongress and the federal government
                bids in Alaska was $2,794. After area-wide leasing was initiated, OCS lease                                 have already made sure that lands with the vast majority of highest potential
                sales In Alaska netted an average of only $1,229 per acre, (OCS Report,
                                                                                                                            foroil and gas have been excluded from consideration as potential wilderness.
                86-0067, September 1986.)

                       The General Accounting Office found that the number    of bids per  tract                                Relatively little oil and gas is estimated to    lie under wilderness lands.
                .declined from of 2.44 bids to 1.65 bids under the area-wide  program.                                      When this country was fir .st settled by Ekiropeans, 100 percent of the land area
                       GAO estimated that -the federal government received    about 4-1 billion                             corresponding to the 48 states was wilderness and teeming with wildlife. The
                (or a discounted value of $5.4 billion in 1984 dollars) less than it would                                  unrestrained pressure of civilization has steadily eroded wilderness areas to
                have received if the same acreage were under the tract selection program."
                (GAO Report, RCED-8S-66, 198S, p.i.v.)                                                                      a small percentage of the total m- 4 percent In the lower 48 states. To those
                                                                                                                            who assign value to wilderness, it is incomprehensible that anyone would
                       Even the industry recognizes the lease price    depression caused by                                 object to protecting the nation's last remaining fragments. Unless the nation
                area-w.ide leasing -- the Oil and Gas Journal reports  that "offshore producers                             maintains the sanctity of designated and potential wilderness areas, even that
                agree that acreage costs on area-wide lease sales are lower than under the
                previous nominated tract concept because more acreage   Is offered at one                                   small percentage will disappear.
                time." (Washington Post, November 8, 1993.)

                                                                                                                                There will always be Proposals to use wilderness and criticalhabitats for
                   Aside from the economic arguments against leasing so much so fast when oil                               other purposes, particularly energy and mineral development. But little
                prices are depressed, there is a compelling conservation argument. Wge lease                                wilderness will be left If the engineers are aliowedto scour the land for the
                offerings involving tens of millions of acres make It impossible to do                                      next.thirty years and beyond      building new roads and drill sites, returning

                                                                                                                                                                  -is-

              for a closer took each time the price of energy or minerals jumps, and                                       Institute, there is obviously a clash in values between advocates of
              returning whenever a new technology allowing recovery of formerly inaccessible                               exploitation and those who favor preservation -- a dispute that must
              resousces. is developed.                                                                                     continuously be settled through the political process. The Audubon Energy

                                                                                                                           Plan has been developed with this dispute in mind. 7he Plan demonstrates that
                   The National Audubon Society believes that a nation like ours with a                                    there are practical alternatives to exploiting the last of our wilderness

              200-year history should look at the wilderness preservation issue in a time                                  areas. 7he United States can leave wilderness alone and still solve its need

              frame that' spans hundreds of years rather than decades. only with such                                      for a safe and assured supply of oil. The total amount of oil and gas that.

              perspective can the nation pass on to succeeding generations the wilderness                                  may be found in wilderness is simply too small to justify the abandom"t of

              resources that are still intact. Indeed, on numerous occasions in our                                        the nation's remaining wilderness heritage.
              national life, our leaders have consciously decided to forgo the sacrifice of
              wilderness and wildlife resources for the sake of others. 7be creation of                                        Under the Audubon Energy Plan, the mean risk.ed estimate of 1.6 billion
              0, ympic Nati onal Park with its large amount of commercial forest, o   r the                                barrels of oil and the 1.6 billion barrel equivalent of natural gas estimated
              recent refusal to permit oil and gas exploration in the Bob Marshall                                         to lie under land already legally designated as wilderness would remain
              Wilderness come immediately to mind.                                                                         underground forever. The same would be true for the Z.3 billion barrels of
                                                                                                                           oil and the Z.S billion barrel equivalent of natural gas estimated to lie
                  7be fact is that wilderness such as that on the Arctic Refuge coastal                                    under wilderness land that has yet to be formally designated as wilderness,
              plain serves a variety of valuable, noncommercial uses: wildlife habitat,                                    (A. Stege'and J. Berea, "Oil and Gas Resources on Special Federal Lands:
              watershed protection, scientific study, fishing, hunting, camping, hiking,      and                          Wilderness and Wildlife Refuge," Annual Review of Energy, Vol. 11, 1986, pp.
              most other forms of dispersed, low density outdoor recreation. Such                                          143-161.) Because wilderness land would never be exploited under the Audubon
              wilderness lands offer also the spiritual lift of peaceful, truly natural                                    Plan, there would be no need for exploration.

              settings.
                                                                                                                               7be estimates for oil in wilderness lands given above assume a mean risked
                  Although not every oil industry organization takes the limited view on                                   estimate of 600 million recoverable barrels of oil for the Arctic Refuge. In
              wilderness protection espoused by such organizations as the American Petroleum                               contrast, the Draft Coastal Plain Resource Assessment mentions a figure of 3.2

                                                                                                                                                                      -17-

               billion barrels, witnout clearly speciiying Witt!Lher Ur 1101. Lite estiladLe is                               oil and gas resources on federal lands will eventually be tapped. The Society
               "risked." (We suspect it is not.) Clarification on this point is needed from                                   stands ready to work with oil and gas companies to help then develop
               interior.   If the 3.1 billinn figue% is risked, that is, already incorporates                                 environmentally sound methods of exploration and extraction that are suitable
               the risk of finding no oil tilt), Interior would be claiming that there are                                    for the great percentage of land, both public and private, on which such
               2.S billion more barrels of oil likely to be found in wilderness lands than in                                 activities need not be prohibited completely. Audubon will continue to
               the estimates we have been using. Nevertheless, even an additional 2.S                                         insist, however, that exploitation of resources on public lands be carried out
               billion barrels would not change the fact that a very small percentage of U.S.                                 carefully in a manner that protects the environment and wildlife. Audubon

               oil is in potential and designated wilderness lands. The percentage of U.S.                                    will continue to oppose oil and gas exploration in any situation where
               oil resources on these lands would rise from 33 percent to 5.8 percent.                                        government agencies or energy companies move hastily, without fully assessing
                                                                                                                              the environmental and economic effects of activities or providing adequate
                   The only type of exploration that we could ever consider, especially given                                 safeguards for their implementation. This appears to be one of those cases.
               the fragile nature of the arctic wilderness, would be that conducted by
               nonintrusivelmethods, such as satellite survey. Nonintrusive methods are                                            it is argued by industry that the coastal plain of the Arctic Refuge must
               currently inadequate for confirming existing Interior estimates, but the                                       be leased now becasue it will take at least 15 years to develop any oil fields
               situation will no doubt change in the future. Fifty years from now,                                            discovered there. We strongly doubt that. it must be remembered that
               technologies for identifying natural resources will have surpassed the crude                                   following discovery of oil at Prudhoe Bay in 1968, oil was flowing through the
               methods available to energy companies today. With such a small percentage of                                   800-mile-long Trans Alaska Pipeline (TAPS) by June of 1977, a period of only 9
               U.S. land remaining as wilderness, it would seem wise for the nation to be                                     years. All that would be needed, should oil production be permitted on the
               patient in confirming Interior's etimates. Surely, 14. Chairman. the                                           Arctic Refuge, would be a 100 to ISO-mile-long pipeline spur (at maximum) to
               wilderness of the High Arctic -- our Serengeti -- is one place where we can                                    tie into TAPS. Our guess is that industry could bring an oilfield on line in
               afford to wait.                                                                                                the refuge within five years, should it someday prove in the national interest

                                                                                                                              to do so.

                   As has been indicated, the National Audubon Society is not opposed to any
               resource extraction on federal lands. We expect that more than 95 percent of                                        it is an illusion to believe that leasing on the coastal plain of the
                                                                                                                              Arctic Refuge will solve the economic problems of the North. After all, its

                                                                                                                                                          _19-

             whole purpose is to deliver nortnern oii to names and industries in tne boutn                           sanctuary in the world, at a time of a world oversupply of oil and with
                 or perhaps the Orient.  Indeed, rather than solving the North's economic                            hundreds of millions of acres of other federal and state lands available for
             problems, it way accentuate them. For evidence of thin, we need lank no                                 exploration.
             further than the situation i@ Alaska today. With the Trans Alaska Pipeline
             carrying oil at near full capacity, the state is going through one of the most                              it has been said by many that we are now at our Last Frontier in Alaska.
             serious economic recessions in its history. The result in many cases is lost                            This has different meaning to different people. To some it offers opportunity
             dreams and destroyed careers.                                                                           for resource development'and the jobs and material benefits delivered. To
                                                                                                                     others, it is wildlife and wilderness spectacles, which constitute a heritage
                 The situation on the Arctic Refuge obviously calls for bold and courageous                          to be preserved for generations of Americans. The decisions we make on the
             pol@tical leadership at both the state and national levels. For politicians                             Arctic Refuge, therefore, are not simply about oil fields and caribou herds.
             to be holding out the promise that yet another great oil bonanza lies beneath                           They are decisions that touch our very deepest values as a nation, and as a

             the arctic tundra just waiting to be exploited only postpones the day when all                          people.-

             Americans mu'st begin to live within their means by implementing cost-effective
             conservation measures.                                                                                      The National Audubon society feels the Department of the interior is
                                                                                                                     making a serious mistake in recommending that the coastal plain of the Arctic
                 On page 6 of its assessmewnt report, interior states:                                               Refuge be sacrificed to Industrial development. The facts convince us that
                                                                                                                     America can achieve energy security without exploiting the last great arctic
                      "Oil and gas developwnt will result in widespread, long-term                                   coastal wilderness in the United States.
                 changes in wildlife habitats. wilderness environment, and Native
                 community activities. Changes could include displacement and
                 reduction in the Porcupine caribou heard."                                                              We believe that U.S. Senators Howard Matzenbaus and Paul Tsongas   were
                                                                                                                     right when in the 1979 debate on the Alaska Lands Act they stated:

                 we agree, and this only reinforces our belief that it is not in the best
             strategic, economic or conservation Interests of the United States to                                             "it appears as if the 'forbidden fruit' syndrow is operating
                                                                                                                          with regard to the Arctic National wildlife Range. Regardless of how
             rectmamend making such sacrifices an the finest arctic wildlife and wilderness                               bitter that fruit may be, there are some oil and gas companies Which

                                                       -20-

                   .will want to invade this last stretch  of north slope arctic land
                   unimpacted by man. What the Congress    does with regard to this
                   fragile area will be an indication. of  how wisely we are going to
                   conserve the nation's natural resources In the future. we can afford
                   to make this Range the 'last place to go' in the search for energy
                   and we.should. We urge the Senate to    study the arguments on both
                   sides of this issue,' for we believe strongly that   aside from high
                   emotions which have surrounded the debate on this    Issue, the facts
                   support protection for the Range at this time . . . " (Report of the
                   Committee on Fnergy and Natural Resources, United    States Senate, No.
                   96-413, November 14, 1979, page 421.)

                   The National Audubon Society, therefore, strongly opposes leasing of the

               coastal plain for oil and gas development at this time, and recommends that
         S?    the U.S. Fish and Wild life Service be directed to manage the entire Arctic
               Refuge consistentwith the conservation purposes, including protection of      its
        (D
               unique wilderness, for which it was established.

                   Your consideration of our comments and recommendations is greatly

               appreciated.

                                                                                                             NAS Final Comments on 1002 Report
                                                                                                             February 6, 1987
                                                                                                             Page 2

                                                                                                                   We wish to commend the many dedicated resource
                                  National Audubon Society                                                   professionals in the U.S. Fish and Wildlife Service, U.S.
                                                ALASKA REGIONAL OFFICE                                       Geological Survey and Bureau of Land Management who gathered
                                   308 G STREET. SUITE 219. A NCHORAGE. A K 99501 (907) 276- 7034            information for the assessment report, often at great personal
                                                         February 6. 1987                                    risk and sacrifice. Because of their many contributions, the
                                                                                                             outstanding resource values of the coastal plain have been
                                                                                                             reconfirmed and understood better than ever before.

                                                                                                                   As one of the oldest and largest conservation
            U.S. Fish and Wildlife Service                                                                   organizations in the United States, the National Audubon Society
            Attnt Division of Refuge Management                                                              has a long history of involvement in the Arctic National
            2343 Main Interior Building                                                                      wildlife Refuge. We recognize it as a very special national
            l8th and C Streets NN                                                                            treasure. Dedicated friends in conservation, including olaus
            Washington, D.C.      20240                                                                      and Margaret Murie, worked long and hard for its establishment
                                                                                                             in 1960 to preserve a portion of the eastern Brooks Range of
                                                                                                             arctic Alaska for its outstanding wilderness values. Thus,
            Dear Sirst                                                                                       unlike many other refuges in the system, the Arctic Refuge was
                                                                                                             established not out of a singular need to conserve wildlife, but
                   These are the final written comments of the National                                      to preserve for all time the spectacular wilderness ecosystem of.
            Audubon Society on the Department of the Interior's Draft Arctic                                 northeastern Alaska as a whole. Audubon strongly supported this
            National Wildlife Refuqe,_A111a.9ka.L_Cewa eta' Plain Resource                                   far-sighted action, and so too enlargement of the refuge in the
            Assessment released    for PUB,     revT   November 23, 1986.                                    Alaska National Interest Lands Act of 1980 (ANILCA). Over the
                                                                                                             years we have worked with other conservationists to protect the
                   After carefully examining the "Resource Assessment         Report"                        refuge from a series of threats from development interests.
            for the  coastal plain of the Arctic National Wildlife Refuge, we
            are convinced it is not in the long-term conservation, economic                                        Conservationists in Alaska and throughout the nation are
            or national security interests of the United States to open the                                  becoming increasingly concerned about the ulterior motives of
            coastal plain to leasing at this time. We urge, therefore, that                                  these development interests (including the Reagan
            no leasing or land exchanges be permitted by Congress, and that                                  Administration) who claim that the oil resources of the Arctic
            the U.S. Fish and Wildlife Service be directed to protect and                                    Refuge are critical to fulfilling growing national energy needs,
            manage the entire Arctic National Wildlife Refuge consistent                                     particularly since President Reagan recently vetoed the National
            with the conservation purposes for which it was originally                                       Appliance Energy Act of 1986. Passed overwhelmingly by both
            established by Congress.                                                                         houses of Congress, this act would have saved the nation
                                                                                                             millions of barrels of oil and billions of dollars on utility
                   The National Audubon Society believes that wilderness                                     bills by the year 2000, thus making exploitation of the Arctic
            designation is the best way to permanently protect the entire                                    Refuge totally unnecessary. in addition, the Reagan
            Arctic National Wildlife Refuge, including the coastal plain.                                    Administration has opposed establishment of fuel efficiency
            We therefore support Alternative 8, the wilderness alternative.                                  standards for automobiles and continuance of the 55 mile/hour
            The Society believes that Congress should proceed with                                           speed limit.
            wilderness designation unless assessment by the National Academy
            of Sciences confirms the importance of the Arctic National                                             in ibis debate over the future of the Arctic Refuge and
            Wildlife Refuge to the nation's immediate and long-term energy                                   its coastal plain, it is vitally important to realize that major
            needs, and demonstrates that petroleum extraction can be made                                    compromises have already been made on Alaska's Worth Slope
            compatible with protection of the refuge's fragile ecosystem,                                    between development and conservation interests. These
            Including its internationally significant wildlife values. In                                    compromises have resulted in current land jurisdictions that
            the interim, the National Audubon Society believes that the                                      essentially make almost 90 percent of the slope potentially
            entire Arctic Refuge should be managed as wilderness in close                                    available for oil-and gas leasing. This is not to mention the
            ccHRperation with adjoining North Yukon National Park.                                           additional 24 million acres of nearshore (state) and offshore
                                                                                                             (federal OCS) lands available in the adjacent Beaufort Sea. A
                                                                                                             mere 2 million acres of of the entire North Slope has been

                               AMLI(ICANS COMM11TED14) CONSFAVATION

             NAS Final Comments on 1002 Report                                                      NAS Final Comments on 1002 Report
             February 6, 1987                                                                       February 6, 1987
             Page 3                                                                                 Page 4

             committed to conservation purposes in the Arctic Refuge. Now                           case, a federal judge ruled that Interior officials made serious
             most of that is under siege by development interests. The                              errors in judgement, and that the land trade was not in the
             questions must be asked: Where will the compromising stop?                             public interest. Now they are designing another refuge land
             Aren't there any public wilderness lands along the Arctic coast                        trade scheme on an even larger scale. Apparently, little was
             of Alaska that should be considered sacrosanct?                                        learned by Interior from their St. Matthew'experience.

                    It is also important to note that this 18 million-acre                                The Department has left us 'no reasonable alternative but
             refuge is the second largest unit in the National Wildlife                             to oppose its recommendations because of the following serious
             Refuge System, and the largest and most spectacular arctic                             shortcomings in its resource assessment process for the coastal
             wilderness sanctuary for wildlife in the world. Wildlife                               plain of the Arctic National Wildlife Refuget
             species of particular national and international concern include
             the 180-thousand-member Porcupine caribou herd (whose calving                            1)  Failure to point out that the establishment of the Arctic
             ground is on the refuge coastal plain), polar bears, grizzly                                 Refuge in 1960 to preserve its unique wildlife, wilderness
             bears, muskox. Dail sheep, wolves, wolverines, snow geese,                                   and recreation values resulted in the remainder of
             peregrine falcons and other migratory birds, and Arctic char   and                           Alaska's vast North Slope and adjacent offshore waters
             grayling.                                                                                    being made available,for oil exploration;

                    when considered in conjunction with the North Yukon                               2)  Failure to release for public review and comment geologic
             National Park that adjoins it on the east, the Arctic Refuge                                 information critical to the 1002 assessment process. This
             constitutes an international commitment to the protection of                                 gives those who could profit from exploiting refuge
             nature.                                                                                      resources advantage over those who actually own those
                                                                                                          resources--the American people;
                    We agree with the Department of the interior (on page   45
             of the draft assessment report) that:                                                    3)  Failure to reveal its proposed land trades with various
                                                                                                          Alaska Native corporations and the State of Alaska, and to
                       The Arctic Refuge in the only conservation system    unit                          demonstrate how such trades will serve the public interest;
                    the protects, in an undisturbed condition, a complete
                    spectrum of the various arctic ecosystems in North                                4)  Failure to justify full leasing when prospects for
                    America.*                                                                             discovery of even one major economically recoverable oil
                                                                                                          field on the coastal plain is only 19 percent (pages 49
             and (on page 46) that:                                                                       and 68), and with the market value of leases depressed
                                                                                                          because of the world oversupply of oil;
                      *The 1002 area is the most biologically productive part
                    of the Arctic Refuge for wildlife and is the center of                            5)  Failure to conduct a comprehensive economic analysis to
                    wildlife activity on the refuge. Caribou migrating to and                             show how the benefits to the Alaska and national economies
                    from the 1002 area and the post-calving caribou                                       can'be optimized from leasing., both in the short and long
                    aggregation offer an unparalleled spectacle.'                                         term;
                    Despite these outstanding natural values, and the fact                            6)  Failure to provide evidence that the Department will
             that the chance for discovery of an economically recoverable   oil                           ensure that air and water quality will be protected from
             field is only 19 percent, the Department of.the Interior is                                  toxic chemicals and other pollutants.such as those
             recommending that the entire coastal plain be made available   for                           creating problems in the Prudhoe Bay oilfieldl
             leasing to the oil industry. Meanwhile, officials of the
             Department are conducting negotiations in secret to trade away                           7)  Failure to explain how adequate water and gravel supplies
             refuge lands on the coastal plain to private interests. This                                 will be obtained after finding that '-specific locations
             subverts the entire assessment report process preempts                                       and sources of water and-gravel for exploration and
             congressional options, and could lead to privatization of the                                development activities have not been identified; it is
             refuge. Many of the individuals involved in these land trades                                understood that these resources', especially water, are not
             are the same ones who attempted to trade,away wilderness lands                               readily available on the.1062 area," (page 75);
             on St. Matthew Island to oil interests in 1984. In that

            NAS Final Comments on 1002 Report                                                       NAS Final Comments on 1002 Report
            February 6, 1987                                                                        February 6, 1987
            Page 5                                                                                  Page 6

               8) Failure to explain why it wouldn't be in the national                             was followed. Furthermore, citizen monitoring of government
                  security interests of the United States to purchase more                          activities was required as well to learn of industry activities
                  foreign oil at current low prices for addition to our                             taking place on the Arctic Refuge. And, despite the magnitude
                 .nation's 'Strategic Petroleum Reserve" rather than lose                           of resources at stake and the seriousness of the consequences of
                  income to the federal treasury by further flooding a                              the decision on people both in Alaska and throughout the natione
                  depressed lease market through opening the Arctic Refuge;                     0.  the Department of the interior chose not to make this report
                                                                                                    available to the public. Then, after being placed under court
               9) Failure to evaluate cumulative impacts'.on the Arctic                             order to do so, the Department abbreviated the comment period to
                  Refuge from oil and gas lease sales on more than a million                        60 days over the Christmas holiday period. This is not the way
                  acres of adjacent state lands (Camden Bay, Demarcation                            a democracy like ours works best.
                  Point and Prudhoe Bay uplands) and 21.2 million acres of
                  OCS leases (Sale 97) in the Beaufort sea scheduled for                                  In addition to Audubon's long history of involvement in
                  July 1987. The latter sale, just off the refuge coast, is                         wildlife conservation, anothermajor priority goal of the
                  the largest oil and gas lease sale ever held in the Arctic                        Society is to 'promote national strategies for energy
                  Ocean;                                                                            development and use, stressing conservation and renewable energy
                                                                                                    resources." In an effort to achieve this goal, we have
             10)  Failure to thoroughly discuss alternative energy policies                         developed an "Audubon Energy Plan" with input from energy
                  that if implemented could make the-nation energy secure                           experts in industry, government and the academic community.
                  without exploiting the Arctic Refuge;                                             This was done in the realization that energy is a major factor
                                                                                                    in determining the quality of human life. it furthers the
             11)  Failure to assure that scarce refuge staff and funds will                         production of goods and services, but its production and use can
                  not be diverted from refuge conservation programs to                              seriously impact the quality of the environment.
      9           monitor and regulate industrial activities on the coastal
      M           plain.  (Since the coastal plain resource assessment was                                The Audubon Energy Plan is a practical, step-by-step
      CA          initiated in 1982, more than 90 percent of the refuge                             alternative to the Administration's energy policy of exploiting
                  budget has been devoted to the 1002 assessment process,                           the last remaining wilderness lands in the United States. It
                  resulting in the almost total neglect of the overall                              shows that proper planning and policy development at the federal
                  refuge conservation program);                                                     level will enable the United States to produce more goods and
                                                                                                    services while actually improving the environment. The
             12)  Failure to recognize that a North Yukon National Park                             environmental pay-off will be cleaner air, purer water, and less
                  adjoins the Arctic Refuge and that the United States has                          pressure to exploit wilderness lands and wildlife habitat such
                  responsibilities to cooperate with Canada in protecting                           as that in the Arctic Refuge.
                  shared wildlife resourceal
                                                                                                          True, Audubon's Energy Plan requires the introduction of
             13)  Failure to address the need for cooperative management of                         regulatory measures that correct imperfections in the
                  the Porcupine caribou herd with Canada through the                                marketplace, such as efficiency standards for home appliances
                  international management agreement that has been                                  and fuel economy standards for automobiles. such reliance in
                  negotiated over the past several years;                                           our Plan on modest measures to promote cost-effective
                                                                                                    conservation stands in contrast to the approach taken by the
             14)  Failure to consult with the appropriate   agencies of the                         Administration, which holds that conservation should be left
                  Government of Canada as directed in Section 1005   of                             solely to the marketplace, no matter how far economists tell us
                  ANILCA; and                                                                       Individual markets are operating from the cost minimum, no
                                                                                                    matter how much energy is being wasted as a result. when this
             15)  Failure to hold public hearings in all Alaskan communities                        blindspot toward energy conservation is combined with the
                  that will be directly affected by the proposed action, and                        Administration's skepticism towards environmental protection, it
                  to make an adequate number of copies of the assessment                            is perhaps not surprising that the Administration makes drilling
                  report available in a timely manner.                                              in wilderness areas one of the pillars of its energy policy.

                  Unfortunately, a series of citizens'   lawsuits proved                                  Fortunately, the recent'bipartisan show of support in
            necessary during the assessment process to   assure that the law                        Congress for appliance efficiency standards indicates that the

             NAS Final Comments on 1002 Report                                                        NAS Final Comments on 1002 Report
             February 6, 1987                                                                         February 6, 1987
             Page 7                                                                                   Page 8

             Administration is out of touch with the country when It comes to,                               The fact that all federal lands have not yet been leased
             tolerance of modest conservation regulations. We are confident                           does not mean that development to proceeding too slowly. These
             that a Presidential veto of the appliance bill in the upcoming                           leases will be much more valuable ten to twenty years from now.
             session will be overridden by Congress. We are also confident                            If the government were to lease all these lands at once, it
             that, when the choice is clearly put, Congress will decide to                            would derive an unfair economic return for-the taxpayers.
             enact additional conservation legislation in order to preserve
             our national treasures such as the Arctic Refuge (as well as to                                 Judged in this context, the Reagan Administration is
             save consumers money.)                                                                   making a serious mistake,in rushing to lease virtually the
                                                                                                      entire U.S. Outer Continental Shelf (OCS)--almost a billion
                    In the meantime,  and as long as this Administration                              acres--and onshore prospects as well. The practice of offering
             refuses to take reasonable administrative and legislative     action                     tens of millions of acres of public lands each year at a time
             to promote cost-effective energy conservation, we will have no                           when oil prices are depressed raises very serious questions
             choice but to oppose attempts to open the Arctic Refuge to oil                           about whether the entire federal leasing program Is amounting to
             and gas development. Audubon has worked hard, particularly at                            a giveaway to the oil industry.
             the state level, to got appliance efficiency standards enacted.
             In New York, we initiated the process that led Governor Cuomo to                                By flooding the market with lease offerings, it is clear
             Introduce a tough efficiency standards bill last year.                                   that the Administration is helping to drive the price of leases
             Massachusetts Audubon played a similar role in getting a bill                            down, thereby providing the oil industry with an opportunity to
             introduced iand passed) in Massachusetts. Audubon members are                            lease large acreages at bargain-basement prices. Evidence of
             well aware that preservation.of wildlife and protection of the                           this downward pressure on lease prices in overwhelming:
             human environment requires wise husbanding of our energy
             resources.                                                                                      The average bid per acre under the Reagan Administration's
                                                                                                             5-year program has been less than half that under the
                    Audubon continues to be actively involved in efforts to                                  Carter program ($1,092 per acre versus $2,381 per acre),
                                                                                                             1W      tin Post, November a. 1983.) Before interior went
                                                                                                             ,p:h
             develop a long-range "ComprehensiveConservation Plan@ for the                                       r!:!@
             Arctic Refuge. However, we have not been party to any actions                                             de leasing in 1982, the average price per acre
             that would preempt a thorough review of the mandated resource                                   for OCS lease bids in Alaska was $2,794.    After area-wide
             assessment report for the refuge's coastal plain, waiting to                                    leasing was initiated, OCS lease sales in   Alaska netted an
             judge the report on its merits, waiting to see if there were a                                  average of only $1,229/acre, (OCS Report,   MMS 86-0067,
             few key areas in which exploration could be allowed without                                     September 1986.)
             risking serious interference with wildlife and wilderness
             resources. Instead of a complete and objective report with                                  *   The General Accounting Office (GAO) found   that the number
             viable management options, we find the assessment report biased,                                of bids per tract declined from of 2.44 to l..65 under the
             contradictory, and lacking essential information. The only                                      area-wide program.
             possible excuse for this is that Interior must not really be
             serious, but is floating a totally unreasonable position in the                             *   GAO estimated that "the federal government received about
             hopes of maximizing its bargaining power in Congress. If so,                                    $7 billion (or a discounted value of $5.4 billion in 1984
             the tactic is likely to backfire by completely alienating those                                 dollars) less than it would have received if the same
             organizations willing to keep an open mind regarding multiple                                   acreage were under the tract selection program,* (GAO
             resource values on the coastal plain. Certainly, this has been                                  Report, RCED-85-66, 1985, p.i.v.)
             the effect on the National Audubon Society.                                                     Even the Industry recognizes the lease price depression
                    The major undiscovered deposits of oil and gas on federal                                caused by area-wide leasing--the Oil and Gas Journal
             land holdings are thought to lie off the coast of the lower 48                                  reports that *offshore producers agree that acreage costs
             states And Alaska. Thus, in the next two decades, as known                                      on area-wide lease sales are lower than under the previous
             onshore reserves are depleted, offshore development will become                                 nominated tract concept because more acreage is offered at
             more important. Relatively little offshore land is currently                                    one time." (Washington Post, November 8, 1983.)
             off-limits to energy development. Most of these deposits will
             eventually be tapped.                                                                           Aside from the economic arguments against leasing so much
                                                                                                      so fast when oil prices are depressed, there is a compelling

            HAS Final Comments on 1002 Report                                                      NAS Final Comments on 1002 Report
            February 6, 1987                                                                       February 6, 1987
            Page 9                                                                                 Page 10

            conservation argument. Huge   lease offerings involving tens of.                             Although not every oil industry   organization takes the
            millions of acres make it impossible to do meaningful                                  limited view on wilderness protection   espoused by such
            environmental impact analyses. Additionally, they make it                              organizations as the American Petroleum Institute, there is
            extremely difficult for states like Alaska to conduct rational                         obviously a clash in values between advocates of exploitation
            development planning.                                                                  and those whose favor preservation--a-dispute that must
                                                                                                   continuously be settled through the political process. The
                  In Alaska, less  than 6 percent of oil resources are                             Audubon Energy Plan has been developed with this dispute in
            estimated to lie beneath designated or potential wilderness                            mind. The Plan demonstrates that there are practical
            lands, including those in the Arctic National Wildlife Refuge.                         alternatives to exploiting the last of our wilderness areas.
            Clearly, Congress and the federal government have made sure that                       The United States can leave wilderness alone and still solve its
            lands with the vast majority of highest potential for oil and                          oil import problem. The total amount of oil and gas under
            gas have been excluded from consideration as potential                                 wilderness lands is too small to justify the abandonment of the
            wilderness.                                                                            nation's remaining wilderness heritage.
                  Nationwide, relatively little oil and gas is estimated to                              Under the Audubon Energy Plan, the mean risked estimate of
            lie under wilderness lands. When this country was first settled                        1.6 billion barrels of oil and the 1.6 billion barrel equivalent
            by Europeans, 100 percent of the land area corresponding to the                        of natural gas estimated to lie under land already legally
            contiguous 48 states was wilderness and teeming with wildlife.                         designated as wilderness would remain underground forever. The
            The unrestrained pressure of civilization has steadily eroded                          same would be true for the 2.3 billion barrels of oil and the
            wilderness areas to a small percentage of the total--4 percent                         2.5 billion barrel equivalent of natural gas estimated to lie
            in the lower 48 states. To those who assign value to                                   under wilderness land that has yet to be formally designated as
            wilderness, it is incomprehensible that anyone would object to                         wilderness, (A. Stege and J. Beyea, *Oil and Gas Resources on
            protecting the nation's last remaining fragments. Unless the                           Special Federal Lands: Wilderness and Wildlife Refuges," Annual
            nation maintains the sanctity of designated and potential                              Review of Energy, Vol. 11, 1986, pp. 143-161.) Because
            wilderness areas, even that small percentage will disappear.                           wilderne    and would never be exploited under the Audubon Plan,
                                                                                                   there would be no need for exploration.
                  There will always be proposals to use wilderness and
            critical habitats for other purposes, particularly energy and                                The estimates for oil in wilderness lands given above
            mineral development. But little wilderness will be left if the                         assume a mean risked estimate of 600 million recoverable barrels
            engineers are allowed to scour the land for the next thirty                            of oil for the Arctic Refuge.   In contrast, the Draft Coastal
            years and beyond--building new roads and drill sites, returning                        Plain Resource Assessment mentions a figure of 3.2 billion
            for a closer look each time the price of energy or minerals                            barrels, without clearly specifying whether or not the estimate
            jumps, and returning whenever a new technology allowing recovery                       is "risked."   (We suspect it is not.) Clarification on this
            of formerly inaccessible resources is developed.                                       point is needed from Interior. If the 3.2 billion figure is
                                                                                                   risked, that is, already incorporates the risk of finding no oil
                  The National Audubon Society believes that  a nation like                        (81%), Interior would be claiming that there are 2.6 billion
            ours with a 200-year history should look at the wilderness                             more barrels of oil likely to be found in wilderness lands than
            preservation issue in a time frame that spans hundreds of years                        in the estimates we have been using. Nevertheless, even an
            rather than decades. Only with such perspective can the nation                         additional 2.6 billion barrels would not change the fact that a
            pass on to succeeding generations the wilderness resources that                        very small percentage of U.S. oil is in potential and designated
            are still intact.                                                                      wilderness lands. The percentage of U.S. oil resources on these
                                                                                                   lands would rise from 3.5% to 5.8%.
                  The fact is that wilderness such as that on the Arctic
            Refuge coastal plain serves a variety of valuable, noncommercial                             Certainly, any exploration that may eventually be
            uses: fish and wildlife habitat, watershed protection,                                 permitted on these areas should be made by nonintrusive methods,
            scientific study, fishing, hunting, camping, hiking, and most                          such as satellite survey. Nonintrusive methods are currently
            other forms of dispersed, low density outdoor recreation. Such                         inadequate for confirming existing interior estimates, but the
            wilderness lands offer also the spiritual lift of peaceful,                            situation will no doubt change in the future. Fifty years from
            truly natural settings.                                                                now, technologies for identifying natural resources will have.
                                                                                                   surpassed the crude methods available to energy companies

                                                                                                  HAS Final Comments on 1002 Report
                                                                                                  February 6. 1987
             HAS Final Comments on 1002 Report                                                    Page 12
             February 6, 1987
             Page 11

                                                                                                  all Americans must begin to live within their means by
             today. With such a small percentage of U.S. land remaining as                        implementing cost-effective conservation  measures.
             wilderness, it would seem wise for the nation to be patient in                              on page 6 of its assessment report, Interior statess
             confirming interior's estimates.
                                                                                                           *Oil and gas development will result in widespread,
                   As has been indicated, the National Audubon Society is not                            long-term changes in wildlife habitats, wilderness
             blindly opposed to resource extraction an public lands. We                                  environment, and Native community activities. Changes
             expect that more than 95 percent of oil and gas resources on                                could include displacement and reduction in the Porcupine
             federal lands will eventually be tapped. The Society stands                                 caribou herd.*
             ready to work with oil and gas companies to help them develop
             environmentally sound methods of exploration and extraction that                            We agree, and therefore do not believe the long-term
             are suitable for the great percentage of land, both public and                       conservation, economic, or national security interests of the
             private, on which such activities need not be prohibited                             United States will be served by recommending that such
             completely. Audubon will continue to insist, however, that                           sacrifices be made on the finest Arctic wildlife and wilderness
             exploitation of resources on public lands be carried out                             sanctuary in the world at a time of a world oversupply of oil,
             carefully in a manner that protects the environment and                              and with hundreds of millions of acres of other federal and
             wildlife. Audubon will continue to oppose oil and gas                                state lands available for exploration.
             exploration in any situation where government agencies or energy
             companies move hastily, without fully assessing the                                         it has been said by many that we are now at our Last
             environmental and economic effects of activities or providing                        Frontier in Alaska. This has different meaning to different
             adequate safeguards for their implementation. This  appears to                       people. To some it offers opportunity for resource development
             be one of Viose cases.                                                               and the jobs and material benefits delivered. To others, it is
                                                                                                  wildlife and wildland spectacles which constitute a heritage to
                   It is argued by industry that the coastal plain of the                         be preserved for generations of Americans. The decisions we
             Arctic Refuge must be leased now because it will take at least                       make on the Arctic Refuge therefore are not simply about oil
             fifteen years to develop any oil fields discovered there. it                         fields and caribou herds. They are decisions that strike to our
             must be remembered that following discovery of oil at Prudhoe                        very deepest concerns as a nation.
             Bay in 1968, oil was flowing through the 800-mile-long Trans
             Alaska Pipeline (TAPS) by June of 1977, a period of only 9                                  The National Audubon Society feels the Department of the
             years. All that would.be needed should oil production be                             interior is making a serious mistake in recommending that the
             permitted on the Arctic Refuge would be a 100 to 150-mile-long                       coastal plain of the Arctic Refuge be opened to full leasing.
             pipeline spur (at maximum) to tie into TAPS. Our guess is that                       The facts convince us that America can achieve energy security
             industry could bring an oilfield on line in.the refuge within 5                      without exploiting the last great arctic coastal wilderness in
             years should it someday prove in the national interest to do so.                     the United States.
                   it is an illusion to believe that leasing on the coastal                              we believe that U.S. Senators Howard Metzenbaum and Paul
             plain of the Arctic Refuge will solve the economic problems of                       Tsongas were right when in the 1979 debate on the Alaska Lands
             the North. After all, its whole purpose is to deliver northern                       Act they stateds
             oil to homes and industries in the South--or perhaps the
             Orient. indeed, rather than solving the North's economic                                         it appears as if the 'forbidden fruit" syndrome is
             problems, it may accentuate them. For evidence of this, we need                             operating with regard to the Arctic National Wildlife
             look no further than the situation in Alaska today. With the                                Range. Regardless of how bitter that fruit may be, there
             Trans Alaska Pipeline carrying oil at near full capacity, the                               are some oil and gas companies which will want to invade
             state is going through one of the most serious economic                                     this last stretch of north slope arctic land unimpacted by
             recessions in its history.                                                                  man. what the Congress does with regard to this fragile
                                                                                                         area will be an indication of how wisely we are going to
                   The situation on the Arctic Refuge obviously calls for                                conserve the nation's natural resources in the future. we
             bold and courageous political leadership at both the state and                              can afford to make this Range the -last place to go" in
             national levels. For politicians to be holding out the promise                              the search for energy and we should. We urge the Senate
             that yet another great oil bonanza lies beneath the Arctic
             tundra just waiting to be exploited only postpones the day when

           WAS Final Comments on 1002 Report
           February 6, 1987
           Page 13

                 to study the arguments on both sides of this issue, for we
                 believe strongly that aside from high emotions which have
                 surrounded the debate on this issue, the facts support
                 protection for the Range at this time... " (Report of the
                 Committee on Energy and Natural Resources, United States
                 Senate, No. 96-413, November 14, 1979, page 421.)

                 To reiterate our position on this issue, the National
           Audubon Society believes that wilderness designation.is the best
           way to permanently protect,the entire Arctic National wildlife
           Refuge, including the coastal plain. We therefore support
           Alternative E, the wilderness alternative. The Society believes
           that Congress should proceed with wilderness designation unless
           assessment by the National Academy of Sciences confirms the
           importance of the Arctic National Wildlife Refuge to the
           nation's immediate and long-term energy needs, and demonstrates
           that petroleum extraction can be made compatible with protection
           of the refuge's fragile ecosystem, including its internationally
           significant wildlife values. in the interim, the National
           Audubon Society believes that the entire Arctic Refuge should be
           managed as wilderness in close cooperation with adjoining North
           Yukon National Park,

       0)        Your consideration of our comments and recommendations is
           greatly appreciated.

                                                  Sincerely,

                                                  David R. Cline
                                                  Regional Vice President

    	February 3, 1987

    U.S. Fish and Wildlife service
    divison of refuge management
    2343 Mian interior Building
    18 and c street nw
    Washington, D.C. 20240

    RE: Draft 1002 Report for the Arctic Costal Plain

    Dear sirs/Madams:

    Here are teh comments of the Nationan Park and Conservation
    Association on the Draft 1002 Report for the Coastal Plain of the
    Arctic National Wildlife Refuge.

    The National Park and conservation Association, founded in 1919
    is the only non-profit, private organization devoted to
    protecting and improving all of our Nation's National Parks. At
    present the Association is primarly concerned with management of
    National Parks it has concerns for the health and welfare of the
    environment nation-wide.

    It has been long recognized (first by Robert Marshall and then by
    Olaus Murie) that there is a need for preserve a portion of the
    Brooks Range and Arctic Alaska for its gret wilderness values.
    This was the original purpose to establish the Arctic Range. It
    was a concern for the unique wilderness ecosystem that formed the
    purpose of the the Arctic National Wildlife Refuge when congress
    established the area. The refuge is a national wilderness
    treasure entrusted to the U.S. Fish and Wildlife Service by the
    people to protect those unique wilderness values also, many of
    the components of thsi ecosystem extend into Canda, and
    ultimately decission that we make for the Arctic Refuge will
    effect Canada.

    With this as a background, use commend the Service for its
    statement on page 45 of the Draft report that states: The Arctic
    Refuge is the only conservatin system unit that protects, in an
    undesturbed condition, a complete spectrum of the various arctic
    ecosystems in NOrth America, We also agree with page 40 that:
    "the 1002 area is the most biologically productive part of the
    Arctic Refuge for wildlife and is the center of wildlife ______
    on the refuge."Given these statements, we find no justification
    for the Department's preferred alternative to make the entire
    coastal plain available for leasing to industry.

    2. The report has several shortcommings in its resource assessment
    of the coastal plain.

    1) There were no hydrologists. ecologists, soils scientists, or
    recreation planners on the planning team.

    2) The report cites outdated data to make various points. For
    example, the statement that the North Slope air is generally of
    good quality (burro, 1973).

    3) The report states that water resources in the 1002 area are
    very limited, but does not describe practical, economic ways that
    industry must deal with this problem and still protect resource
    values.

    4) Large and ovious animals were selected for Evaluation
    species" which may not reflect resource development impacts of
    consequence to all of the relevant ecosystems. For example the
    arctic fox, small mammals, Lapland longspurs, and pectoral
    sandpipers could be used as indicators of environemntal quality.

    5) The cultural importance of bowhead whales to the people of
    kakotwik has been inadequately addressed. The 1979-1985 bowhead
    whale studies (Liung-blad et al. 1986, Richardson 1980 and Miles
    et al 1986) are important to consideration of the pokok port
    site and annual sealift activities.

    6) Baseline data reports show a tendency to duplicate efforts or
    to establish habitat classification systems independently of
    other investigators. A concerted effort should be made to
    standarize a habitat classification applicable to most studies
    to expodite comparisons between habitats, areas, and populations
    over time and regions.

    7) Very little use was made of teh substantial data on
    terrestrial bird populations of the Refuge that have been
    collected over 4 years. As of 1985 127 10-hectara plots in 7
    habitat types in 10 study areas of the 1002 area have been
    established and surveyed in various years. A more consistant
    study design should be conducted that addresses the need to
    obtain information on biotic resources of the Refuge prior to
    further exploration, development, and production of oil and gas
    resources. Results to date do not support the statements of
    importance of rock and willow plarmian compared to other
    terrestrial species.

    8. No mention is made of the doucments: gravel removal studies in
    Arctic and Subarctic FLoodplains in AK (FWS 085-80/08: and Gravel
    Removal Guideliens Manel for Arctic and Subarctic Floodplains
    (FMS/OBS-80/09).

    National Parks and Conservation Association
    1015 Thirty-First Street, N.W., Washington, D.C.2007
    	Telephone (202) 944-8530

          3.                                                                                         4.

          9) While culvert design is addressed tending them is not.                                  l?) The disposal of hazardous wastes associated with oil
          Evaluations along the Trans Alaska Pipeline and the Dalton                                 development presents a serious long term problem that is not
          Highway show that metal culverts remain frozen after spring                                adequately addressed and are not fully understood in the Arctic.
          breakup beciins causing significant poncling of surface water, to
          such an extent that vec
                                  getation is drastically altered, animal                            20) The report does not consider energy conservation and creating
          populations changed, and washout of roads and workpads occurs.                             viable alternative energy sources that can better provide for.
          Substantial areas of the North Slope have been altered by                                  future needs than can the Arctic Refuge.
          non-functional culverts in runoff conditions.
                                                                                                     21) The report does not deal with the value to the people of
          10) Based on studies a)on4 the Trans Alaska Pipeline in 1980 and                           establishing the 1002 area as part of the National Wilderness
          other years, snow drifting may be 5 to 6 times that indicated in                           Preservation System.   In fact the report, page 93, states that-,
          the report (100 ft.).   This coupled with impounding of runoff                             "No further study or public review is necessary for the Congress
          from roads and workpads will account for several hundred more                              to designate the 1002 area as wilderness." It also states that a
          acres of nesting habitat effected than is indicated in the                                 wilderness review was conducted in the early 1970's pursuant to
          report.                                                                                    the provisiona of the Wilderness Act, but the draft report was
                                                                                                     nevei, made final nor was puplic c(xnent obtained.   The Wilderness
          11) Based on studies durinc),1976-81 along the Dalton Highway,                             Act of 1964 directed federal agencies to study areas to determine
          dust shadows can result in a 55% reduction of nesting bird                                 their suitability as Wilderness. As part of this process,
          densities and extend about 800-1000 feet down wind.     The report                         Agencies were directed to hold public hearings.     Hearings were
          states only 250 ft. for a total of 7,000 acres will be effected                            never held and the report was never finalized for this area,
          by development.   The actual effect of development may be more                             although Congress directed the Secretary to do so.
          than 4 times what the r-port suggests.
                                                                                                     22)The Department seems anxious to pursue development. It has
          12) Increased snow drifting, accelerated snow melt due to dust,                            disregarded the purpose for designating the area for future
          and impounding of sheet flow by roads and workpads can combine     to                      generations of Americans.   It wants to make all the decisions
          produce significant environmental impacts over a larger area than                          here and now and not leave any options for the future.     The
          the report states.                                                                         Department has taken every measure to prevent the public from
                                                                                                     commenting on this report. It took a court case to direct the
          ia) Ongoing studies od the Lisburne Terrestrial Monitoring                                 Department to allow comment on this report.
          Program-1985 Jk 1986 have provided current data of direct import
          to this area.   Considerable insight as to consequences of                                 In view of these findings and others that we have not cited we
          development activities can be added to the assessment by                                   can not agree with the Departments recommendation of "full
          including these data with the referenced material.                                         leasing of the Coastal plain." We feel that the unique wilderness
                                                                                                     resource of this area is important to the nation as well as
          14) Ptarmigan were one of the minor residents on the area's study                          Canada.  Therefore, we urge that no further development or land
          plots. Tundra-nesting birds (other than ptarmigan) and small                               trade in the 1002 study area take place and that the area be
          mammals will probably incur greater losses than ptarmigan, and                             added to the National Wilderness Preservation system.
          they are important foods for larger predators.
                                                                                                     Thank You for complying with the court for the opportunity to
          15) Regulations that deal with oil spill prevention, containment,                          comment.
          and cleanup should be noted in the report.
                                                                                                     Sincerely,
          16) Caribou herds are an enigmatic group of individuals, often
          unpredictable in response to natural and unnatural phenomena. and
          area unique resourceP The report does not contain sufficient
          data to assess the potential inpact of development on this
          species.                                                                                   William J. Holman
                                                                                                     Alasl,a Regional Representative
          17) The scenarios presented for the various alterriRtives 4or the                          4300 Rendez-)ous Circle
          petroleum potential are pure conjecture until the resources are                            Anchoracie. F4K Q9504
          defined.                                                                                   907) 33:1-9454

          18) The report looks at the 1002 area in isolation, rather thar.
          examining in detail the cumulative effects of oil and qas
          development on adjacent state and federal leases and offshore on
          the outer continental shelf.

                                     Working lor the Natum nt loninft-.

         NATIONAL WILDLIFE FEDERATION, 1412 Sixteenth Sttect, N.V., Washington, D.C. 20036-2266 (202) 797-6KOO
                                   Office of the Executive Vice Pmsident                              lobby_Congress to open the Arctic Refuge to oil and gas
                                                                                                      development (December 1986 issue of Alaska Construction and
                                                                                                      Oil). And, of course, concurrent with all of this are the
                                                                                                      secret negotiations the Department of the Interior has .
                                                   February 4, 1987                                   underway with Native corporations to trade away the public's
                                                                                                      interest in the subsurface rights to oil and gas resources
                                                                                                      of the 1002 area.
              The Honorable Donald Paul Nodal
              Secretary                                                                               The course of action recommended by Assistant Secretary.Horn
              U.S. Department of the Interior                                                         and the direction that seems to be coming from the Interior
              18th and C Streets, N.V.                                                                Department give us concern about your commitment to be
              Washington, D.C. 20240                                                                  guided by the oath of public trust to which you have pledged.
                                                                                                      yourself.

              Dear Mr. Secretary:                                                                     The Federation, howeveri attempted to review the report
                                                                                                      objectively. Our review has been extensive, and involved a
                                                                                                      critical analysis of all major aspects of the available
              The National Wildlife Federation (NWF) has always viewed     the                        Information.
              Coastal Plain of the Arctic National Wildlife Refuge as a
              magnificent natural resource. It provides critical habitat.                             our first problem with the report Is that it does not comply
              for an incomparable array of arctic wildlife, including                                 with the mandate of Congress in several is    ortant respects.
              caribou, polar bears, grizzly bears, musk oxen, and snow                                one of the most glaring oversights is that! despite the
       0      geese. It is truly a world-class wildlife area and a                                    specific requirements or the law for a baseline study or
       r;3    national treasure.- However, the Federation has long                                    fish and wildlife resources, there are significant I
       L11   .recognized that U significant deposits of oil and gas are                               shortcomings In the biological data upon which the report Is
       co     present in this area, the question of their development and                             premised. For example, one of the most important questions
              production will have to be addressed.                                                   to resolve before AM recommendations can,be made about
              The National Wildlife Federation has reviewed the Draft                                 future development in the 1002 area Is to define the
              coastal Plain Resource Assess      , the so-called 1002                                 critical calving habitat for the Porcupine Caribou Herd.
                                            M=                                                        Yet, leading caribou biologists agree that the.biological
              Reporti which examines several questions surrounding the                                data is insufficient to define the ecological attributes of
              potential oil and gas resources of the Arctic coastal Plain.                            critical calving areas.
              Federation staff, knowledgeable leaders from our state
              affiliate in Alaska (The Wildlife Federation.of.Alaska), and                            Another oversight is the Department's failure to consult in
              our consulting geologist have,exauined the report and have                              a timely manner with the Government of Canada. Despite-the
              provided me with detailed consents. Also, along with two                                explicit mandate of the law, no consultation occurred before
              other senior staff members, I traveled to Alaska in mid-                                the report was released. This is a significant omission,
              January to meet personally with representatives of the major                            given that the Porcupine Caribou Herd Is an international
              state and federal agencies, oil and gas companies, and                                  resource and the Government of Canada has recently
              environmental-interests concerned about the future of these                             established the North Yukon National Park Immediately
              1
              S:nds.                                                                                  adjacent to the Arctic Refuge. At the minimum, this is an
                                                                                                      arrogant disregard for one ofthe United States' most
                nce the outset, I have had-reservations about the process                             important allies.,
              the Department of the Interior used in producing this
              report. Public interest groups had to resort to litigation
              to obtain access to the assessment process and the
              opportunity to comment on this draft. Then, Assistant
              Secretary Horn publicly unveiled a strategy for industry to

               Beyond such omissions, the analysis presented in the report                            Instead, in an effort to make a more positive and
               is seriously flawed. For example:                                                      constructive contribution to the resolution of this
                                                                                                      controversy, the National Wildlife Federation will submit a
                    0    there is little support  for the apparent                                    comprehensive report regarding the future of the Coastal
                         conclusion of the Executive Summary that    impacts                          Plain of the Arctic National Wildlife Refuge to the Congress
                         upon fish and wildlife resources can be mitigated                            shortly.
                         effectively; in fact, this assertion appears to be
                         contradicted later by the report when it states,                             We will be pleased to make copies of that report available
                         for example, that mitigating the loss of caribou                             to you, Assistant Secretary Horn, Director Dunkle, and
                         core calving habitat "is not possible";                                      representatives of other interests when It Is released to
                                                                                                      Congress and the public.
                    0    the cumulative environmental impacts of    developing
                         millions of acres of adjacent on-shore and off-                              Thank you.
                         shore lands -- which are planned for leasing --
                         are ignored; and,                                                                                            Sincerely,
                    a    the report concludes that providing the fresh
                         water necessary to drill even g= exploratory well
                         is a significant and unresolved problem and then
                         simply fails to address the question of providing                                                            JAY D. HAIR
                         the water necessary for any level of future
                         development.                                                                 JDH:kg
        N)     These are only a few examples of the problems which are                                cc: Assistant Secretary Horn
               evident with the assessment of the potential impacts of                                     Director Frank Dunkle
               development of the 1002 area. In general, the shortcomings
               of the fish and wildlife impact analysis are matched only by
               the zeal with which the Department wraps its *lease-
               everything" recommendation in the flag of national security.

               Together, the conduct and content of the report, make it
               clear that the Department has already decided what it will
               recommend to Congress regarding the future of the Arctic
               National Wildlife Refuge. As a result, the critical
               questions Posed by Congress In enacting ANZLCA remain
               unanswered. It is regrettable that Instead of responding to
               the mandate of Congress the Department has embarked upon a
               course of action which can only add to the polarization of
               this controversy and cloud the very issues which it was
               asked to resolve.

               Therefore, the National Wildlife Federation does not believe
               that its submission of detailed comments on the Draft
               Coastal Plain Resource Assessment to the Department of the
               interior would be constructive. The comments submitted by
               our state affiliate, the Wildlife Federation of Alaska,
               adequately represent our views.

    	NATIONAL
    	WILDLIFE REFUGE
    	ASSOCIATON

    16096 CREEKWOOD ROAD
    PRIOR LAKE , MINNESOTA 55372
    (812) 447-5586
    JANUARY 15, 1987

    Mr. Willaim P. Horn
    Assistant Secretary for Fish and
    	Wildlife and parks
    U.S. Department of the interior
    Fish and Wildlife Service
    18th & C streets, N.W.
    Washington, D.C. 20240

    	Attn: Division of Refuge Management
    Dear Mr. Horn:
    This expressed the concerns and views of the National Wildlife
    Refuge Association (NWRA) on the draft Arctic National Wildlife
    Refuge, Alaska Coastal Plain Resource Assessment report released
    for public review November 24, 1986. As a nationwide citizens'
    organization dedicated to the preservation and perpetuation of the
    National Wildlife Refuge System, we appreciate this oppertunity to
    review and comment on the draft 1002 report document. Many of our
    members have had extensive experience in manageing National Wildlife
    Refuges and in administering oil and gas operations, including
    related developments on Alaskan refuges.

    Unlike some conservation groups, NWRA has deferred taking a position
    on thsi controversial issue until we could review the Interior
    Department 1002 report. Despite the inevitable environmental dam-
    age of oil and gas extraction to dedicated conservation lands, we
    believe that such development could be sanctioned if a national
    emergency or crucial need positively existed and if other energy
    development alternatives were impractical to pursue. We recognize
    that properly-directed oil and gas developments can be condoned as
    an acceptable use of federal lands, including wildlife refuge units
    where habitat manipulation is a standard management practic. we
    also recognize and appreciate instances where direct or indirect
    contributions of the oil idustry have benefited some refuges. Oil
    and gas leasing on the coastal plain of the Arctic National Wildlife
    Refuge is, however, a horse with a different color.

    The Arctic Refuge was not the creation of a government bureaucracy.
    A review of the extensive and detailed files of the establishment
    of the original wildlife range reveals that this magnificent reserve
    exists because of teh exhaustive efforts of citizens throughout the
    Nation. For a 10-year period, major conservation organizations,
    sportsmen's groups, civic organizations and renowned naturalists,
    including Olaus and Margaret Murie, studied the area and supported
    its establishment. The arctic reserve concept was brought forward
    for executiev confirmation by individual citizens and conservation

    				-2-
    Leaders in ALaska and throughout the Nation. It exists today
    because people cared enouth to have it established. Its status
    will be vigorously defended because people car even more about
    its protection now in a world rapidly running out of virgin Wild-
    lands and their associated wildlife. The arctic Refuge is un-
    questionably one of teh last outstanding natural treasures in the
    entire world.

    Since the inception of our organization in 1975, we have strongly
    supported the maintenance of the wildland character of the arctic
    and the expansion of the Arctic Refuge under the Alaska National
    Interest Lands conservation Act of 1980 (ANILCA). We have worked
    with conservation groups over the years to protect refuge values
    from various detrimental threats, and our efforts to preserve this
    internationally important arctic reserve will prevail until it can
    be unequivocally demonstrated to be in the national interest to do
    otherwise. With respect to the recommendation for full leasing of
    the coastal plain, our postition is that an acton of this magnitude
    at thsi time is not in the long-term economic, national security,
    or conservation interest of our Nation.

    We find many inadequacies in the 1002 assessment report. We find
    the report to be seriously incomplete in vital information areas
    and woefully inadequate in analyzing the discussing alternatives,
    as well as the bilogical, social and economic impact of full scale
    leasing, A bias toward development is noted and we suspect that
    this is inte4nded to influence public sentiment under the guise that
    the 1002 area is "clearly the most outstanding oil and gas frontier
    remaining in teh United Staes", and full leasing would "contribute
    substantially to national economic and security interests."
    Unfortunately, these statements, in the absence of supportive infor-
    mation, may be viewd as contentions rather than facts. An action
    of this magnitude and its potential environmental and social con-
    sequence must be based on fact, not mere contentions.

    If it is in the national interest to develop oil and gas resources,
    industry should look first to developing the numerous leases
    already in its possession throughout the United States, including
    onshore and offshore lease areas situated along the breadth of the
    arctic costal plain, and keep this part of the refuge's coastal
    plain intact, at least during the immediate future. Development
    of the 1002 area should be a last resort, predicated on a clearly
    demonstrated national need. We hasten to note that major compro-
    mises have already been made on Alaska's North Slope by both
    development and conservation interests. These resulted in making
    90 percent of the arctic costal plain available to industry in
    addition to some 24 million acres of state-controlled nearshore
    and federal offshore areas along the Beaufort Sea.

    The problem of report completeness poses a major concern to our
    organization. Aside from the need to provide supportive informa-
    tion on full leasing, we believe that the report is remiss in not

                                                      3 -                                                                                                      4

                           describing the proc .ess and rationale leading to the establishment                                      These issues should have been presented and discussed in a separate,
                           of the original arctic wildlife range. The draft report (page 45)                                        clearly-defined section of the 1002 report.
                           states that "the Arctic Refuge is the only conservation system                                           We find the alternatives to be both narrow in scope and superfici-
                           unit that protects, in an undisturbed condition, a complete spectrum
                           of the various arctic ecosystems in North America." This statement                                       ally discussed. This my be by design to facilitate support of
                           would be more meaningful if reviewers had a better insight to the                                        the preferred alternative of opening the entire 1002 area to full
                           exhaustive efforts, and the reasons for these efforts, that culmin-                                      leasing. Due emphasis should be placed on greater objectivity in
                           ated in a mandate to preserve the natural integrity of this special                                      selecting alternatives and discussing their implications in the
                           ecosystem. Development now or in the future is clearly in conflict                                       final document. We note that the 1002 report makes reference to
                           with the original purpose of establishment. The 1002 report does                                         structuring a leasing program to protect the southeast part
                           not adequately address the wildland values of the coastal plain                                          (242,000 acres) used as a caribou calving area so this would be the
                           and how these values will be changed by large scale oil and gas                                          last part to be developed. This type of rationale should be the
                           developments.                                                                                            key to all development alternatives. The manner in which alter-
                                                                                                                                    natives have been drafted induces our organization to oppose full
                           The report is conspicuously void of any discussion of commitments                                        scale leasing and to support the no action alternative.
                           of the United States to the international community. It should
                           recognize, among others, the following treaties and legislative                                          Because of the inadequacies which we perceive in this document
                           mandates:                                                                                                the NWRA strongly opposes oil and gas leasing.along the coastai
                                                                                                                                    plain area of the Arctic Refuge. We urge the Interior Department
                              1.  The Migratory Bird Treaty with Canada, Mexico and Japan                                           to manage this unique area--the refuge in its entirety--consistent
                                  as concerns the possible impact on the continental snow                                           with the purposes for which it was founded, lest this unique
                                  goose populations, produced in Canada and tranditionally                                          arctic reserve be sacrificed on the altar of economic dogma.
                                  using the 1002 area for feeding-and staging prior to
                                  migration.                                                                                        in conclusion, you should know that we strongly object to the
                                                                                                                                    secretive efforts of the Interior Department to negotiate land
                              2.  The agreement for the Conservation of Polar Bear (1973)                                           exchanges with Native organizations. These negotiations are
                                  with Canada, Denmark, Norway, and the U.S.S.R., which                                             obviously aimed toward influencing congressional decision making.
                                  states that each contracting party shall take appropriate                                         While we agree with land exchanges in principle, we strongly oppose
                                  action to protect the ecosystems with special attention                                           the manner in which current negotiations behind closed doors are
                                  to protecting denning and feeding sites and migration                                             being conducted. This approach may lead to costly litigation on
                                  patterns. Development in the 1002 area would adversely                                            essentially the same grounds that the St. Matthew Island land ex-
                                  affect known polar bear denning areas.                                                            change was contested and ruled an illegal action by the Federal
                                                                                                                                    Court. The Arctic National Wildlife Refuge was established by the
                              3.  Agreement calling for cooperation in the field of environ-                                        American people for the American people and they should have an
                                  mental protection between the U.S.A. and the U.S.S.R. (1972)                                      opportunity to voice their opinions whenever dedicated public lands
                                                                                                                                    are transferred to private ownership.
                              4.  The 1976 convention between the U.S.A. and U.S.S.R. con-                                          We will appreciate your careful consideration of the concerns which
                                  cerning the Conservation of Migratory Birds and their
                                  Environment (impact on birds migrating along the northern                                         we have expressed.
                                  part of the continent).                                                                           Sincerely,
                              5.  Impact on the ANILCA directive requiring consultation with
                                  the Canadian government involving oil development along
                                  the refuge coastal plain adjacent to Canada's Northern
                                  Yukon National Park. Canadian officials had not been                                             Llorrest A. Carp    6r
                                  consulted before the 1002 report was 1,eleased November 24.                                       President   ,
                                                                                                                                    National Wildlife Refuge Association
                              6.  Impact on on-going discussions with Canada concerning the
                                  establishment of an international Porcupine caribou
                                  treaty. Development would adversely affect this herd and
                                  subsistence activities associated with Arctic Village,
                                  Kaktovik. and the Canadian village of Old Crow.

                                       U. S. Fish and Wildlife Service
                                        Division of Refuge Management
                                              2343 Main Interior                                                              area is the most biologically productive part of the Arctic MIR.
                                      18th & C Sts. N.W. Wash DC 20240                                                        Despite this and the knowledge that the development of economically
                                                   Comments                                                                   recoverable oil is going to depend upon full exploration, gambling on
                                                     Draft                                                                    production and constructing all necessary facilities, the Interior
                                  Arctic National Wildlife   Refuge, Alaska,
                                      Coastal Plain Resource Assessment                                                       Department recommends that all indicated oil bearing areas within
                                                      BY                                                                      the 1002 portion of 1.5 million acres of the Arctic NWR coast be leased
                                 The National Wildlife Refuge Association                                                     for development.
                               Washington Representative - Marcus C. Nelson
                                   4216 Downing St. Annandale, Va. 22003
                                                                                                                                  According to the 1002 report, the outstanding wilderness, wildlife
                                                                                                                              habitat and fish and water qualities will be severely impacted by oil
                     The Interior Department'srecommendation to the Congress, in its                                          and gas leasing. The presence of oil development facilities would elim-
                 "Draft Arctic National Wildlife Refuge, Alaska, Coastal Plain Resource                                       inate the wilderness character in development areas and cause intrusions
                 Assessment" pits the protection of a pristine National Wildlife Refuge                                       into designated wilderness adjacent to the 1002 area. Development would
                 enviornment of un Iparalleled ecological value against the exploration                                       cause widespread, long-term changes in wildlife habitats and interfere
                 and development of those lands for the unproven production of oil.                                           with native subsistence activities.

                     The Arctic National Wildlife Refuge (ANWR) was set aside to protect,                                         The National Wildlife Refuge Association (NWRA) has strongly supported
                 in an undisturbed condition, a complete spectrum of various arctic                                           the expansion of the Arctic refuge unit and the maintenance of its
                 ecosystems, which together with Canada's adjoining Yukon National Park,                                      wilderness qualities early in the deliberations of the Alaska National
                 constitute the most spectacular a  rctic sanctuary found anywhere in the                                     Lands issue. The NWRA and conservation organizations worked during
                 world. lbe-18-million acre arctic NWR provides internationally important                                     succeeding years to protect the Arctic NWR from potential encroachments
                 calving and rearing grounds for the 180 thousand head porcupine caribou                                      on the premise that the naturalness of the unique ecosystems of arctic
                 herd as well as natural habitats for polar bears, grizzly bears, musk ox,                                    Alaska should prevail when virtually the rest of the north slope and
                 dall sheep, wolves, wolverine, peregrine falcons, snow geese and other                                       millions of acres of other Alaska lands and waters would be accessible
                 important migratory birds.                                                                                   to commercial interests.

                     Because the coastal plain area reputedly contained major oil and gas                                         in a  separate action, the Department and Native Corporations have
                 resources, Congress, in Section 1002 of ANILKA, identified 1.5 million                                       negotiated towards the exchange of privately owned lands for sub-surface
                 acres of the 2.0 million acre coastal plain for study and required a                                         rights on the coastal plain area of the Arctic NWR surrounding Kaktovik.
                 comprehensive assessment of resource values, including petroleum resources                                   This unofficially estimated 95,000 acres of presumed oil bearing lands,
                 through a Government-guided   .oil exploration program by means other than                                   at least equal to the potential of other refuge lands, invites a major
                 actual drilling.                                                                                             private development over which Oe Government would have little control.

                     This past November, the u. S. Fish and Wildlife Service (USFWS)                                              The NWRAs position on the Arctic NWR development concerns serious
                 released the required draft resource assessment for a 60-day public                                          inadequacies of the 1002 report. The report is flawed by an insufficient
                 review peried. The "so called" 1002 report recognized that the study

                analysis and discussion of alternatives other than opening
                the entire 1002 area to oil leasing. Another  critical shortcoming
                concerns the distorted importance of the areas petroleum resources
                without providing a perspective of the cumulative benefits and impact
                from oil and gas lease sales already let and to be scheduled in other
                parts of arctic Alaska, including off shore areas. The IGIRA believes
                that the 1002 report should be re-drafted to be more thorough and
                objective in content; otherwise, the review and decision making process
                will be woefully impaired.

                    Based on the known widespread, long-term changes in wildlife habitat
                and natural systems that will occur, weighed against the gamble of
                full exploration to develope what oil may be present under the locations
                that showed signs of promise will spread activity over most of the
                1.5 million acres studied. This appears to be "over kill" and not in
                the best strategic, economic or conservation interests of the United
                States to recommend such sacrifices on the finest Arctic Wildlife Sanctuary
                in the world at a time of world oversupply of oil, and with millions of
                acres of other federal and state lands available.

                   The National Wildlife Refuge Association appreciates this opportunity
              to comment on this most important proposal under consideration for the
              Arctic NWR.

                                                               dated 1-9-07

    	Natural Resources
    	Defense Council

    	122 East 42nd Street
    	New york, New York 10168
    	212-949-0049

    	Comments
    	of the
    NATURAL RESOURCES DEFENSE COUNSIL
    		on The
    	Draft
    Arctic National Wildlife Refuge
    Coastal Plain Resource Assessment
    Report and Recommendation
    To the
    Congress of the United States
    And Legislative Environmental Impact Statement

    February 6, 1987
    Prepared by:
    Lisa Speer
    Senior Project Scientist
    Natural Resources Defense Council

    		1
    	The Natural Resource Defense Council (NRDC) is a national
    enfironmental oraganization dedicated to the protection and
    enhancement of the nation's natural resources. NRDC's membership
    totals approximately 60,000 members and supporters in the U.S and
    Canada. NRDC has had a long standing interest and involvement in
    the federal government's oil and gas leasing programs; we there-
    fore welcome the opportunity to comment on the Interior Depart-
    ment's draft Report to Congress and Legislative Environmental
    Impact Statement (LEIS) on oil development in the coastal plain of
    the Arctic National Wildlife Refuge. Our major comments can be
    summarized as follows:

    1. The draft Report/LEIS fails to meet the requirements of NEPA
    and its implementing regulations because it does not adequately
    assess:

    a. cumalative impacts of oil and gas development in the
    Alaskan and Canadian arctic;

    b. Reasonable alternatives to the proposed action;

    c. Imapcts of gas development;

    d. imapcts of full leasing on water quantity and quality;

    e. impacts of full leasing on air quality;

    f. conflicts between teh proposed action and the Alaska
    coastal management program; and

    g. impacts on endagered and threatened species.

    2. The draft Report/LEIS fails to comply with Section 810 of
    the Alaska National Interest Lands conservation Act.

    3. The Department's estimates of the amount of oil and
    associated economic benefits that would accrue to the nation from
    full leasing of the coastal plain fo the REfuge are overstated as
    a result of the use of overly optimistic assumptions and
    methodologies that inflate the amount and value of projected oil
    reserves.

    4. The Department's conclusions that the oil industry can
    operate in the arctic without significant environmental

                                                2                                                                                           3

              consequences is unjustified and Is contrary to evidence presented                         recommendations regarding whether oil and gas development     in the
              in the body of the draft Report.
                                                                                                        coastal plain wouldbe in the national Interest.

              I.    Introduction                                                                              On November 24, 1986, the Department Issued a draft Report,
                    The le million acre Arctic National Wildlife Refuge is the                          to Congress and Legislative Environmental Impact Statement (LEIS)
              second largest refuge in the National Wildlife Refuge System and                          recommending full leasing of the coastal plain to the all Indus-
              the largest arctic wilderness sanctuary for wildlife In the.world.                        try. The decision to recommend full leasing was based an three
              The Refuge, which stretches from the southern foothills of the                            considerations:   the analysis of Impacts presented In the draft
              Brooks range.to the Beaufort Sea   In northeastern Alaska, supports'                      Report, the national need for domestic sources of oil and gas,.and
              one of the few remaining large caribou herds In North America, as                         "the ablllty of the Industryto minimize damage to the North Slope
              well as polar bears, grizzly bears, moose, muskox, Dall Sheep    ,                        environment as learned from oil and gas activities elsewhere In
              wolverines. snow geese, peregrine falcons and other species of                            the Alaskan Arctic." Draft   Report thereafter, "D.R.") at Ill.
              arctic fish and wildlife. The coastal plain portion of the Arctic                               As discussed In detailbelow, the Department's substantive
              Refuge lles.on the north slope of the.Brooks Range and consists                           analysis of these three considerations is seriously flawed. In

              largely of pristine, extremely   fragile tundra and wetlands. The                         addition, there are many  legal deficiencies In the draft

              coastal plain lies 60 miles to   the east of the giant oil fields                         Report/LEIS. Taken together, these defects in the Department's
              near Prudhoe Day, and according   to the Department's draft Report                        analysis render the document fatally flawed and therefore not a
              to Congress, there is a 19% chance that economically recoverable                          suitable or adequate basis on.which to make recommendations to
              all exists somewhere In this region of the   ArctIc Refuge.                               Congress on leasing In the Arctic'Refuge.

                    The Alaska National Interest Lands Conservation Act    of 1980

              (ANILCA) placed roughly half of the Arctic Refuge under wilderness                        II.   The Analysis of Environmedtal Impacts In the Draft Report to
                                                                                                              Congress/LEIS
              protection but.deferred a decision to protect 1.5 million acres of
                                                                                                              A. The Conclusions Drawn   In the Executive Summary @jje not
              the coastal plain as wilderness pending a comprehensive assessment                        supported by the Body of the Draft Report.
              of resident fish and wildlife, oil and gas potential and the                                   According to the draft Report  I. full leasing of the coastal
              Impacts that 611-development may have on the environment of the                           plain could result In a 20-40% decline   in the Porcupine caribou
              Refuge.  ANILCA *instructed the Secretary of the Interior to report                       herd (D.R. at 112), a 20-50% reduction   In the muskaxen population
              his findings'on 'these three topics to the Congress along with his                        (which in 1985 numbered only.476.) (,Ld. at 114). a loss of half of

                                                                                                        the wolverine population (Ad. at 116).   almost 50% of the snow

                                                  4

              goose that stage In the coastal plain (ld. at 122), and a        loss of                       Omissions from the   draft report/LEIS, discussed below,      ren der the
              subsistence hunting opportunities throughout approximately one                                 document so inadequate as to preclude      meaningful analysis.     The
              half of the coastal plaln.(@Ld. at 132). In light of these and                                 Department must therefore prepare and      circulate a revised    docu-

              other impacts projected by the    draft Report, It is difficult to                             ment, as provided for by 40 C.F.R. 61502.9(a).

              understand how the Department    can conclude In the Executive

              Summary  that oil development on the coastal plain can be expected                             1.    Cumulative Impact

              to generate "minimal effects" (1d. at 2).                                                            Cumulative effects are     those that  result from   the Incre-

                    The Executive Summary Is the document most often read by                                 mental Impact of a proposed action when      added to other past,

              declelon-makers and others. It must accurately reflect the.                                    present and reasonably foreseeable future actions (40 C.F.R.

              conclusions of the body of the, Report so that a complete.under-                               170B..7). Nowhere In the draft Report/LEIS does the Depa        rtment.
              standing of thelaplications of developing the Arctic Refuge may                                analyze In-detail the cumulative Impacts of oil and gis develop-

              be had by all readers. The Executive Summary should be revised to                              ment projects throughout the Alaskan     and nearby Canadian arctic,.

              explicitly state the losses of wildlife and habitat projected to                               UCTSPA LO @ 1.910 L OL; L LUM L a large number of oil and gas development

              result from full leasing.                                                                      projects.have been undertaken In or are planned for the region

                                                                                                             (e.g.. Prudhoe  Day. the Lisburne Field, the Kuparak Field,       the

                                                                                                             Endicott Project, Milne Point, Seal Island, the Naval Petroleum

              B.    Deficiencies in the NEPA Analysis                                                        Reserve-Alaska  and State, federal and Canadian waters of the

                    The purpose of an environmental impact statement Is to                                   Beaufort.Sea).

              provide a full and fair discussion of the significant environ-                                       There are a large.number of wildlife species that stand to

              mental impacts of a proposal and to inform decision makers and        the                      be significantly affected by     the Incremental Impacts of all.of the

              public of the reasonable alternatives which would avoid or                                     different oil and,gas.development projects In northern Alaska and

              minimize adverse effects on the environment. 40 C.F.R. �1500.2.                                Canada. For   example,-  denning polar bears are extremely sensitive

              The Council on Environmental Quality's regulations Implementing                                to human*activitles.    D.R. at   117.   The draft Report notes that

              NEPA specify that In order to achieve these goals, certain                                     oil development could    produce a major reduction In the availabl-
              Information must be presented In an EIS. Unfortunately, the draft                              lity of denning habitat In the 1002 area.       Id. at 118.     Similar

              Report to Congress/LEIS does not fulfill the Informational                                     reductions In dennlng habitat can be expected to result from

              requirements mandated by NEPA or Its Implementing regulations.                                 current and future oil development     elsewhere In the arctIc.      It Is

                                                6                                                                                          7

             therefore critical that the Interior Department analyze the                                fails to evaluate the effect of oil and gas activities In the
             cumulative Impacts of all those developments. only by doing so                             Canadian Beaufort Sea.   The Sale 97 cumulative Impact analysis
             will the Department be able to assess the extent to which develop-                         therefore could not be used In the final Report/LEIS on the Arctic
             ment of the Refuge, in combination with similar developments                               Refuge.
             elsewhere, will affect the overall health and survival of the                                    We recommend that the Department prepare and circulate for
             regional polar bear population.                                                            public comment a draft cumulative impacts assessment prior to
                   Another species sensitive to human disturbance Is the snow                           Issuing the final report to Congress in accordance with 40 C.F.R.
             goose.  This species is highly sensitive to aircraft disturbance.                          �1502.9.

             Id. at 121. Studies have reported that snow geese flush In
             response to aircraft and helicopters passing by at distances of up                         2.    Failure to Consider Reasonable Alternatives to the Proposed
                                                                                                              Action
             to 9 miles. Id. The draft Report concludes that oil and gas
                                                                                                              One of the most Important functions of the NEPA process to
             activities In the Refuge could result in the displacement of these
                                                                                                         soess the reasonable alternatives to proposed actions that will,
             geese from up to 50% of their preferred staging habitat. Id. at                            :void or minimize adverse effects on environmental quality.
             122.  If this has occurred or is occurring In other areas of the                           Indeed, the CEQ regulations call the analysis of alternatives "the
             Alaskan arctic subject to oil development, major impacts to the
                                                                                                        heart of the environmental Impact statement". 40 C.F.R. �1502.14.
             regional snow geese population could result. It is therefore
                                                                                                              According to the draft Report, energy Independence and
             extremely Important that the Department evaluate the effect on
                                                                                                        economic benefits appear to be the primary goals the Department
             snow geese of leasing in the Refuge In the context of larger
                                                                                                        hopes to achieve by opening the Refuge to oil development (e.g.,
             Impacts resulting from development activities across the region.
                                                                                                        D.R. at pages 111-8, 161-166, 169). Yet nowhere In the draft
                   The Department has recognized the need to perform cumulative
                                                                                                        Report could we find any analysis of alternative methods of
             Impact analyses for oil and,gas development on federal land and                            achieving these same goals.
             routinely does so for federal OCS lease sales. For example, the
                                                                                                              Rather than evaluating alternatives for enhancing energy
             draft environmental Impact statement for Lease Sale 97 in the
                                                                                                        security and associated economic benefits, which together consti-
             Beaufort Sea evaluates the cumulative effects of oil and gas
                                                                                                        tute the purpose for action, the Department Improperly frames the
             operations throughout the Alaskan Arctic.     (FEIS Sale 97 at 4-A-                        alternatives In terms of forgoing such benefits In order to
             28). We note however, that the Sale 97 cumulative impact analysis
                                                                                                        partially or completely protect the Refuge from oil and gas
             assumes no development in the Arctic National Wildlife Refuge and
                                                                                                        development. For example, the draft Report's discussion of the

                                                                                                                                             9

             wilderness alternative Indicates that by designating the Refuge as                          the desirability of pursing one energy scenario over others. The

             wilderness, the nation must completely forgo the energy and                                 following energy alternatives should be examined.

             economic benefits that will allegedly result from developing oil                                  a.    Improved automobile cas m1leage standards
             and gas in the Refuge.A This Is     not necessarily the case, as                                  The Administration has rolled back fuel economy standards
             there are many other options for    reducing the nation's dependence                        from 27.5  miles per gallon (mpg) mandated by Congress to 26 mpg
             on foreign oil achieving related    economic benefits.                                      for 1986, 1987 and 1988 model year automobiles. The decision not

                    The Report to Congress and   accompanying Legislative EZS                            to enforce original fuel economy standards means that     an extra 300

             provide the opportunity to stand    back and evaluate broad policy                          million barrels of oil will be used by 1987, 1987 and     1988 model

             alternatives to promote national    goals of energy independence and                        year cars.

             economic benefits. We believe that alternative energy sources                                     To put this  number In perspective, the Department's draft

             should be discussed in the context of the "Wilderness" and "no-                             Report to Congress estimates that the coastal plain portion      of the
             action" alternatives so that ways of avoiding oil and gas develop-                          Refuge contains an  estimated risked mean of 614 million barrels of

                   in the Arcti
             menic             c National Wildlife Refuge   can be explored. For                         oil. Z&AUU, UY L110 04nV40 OGICAOn  orrolling back automobile

             example, if President Reagan had signed the    National Appliance                           efficiency standards for th  ree years, the Administration   will

             Energy Conservation Act of   1986, the nation  could have saved about                       cause the equivalent of   half of the.oil projected to underlie the
             1.3 billion barrels of oil   equIvalent.2 This represents more than                         Arctic National Wildlife   Refuge to be needlessly burned by less

             twice the risked mean oil   resources thatIthe Department estimates                         fuel efficient cars.
             underlies the Arctlc-Refuge.3 The "wilderness" and "no.actlon"         I                          b.   Appliance efficiency   standards

             alternatives should be structured so that comparisons of      this sort                           The economic attractiveness of appliance efficiency stan-

             can be readily made. This will permit the publicto comment on                               dards was demonstrated In 1986 when the appliance Industry and      the

                                                                                                         conservation community jointly sponsored federal legislation to
             1.     "A decision to designate  Ithe 1002 area as wilderness will
             maintain long term fish, wildlife, subsistence and wilderness                               enact uniform appliance. efficiency standards. As noted above,
             values at a cost of a.potentlal but unconfirmed 3.2 billion
             barrels of oil." Draft report at 144.                                                       these standards would have saved an estimated 1.3     billion barrels

                                                                                                         of oil equivalent from.gas savings   In furnaces, water heaters, and
             9. Howard Geller, American Council on     an Energy Efficient
             Economy, 1986. Energy and Economic Savings Potential from       Natural                     ranges. Despite   the swift passage  of the legislation by over-
             Appliance Efficiency Standards.
                                                                                                         whelming margins  In the Congress, the President   chose  to forego
             3. Mean estimate of conditional, economically recoverable       oil
             (3.23 billion barrels) times marginal probability (19%)       614                           these significant  energy savings and vetoed   the bill  in November.
             million -barrels of ol-1.

                                              10
             It Is difficult to understand why the Administration feels so                          Implementation period, 6 yet the federal government has proposed no

             pressing a need to open the Refuge in light of Its rejection of a                      programs to help this process along.   The only direct government

             far more effective method of assuring energy security.                                 Involvement has been In solar and conservation tax credits. This

                   C.   Government funded conservation research                                     program was terminated at the request of the Administration.
                   According to DOE,4 federal Investments In 18 major Indus-                              e.   Mass Transit Expansion

             trial/commerclai energy saving technologies will be providing 521                            Mass transit Is more fuel efficient than automobiles and

             million barrels per year In equivalent energy savings by the year                      also allows a reduction In automobile travel miles in areas well

             2010. These technologies have been Introduced into the market in                       served by mass transit. A 50% change in transit ridership up from

             the 1978-1983 period and savings are based on expected market                          current levels could save over 3 billion barrels of oil over the
             penetration by 2010. Despite the success of these technologies,                        next twenty years.7 Mass transit Is generally a much lower cost

             the Administration Is advocating a 50% cut in federal conservation                     option to the nation than automobile-based transportation systems,

             technology research and development as part of its PY 1988 budget                      even excluding the benefits of their lower energy costs. Yet the

               on top of a 50% cut from FY 1980 through FY 2987. These budget                       Administration has consistently supported large cutbacks In
             cuts will mean that potential further major savings in energy                          federal mass transit funding and has withheld money that Congress
             conservation will not be realized.                                                     directed to be Invested In mass transit construction, despite the

                   d.   Incentive Proarams for BuAldInQ Retrofit                                    consequences on oil Imports.

                   Some 3.5 million barrels of oil equivalent per day are used

             In the form of oil or gas for heating homes.    Incentive-based                             To comply with CEQ's regulations implementing NEPA, the

             retrofit Insulation programs have the potential to save more than                      Department must perform a comprehensive evaluation of these and
             1.5 million.barrels per day at a cost of less than that of 011.5                       other alternative mechanisms of meeting national energy needs and

             Pilot programs sponsored by utilities have shown that almost 905%                      the effects of such alternatives on oil Imports and the envlron-

             of the potential savings can be achieved with a three year

                                                                                                    6.  Eric Hirst and R. Goeltz, "Potential Versus Practice instal-
                                                                                                    lation of Retrofit Measures in the Hood River Conservation
                                                                                                    Project," Oak Ridge National Laboratory, ORNL/CON-189 1985, at
                                                                                                    26-27.
             4. PY 87 Energy Conservation Multl-Year Plan. July 1985, Office
             of Conservation, U.S. DOE.                                                             7.  David Goldstein, Senior Scientist, Natural Resources Defense
                                                                                                    Council, 1985. Testimony for House Appropriations Committee,
             5.  SERI/Solar Conservation Study, A New Prosperit , Birck House                       Subcommittee on Transportation, on Appropriations for the Urban
             Publishing, Andover, Massachusetts at 13.                                              Mass Transit Administration, 2 May 1985.

                                                 12                                                                                             13

             ment.   Included In such a discussion should be a "least-cost"                                 leasing of the coastal plain, the draft report fails to analyze

             analysis of different energy sources.                                                          the impacts of developing the gas resources of the coastal plain.

                                                                                                            The Department assumes that crude oil Is the only potentially

                   Least-cost analyses are essential to economically rational or                            economic hydrocarbon which would attract      leasing interest if the
             defensible decisions concerning the development of energy                                      1002 area were opened to leasing.      D.R. at 75.    Later in thedraft

             resources.   Congress recognized the value of least cost planning                              Report, however, the Department notes that "it is expected that

             as early as 1980, when the Pacific Northwest Electric Power                                    gas production from this area would also be economic within two to
             Planning and Conservation Act authorized the creation of a new                                 three decades."    Id. at 143. The Department's failure to evaluate

             agency to plan for electricity use in the Northwest and charged it                             the Impacts of gas recovery In the Refuge not      only violates the

                                                             'as:-.-'   The Callfor-
             with acquiring electricity In a least cost            n::.                                     CEQ regulations, but also section 1002(h)(3) of ANILCA, which
             nia Energy Commission has operated under at least cost principles                              require a the Department to evaluate the adverse effects of
             for a decade under leadership from both political-parties and now                              exploration, development and production of oil and gas within the

             claims that those principles have saved that state's ratepa7ers                                coastal plain.
             billions of dollars. Before oil development In the Arctic                                             This is Important because the impacts of gas development
             National Wildlife Refuge can be justified on an economic basis,                                would not be limited simply to the construction of a gas pipeline
             the Department must develop.a least cost energy plan and see where                             for transportation of gas, as the draft Report Implies.         Rather,
             development of the Refuge fits In.      If It falls behind other                               the development of gas will Inevitably result In the Increased

             options notbeing pursued, then the development of the Arctic                                   demand for scarce   supplies of water and gravel, new construction
             National Wildlife Refuge should be postponed until other more                                  which will result in habitat lose, and other Impacts associated
             attractive resources are exploited.                                                            with further development of the Refuge.       in order to comply with
                    This analyses should be prepared and circulated for public                              both �1002(h)(3) of ANILCA and 51502.91a) of the CEQ regulations,
             comment prior to the Issuance of the final Report In accordance                                the Department must prepare and circulate a draft assessment of
             with 61502.9(a) of the CEQ regulations.                                                        the impacts of both   oil and gas development in the Arctic National

                                                                                                            Wildlife Refuge prior to Issuing Its final report to Congress.

             3.     Failure to Evaluate the    Impacts of Gas DeveloRMent

                    The CEQ regulations require that an Agency evaluate impacts

             of a proposed action. While the Department is proposing full

                                                  14                                                                                          15
              4.     Failure to Adeguately Evaluate Impacts n Water.                                       to be Incorporated more thoroughly into the analysis Of Impacts.
                     a.   Water Quantity Issues                                                            For example, what percentage of food sources will be Affected by
                     The list of preparers of the draft Report/LEIS does not                               contamination from reserve pits? What percentage of the habitat
              Include anyone with expertise in water. Yet the report describes                             area will be contaminated with pit fluid dlscharges@
              very significant potential Impacts on water. The result Is a                                      In order to perform such an analysis, the Department muist
              woefully Inadequate analysis of water Issues.                                                estimate how many tons of muds, cuttings and other wastes will be
                     For example, the Report the Department acknowledges that "as                          generated by oil and gas operations in the Refuge and disposed of
              much as 15 million gallons of water may be needed to drill one                               In reserve pits. Calculations must them be made on the percentage
              exploratory well. Taking this amount of water from the water-                                of pits that leak and the amount of water that will be discharged
              deficient 1002 area could have a major adverse effect.,, D.R. at                             into the tundra by pit de-waterlng operations.      This will  allow
              99. However, there Is no discussion of what this effect may be In                            the Department to estimate the amount of habitat that will be
              the chapter on environmental consequences. This is a major                                   contaminated by metals, hydrocarbons and other pollutants associ-
              omission that must be corrected. In addition. In order to                                    ated with pit fluid discharges. Since the Department routinely
              evaluate the overall demand for water, the Department should                                 estimates the quantity of muds and cuttings generated as a result
              estimate the number of exploration and development wells that will                           of OCS lease sales (see, e.g., Sale 97 DEIS at Table II-A-1).
              be drilled In the Refuge. Since the Department routinely does                                This should not be excessively difficult.
              this for OCS sales (see, e.g.. Sale 97 DEIS at Table ir-A-1), this                                 The Department must prepare and circulate a revised and
              should not be difficult.                                                                     expanded analysis of the Impacts of the proposal (and alterna-
                     b.   Water Quality issues                                                             tIves) on water quality and quantity on the North Slope prior to
                     With respect to water quality, the Department fails to                                Issuing the final report to Congress in accordance with 40 C.      F.R.

              analyze the impacts of all and contaminant spills, reserve pit                               �1502.9.

              fluid discharges and leaking reserve pits on the overall water
              quality of the region, even though the Department acknowledges                               5.    Fal                             Ity Impacts
              that reserve pit fluid discharges Into tundra ponds is resulting                                   The list of preparers of the draft Report includes no air
              in a deterioration In water quality, and that the quality and                                quality specialists, and the draft Report Itself contains no
              quantity of organisms used as food by North Slope bird species may                           adequate discussion of the impacts of oil and gas development on
              be decreasing as a result.     D.R. at 100. This information needs                           the air quality of the North Slope.     This Is of considerable

                                                 16                                                                                           17

             concern due.to the fact that large amounts of air pollutants are                             addition, Sectlon.1506.2(d) requires that EISs discuss any

             emitted by oil and gas operations elsewhere in the North Slope.                              Inconsistency  of a proposed action with any approved state or

             For example, the approximately 20 state permits Issued and pending                           local plan and laws whether or not federally sanctioned.       Where an

             for operations on the North Slope allow a total of between 80,006                            Inconsistency exists, the EIS must describe the extent to which
             and 100.000 tons of oxides of nitrogen (No.) to be emitted into                              the Agency, In this case the Department, would reconcile Its
             the air annually@ To put this number In perspective, the New York                            proposed action with the plan or law.
             State Department of Environmental Protection reports that NOX                                      Despite this requirement, we could find no comprehensive
             emissions In 1980 (the last year for which complete data is                                  discussion of possible conflicts between leasing of the coastal

             available) for the five boroughs of New York totaled 196,775 tons.                           plain and the policies and standards,of the Alaskan Coastal
             S02, total suspended particulates. carbon monoxide and volatile                              Management Program (ACMP) (6 AAC 80).     This Is a serious omission
             organic compounds are other air pollutants of concern that are                               given that leasing and subsequent exploration and development will

             emitted In substantial amounts by oil and gas operations.         (Sale                      have significant direct Impacts on the state's coastal zone.
       2     97 DEIS Table IV-B-5).    DOI has concluded the  t a major potential                               Federal activities which result In an Impact on a state's
       -4    consequence of Increased   air emissions Is acidification of the                             coastal zone must be consistent with that state's federally

             local tundra. Id. at IV-B-126. Concerns have been raised with                                approved coastal zone management program. While federal land Is

             respect to the effects of S02 emissions an caribou forage.                                   excluded from the coastal zone, the coastal plain of the Refuge
                    The Department must prepare and circulate a draft assessment                          directly buts non-federa      an         s       ect-to-the-goa-l-s-and
             of the Impacts of leasing the coastal plain on the air quell      ty of          A           policies of the Alaska Coastal Management Program as approved by
             the Alaskan and Canadian arctic, prior to Issuing the final report                           the U.S. Department of Commerce.     Oil and 995activities conducted
             to Congress in accordance with 51502.9 of the CEQ regulations.                             -on-tK-e -coa-s'tal plain will affect these lands, and such activities
                                                                                                        -7;7u9Wtther`efore @econs@istent-wlth the standards of        ACMP. ACMP

             6.     Failure to Consider Conflicts Between the Proposed Action                             standards that must be considered in the EIS in lu        t

                    and the Alaska Coastal Management Progr4m
                    Section 1502.16(c) of the CEQ regulations     requires the                                  a.    qqastaL_AeveLq q@er! (6 AAC.040).    This standard governs
             Agency to discuss "possAble conflicts between the proposed action                            the location of development, placement of structures, discharge
             and the objectives of federal, regional, state and local .... land                           of dredged material, and other activities affecting the coastal

             use plans. policies and controls for the area concerned." In
                                                                                            @
                                                                                                            x
                                                                                                            c
                                                                                                          d   u
                                                                                                            'roc

                                                                                                          p   c
                                                                                                            ol

                                                                                                          t heJ

                                                                                                          _u_ t

                                                                                                            tand                                              c          fol

                                                                                                            .g.

               zone. The Department must discuss     means of conformance with this                                d.    Transportation and Utilities (6 AAC �80.080) This
               standard.                                                                                     standard requires that routes for transportation and utilities be
                     b.    Geophysical Hazard Areas (6 AAC 80.050). Onshore                                  sited Inland from shorelines. among other things. conformance
               dove lopment will cover extensive areas of permafrost. Portions of                            measures must be spelled out.
               the main pipeline and haul road from the Refuge to the TAP would                                    e.    Minina and Mineral   Processin (6 AAC �80.11C     @MP'
               cross onshore areas and streams Included within the coastal                                   standards require that mining    and mineral processing be compatible
               boundary. Development along the entire route could be subject to                              with other standards, adjacent uses and activities, state and
               problems with permafrost. These hazards will constrain the                                    national needs and District Programs. 6 AAC 580.110(a]. Extrac-
               pipeline route. The Department needs to Identify means of                                     t1on of sand and gravel Is a major concern an the North Slope.
               conformance with this standard.                                                               The Department estimates that several million cubic yards are
                     C.    Energy Facilities (6   AAC 80.070). This standard                                 required to develop an oil field. D.R. at 100. The sources of
               Includes 16 policies for siting    energy related facilities, some of                         this gravel, the Impacts of mining It, and means of conforming
               which would apply to development of the Arctic National Wildlife                              with the ACMP policies governing mining must be discussed.
               Refuge. For example, ACMP policies require that facilities be                                       f.    Subsistence (6 AAC �80.120)     State standards guarantee
               sited to 11 minimize adverse environmental and social effects                                 opportunity for subsistence use of coastal areas and resources.
               while satisfying Industrial requirements, and 2) be compatible                                The draft Reportnotes that subsistence hunting will be precluded
               with existing and subsequent uses 16 AAC 80.07011),121). Other                                on up to half of the coastal plain. D.R. at 132. Given this
               ACMP policies require that facilities be consolidated and sited        In                     impact, the Report must analyze means of conforming with ACMP
               areas of least biological productivity, diversity and vulnerabl-                              standards on subsistence.
               11ty.  (6 AAC 580.070131,[13)) Facilities must be designed to                                       9-   Habitats (6 AAC 560.130) The ACMP standard for all
               permit free passage and movement of fish and wildlife with du      .e                         habitats In the coastal zone require that habitats "be managed so
               consideration for historic migratory patterns.                                                as to maintain or enhance   the biological, physical and chemical
               (6 AAC SSO.010(121). This Is particularly critical given the                                  characteristics of the habitat which contribute to its capacity to
               concerns raised in the draft Report conce    rning the reluctance of                          support living resources." 6 AAC Sao.130[b).        Habitats of
               caribou to cross barriers such as roads and pipelines. D.R. at                                particular relevance Include rivers, lakes, streams and wetlands.

               108-109.                                                                                      Most of the coastal plain is considered wetlands; onshore develop-

                                                                                                             ment would therefore need to be designed and constructed to avoid

                                                 20                                                                                       21
                adverse effects an natural drainage patterns, the destruction of                        whales, (D.R. at 136), but there Is no discussion of specific
                IImportant habitat, and the discharge of toxic substances.   6 AAC                      impacts on endangered bowhead and greywhales, which inhabit t    .he
                580.130[c)[3).  In addition, rivers, lakes and streams are managed                      Beaufort Sea adjacent,to the  coastal plain. D.R. at 38.     In
                to protect natural vegetation, water quality, important fish and                        addition, no consideration has been given to two species of plants
                wildlife habitat and natural water flow under the ACMP.                                 currently.designated as candidates for listing as threatened or
                6 AAC S80.1301c](71. means of conforming to the ACMP habitat                            endangered that occur within thelcoastal   plain. Salix ovalifolia
                                                                                                        variety alacialls, a low growing willow, Is found in sandy solls
                policies for all of these habitats must be examined.
                     h.   Air, Land and Water Quality (6 AAC �80.140) The air,                          around the region. The other species,-Thl"pl arcticu , Is.a
                land and water quality standards .of the ACMP incorporate by                            mustard that occurs In northeastern Alaska on well drained.91tes
                reference all the statutes pertaining to and regulat,ions.and                           such is dry ridges and low river terraces. Both plants could be
                procedures of the Alaska Department of Environmental Conservation.                      affected by,.activitles such as coastal vehicular traffic, onshore
                                                                                                        development or sand and gravel mining operations. The U.S. Fish
                Conformance measures for each of these statutes and regulations.
                must be discussed in the Reporta                                                        and Wildlife Service has stated in connection with development of
                     ,The Department must prepare a draft assessment that dis-                          the Beaufort Sea that "agencies wherever possible will be Inter-
                cusses possible conflicts between the proposed action (and                              ested In protecting such (threatened) species, thereby reducing
                alternatives) on the objectives, policies and controls of the                           the probability that they will require listing. We encourage you
                Alaska Coastal Management Program prior to Issuing the final                            to consider them In  your environmental planning." Sale 97 DEIS
                report to Congress In accordance with 40 C.F.R. �1502.9. This Is                        at J-1.
                particularly important In light of the fact that the Department                                The Department must prepare and circulate a draft assessment
                considers the Report the leasing EIS. D.R. at 13.                                       of the Impacts of the proposal and alternatives or endangered
                                                                                                        species that Includes the omissions cited above prior to Issuing
                7.   Failure to Adequately Evaluate Impacts on Endancered and                           the final report to Congress.
                     Threatened Species
                                                                                                        8.     Failure to Adequately AnalVze Archeolodical Impacts
                     The evaluation of impacts on endangered and threatened
                                                                                                               Early.man occupied the Beaufort Sea area during the    past
                species contained In the Report is totally inadequate. For
                                                                                                        18,000 years. Known archeologIcal.s1tes exist on the North Slope
                example, the draft Report acknowledges that activity, noise,
                                                                                                        and others probably occur within the boundaries of AHWR. In
                altered habitats and changes in availability of food sources from
                                                                                                        preparation for Sales 97 and 87 In the Beaufort Seas, the

                dredging and other operations may adversely effect seals and

                                               22                                                                                        23
              Department Of Interior did an extensive assessment of the poten-                                    tence uses and resources resulting from such
                                                                                                                  actions.
              tial for archeological resources. Sale 97 DEIS at H-1-9.      In                               (b)  If the Secretary is required to prepare an environ-
                  rast, the archeological analysis contained in the draft Report                             mental impact statement pursuant to section 4332(2)(C) of
              cont                                                                                           Title 42, he shall provide the notice and hearing and
                                                                                                             include the findings required by subsection (a) of this
              is totally inadequate, consisting of two sentences. A revised                                  section as part of such environmental impact statement.
              draft evaluation of archeological impacts should be prepared and                               While acknowledging that development of the 1002 area "will
              circulated prior to Issuing the final report to Congress.                                result In a major adverse effect on subsistence uses within the

                                                                                                       1002 area" (D.R. at 129), the Department claims that it need not
              C.    Failure to comply With the  Alaska National Interest Lands                         perform an 810 analysis until the actual lease sale:
                    Conservation Act (ANILCA)
                                                                                                             Overall a major effect (considered a significant
                    1. Section 810                                                                           restriction of subsistence uses under section 810 of
                                                                                                             ANILCA) could occur If alternative A was Implemented.
                    Section 810 of ANILCA requires that:                                                     If the Congress enacts the legislation to authorize
                    (a) In determining whether to withdraw, reserve, lease, or                               the Department of the Interior to lease the 1002 area,
                    otherwise permit the use, occupancy, or disposition of                                   the Secretary of the Interior must, pri  'or to the
                                             rovIslons of law authorizing such                               actual lease sale, determine the effects on subsis-
                    public lands under any p                                                                 tence of such disposition in compliance with section
                    actions, the head of the Federal agency having primary                                   810 of ANILCA unless the Congress were to exempt the
                    jurisdiction over such lands or his designee shall evaluate                              Secretary from that requirement.    Id.
                    the effect of such use, occupancy, or disposition on
                    subsistence uses and needs, the availability of other lands                              This directly contravenes the explicit language of section
                    for the purposes sought to be achieved, and other alterna-
                    tives which would reduce or eliminate the use, occupancy, or                       810(b), which states that If the Secretary Is required to prepare
                    disposition of public lands needed for subsistence purposes.
                    No such withdrawal, reservation, lease, permit or other use,                       an environmental Impact statement, he shall include the findings
                    occupancy or disposition of such lands which would signifi-
                    cantly restrict subsistence uses shall be effected until the                       regarding subsistence use required by subsection (a) In the
                    head  of such Federal agency --
                          (1) gives notice to the appropriate State agency                             environmental statement. If the draft Report to Congress/LEIS is
                          and the appropriate local committees and regional                            to serve as a leasing EIS (D.R. at 13). (something which we
                          councils established pursuant to section 3115 of
                          this title;                                                                  believe is not appropriate), the Secretary must Include the
                          (2) gives  notice of, and holds, a hearing In the                            Section 810 analysis in the LEIS
                          vicinity of the area involved; and
                          (3) determines that (A) such a significant                                        The findings required by �810 must therefore be made In a
                          restriction of subsistence uses is necessary,                                supplemental environmental Impact statement that Is prepared and
                          consistent with sound management principles for
                          the utilization of the public lands, (B) the                                 circulated for public comment prior to the Issuance of a final
                          proposed activity will Involve the minimal amount
                          of public lands necessary to accomplish the                                  Report/LEIS. The discussion of alternatives to leasing the Refuge
                          purposes of such use, occupancy, or other
                          disposition, and (C) reasonable steps will be
                          taken to minimize adverse impacts upon subsis-

                                                 24                                                                                        25

               required by �810(a) should Include an evaluation of energy                               nation's dependence on foreign oil and enhance national security.

               alternatives described earlier in these comments.                                        D.R. at 162-165.   However, each of these claims is based on

                                                                                                        flawed. misleading or Insufficient evidence. In addition, nowhere

                     2.   Section 1005                                                                  in the Report is it acknowledged that there are other, far less

                     ANrLCA Instructed   the Department to "consult with the                            environmentally damaging Ways of securing far more energy than Is

               appropriate agencies of   the government of Canada in evaluating                         thought to underlie the Arctic Refuge, such as these discussed in

               ... impacts particularly  with respect to the Porcupine caribou                          Section 11.8.2. above.

               herd." This consultation is extremely Important given that many

               of the species that stand to be affected by oil development In the                       A.    The Department's Estimates of the Amount of Oil and Gas In
                                                                                                              !he Arctft Refuge are Overstated
               Refuge migrate freely between the Refuge and the bordering
                                                                                                              The Department's estimate of 3.2 billion barrels of oil In
               Canadian National Park., According to testimony given by the Yukon
                                                                                                        the Arctic Refuge is a "conditional" mean estimate. D.R. at 72. A
               Government on January 9, 1987,8 the Department has so far failed
                                                                                                        conditional mean  estimate Is "the average amount you would expect
               to fulfill its obligations to consult with the Canadian govern-
                                                                                                            flnd If at le_st one of be prospects In an area contained
               ment. NRDC shares the concern of the Yuk                t and we
                                                                                                        economically recoverable   accumulations of,hydrocarbons and If all
               strongly recommend that the Department begin consultations
                                                                                                        the prospects modelled were drilled."g Conditional resource
               Immediately.
                                                                                                        est1mates.assume that hydrocarbons will be present in some of the

                                                                                                        prospects. They do not take Into account the possibility that the
               111. The National Need for Oil and Gas 19 Inadequately     Analyze
                                                                                                        area may not be hydrocarbon prone; this consideration Is taken
                     The Department claims that full leasing of the coasts   I pilain
                                                                                                        into account In determining the risked economically recoverable
               could help achieve national security and economic benefits.     it                                                      10
                                                                                                        resources In a planning area.      A risked estimate Is one where
               claims that development of 3.2 billion barrels of oil could yield
                                                                                                        the conditional mean is multiplied by the marginal probability of
               Net National Economic,Bonefits of $79.4 billion, based on an oil
                                                                                                        finding hydrocarbons.     In ebtabllshlng the size, timing and
               price of $33 per barrel. D.R..at 1. In addition, the draft
                                                                                                        location of  leasing for the federal Outer Continental Shelf oil
               Report asserts that leasing the coastal plain would reduce t!   te

                                                                                                        9.  U.S. Department of the Interior, February 1986 5-Year      Outer
                                                                                                        Continental Shelf Oil and Gas Leasing Program for January      1987-
                    W.I. Klassen, Deputy Minister. Department of Renewable                              December 1991, Detailed Decision Documents at 29.
               Resources, Government of the Yukon Territory. Statement In
               Response to the Draft.Arctic Natural Wildlife Refuge Coastal Plain                       10. Id.
               Resource Assessment at 6.

                                               26                                                                                        27
             and Gas Leasing Program. the Department uses risked eatimates.11                         then the entire amount of the prospect's economically recoverable

             In contrast, the oil estimates for the Refuge are conditional                            resources are deemed to be unleasable at the time of sale for

             estimates. Inexplicably, the Department failed to risk the oil                           given economic assumptions. Thus, the estimate of leasable

             estimates In the way that It customarily does for OCS program.                           resources In a planning area is the sum of economically recover-

             Since the marginal probability of finding hydrocarbons In the                            able resources associated with prospects calculated by the

             Arctic is only 19%, the total amount of risked mean economically                         Department to be worth acquiring, i.e., they have positive private

             recoverable oil underlying the Refuge Is 614 million barrels, or                         values.

             one-fifth the amount of oil the Department claims is in the Refuge                              It appears that the Department not only failed to risk its

             in the draft report. and there Is 81% chance that no oil at all                          estimates of oil underlying the Refuge, but It also did not

             will be found. The failure to make this clear In the Executive                           estimate the leasable resources as It typically does for the OCS

             Summary and In the body of the report Is unjustflable and must be.                       program. Why are oil and gas estimates of the coastal      plain for

             corrected.                                                                               the Arctic National Wildlife Refuge assessed differently than oil

                   Furthermore, the estimates of both conditional and risked                          and gas estimates of the federal outer Continental Shelf?

             economically recoverable resources do not take Into account costs                        B.     The Department's Estimates of the Economic Benefits of Oil
                                                                                                             Development are Overstated
             incurred In searching for oil and gas, primarily exploration
                                                                                                             It Is extremely difficult to tell how the Department came up
             expenses. In order to factor in such expenses, which are
                                                                                                      with Its net economic value estimates, In that no information Is
             important to a company's decision on whether or not to explore and                       given on how the Department calculated the alleged revenues that
             develop a lease, the Department has developed estimates of
                                                                                                      will accrue from full leasing of the coastal plain. In the final
             "leasable resources" In the proposed 5-Year OCS Leasing Program.
                                                                                                      Report, the Department's methodology must be completely explained.
             In determining the amount of leasable resources in an area, an
                                                                                                             It appears from what little information Is presented that
             assessment Is conducted of each prospect to determine its risked
                                                                                                      the Department's methodology for assessing new economic benefits
             economic value at the time of sale to both the lessee and the
                                                                                                      Is Inconsistent with that used In the federal outer Continental
             nation as a whole. if the private value (after-tax net present
                                                                                                      Shelf Oil and Gas Leasing Program. For example, estimates of net
             value), Is found to*be greater than zero, then the economically
                                                                                                      economic value In this OCS program are made for prospects contain-
             recoverable resources associated with the prospect are considered
                                                                                                      ing leasabl resources, which are risked estimates of oil that
             leasable. If the private value of the prospect is zero or less,
                                                                                                      will bring positive net benefits to the lessees after deducting

             11.  rd., Decision and Summary, at Table 2.                                              royalties, rentals and taxes.    Had the Department based Its net

                                                  28

               economic benefit calculations on risked oil estimates. the                                 IV.    Impacts of Oil Development Elsewhere In the Alaskan Arctic

               economic value of full leasing would   be 19% of that cited in the                               The draft Report notes very significant environmental

               Draft report ($15.1 billion vs $79.4 billion).     If the net                              problems that have resulted from oil and gas development elsewhere

               .economic benefit calculations Were based on leasable resources,                           in the Alaskan Arctic.    These problems indicate that, contrary to

               the economic benefits would be even lower.       In addition, the                          the Department's assertions, the oil Industry in fact cannot

               Department bases its estimate of co  ndltlonal economically recover-                       operate In the arctic without severe environmental consequences.
               able oil re sources on an oil price of $33 a barrel In 1984 dollars                              For example, the Fish and Wildlife Service (FWS) has

               in the year 2000. In order for this value to be reached in the                             undertaken investigations into the effects of reserve pit fluid

               ,year 2000, the oil price would have to grow at an average rate of                         discharges on water quality and the freshwater macroinvertebrate

               about 4% per year starting from the currentoll price of about $18                          community of tundra ponds. The aquatic Invertebrates studied are

               a barrel.   In contrast, MMS uses a real oil price Increase of 1%                          known to be sensitive indicator organisms for a wide variety of

               per year in calculating the net economic value of leasing OCS.                             environmental pollutants and an Important food source to the
               areas.12 Thum- thp At arnwth rate used in the d    raft Report is                          approximately 150 species of water fowl, sea blrds, shorebirds,
               more than four times the growth rate assumed by MMS. is a result,                          raptors, and passerines using the North Slope for nesting,

               the draft Report projects a much higher net economic benefit than                          rearing, molting and feeding.     D.R. at 100.   Preliminary results

               would have been the case If the MMS oil price increase rates were                          of those studies show increases In heavy metals, including

               used. We recommend that the Department make Its projections on                             aluminum. barium. chromium, zinc and arsenic, hydrocarbons, pH,

               oil prices consistent with those used by the Minerals Manag    ement                       salinity, alkalinity, turbidity and sediment loads for ponds

               Service.                                                                                   adjacent to reserve pits on the North Slope. Moreover there were

                     NRDC has reviewed the economic analysis In the draft 5-Year                          concomitant decreases In oxygen levels, total taxa, taxa diversity

               Program and has provided the Department with major comments on it.                         and Invertebrate-abundance In tundra ponds associated with reserve

               Many of these comments are relevant to the economic analysis in                            pits.   The results of these studies indicate that the disposal of

               the Arctic National Wildlife Refuge draft Report.      For your                            drilling muds, cuttlngs and other wastes In reserve pits on the

               convenience these comments are attached as Attachment 1.                                   North Slope Is resulting In substantial deterioration and water

                                                                                                          quality as a result of leaching, breaching or overtopping of the

                                                                                                          pits. Along with deteriorations In water quality, the quality and
               12. 5-Year OCS Leasing Program January 1987-December 1991
               Secretarial Issue Document, October 1985 at Table 2, Table     5.
               Table 6.

                                               30                                                                                         31

             quantity of organisms used as food by North Slope bird species may                        In the arctic environment are quite severe.     Direct contact with
             be decreasing. Id.                                                                        oil or diesel often results In immediate mortality to the above-
                   Another impact of existing oil operations on the North Slope                        ground vegetation.   Injury to the root system may not be immedi-
             is air pollution. Oxides of nitrogen (NO,), sulfur dioxide (S02),                         ately obvious at,d can cause a slow daterioratio  n of plants and a
             total suspended and particulate matter, and carbon monoxiSe (CO)                          high degree of winter kill In future years. Id. at 103.       The
             are the principle air pollutants generated by oil and gas activi-                         draft Report cites a study that found that the site of a diesel
             ties In Prudhoe Say.   State permits Issued or pending for gas                            spill In Northern Alaska showed little recovery after 30 years.

             fired turbines on the North Slope allow close to 100,000 tons of                          -1d. The ability of the industry to avoid these spills appears to
             NO, to be emItted.annually. In contrast, the 5 boroughs of New                            be minimal: "[a]ccldental spills of crude oil and refined
             York City emit approximately 197,000 tons of NO, per year.                                petroleum products an Inevitable consequence of oil field develop-

                   Permit limitations on carbon monoxide emissions on the North                        ment." Id. at 103.

             Slope have apparently been exceeded by older gas fired turbines.                                To our knowledge, no one outside the oil industry has ever
             In addition, EPA Is presently Investigating whether or not permit                         done a comprehensive evaluation of the environmental Impacts that
             exceedences for NOX have occurred as a result of "downwash" In the                        oil and gas development has had an the Nort   h Sl.ope of Alaska. In
             vicinity of stacks.   Questions have been raised about the Impacts                        addition, there has been very little monitoring of environmental
             of air pollutants, particularly SO., on lichen and plant species                          parameters an the North Slope. particularly In the area of
             which serve as caribou forage. @                                                          contamination from reserve pits. Given that knowledge about the
                   Other major air pollution problems Include gas flaring,                             environmental Impacts of oil and gas development on the North
             which generates smoke trails that have been tracked for 100 miles,                        Slope Is so limited, the conclusion that the oil industry Is
             Incineration of oily and hazardous waste, and visibility Impair-                          capable of operating In North Alaska without causing extensive and
             ment caused by smog. The draft Report deals volth none of these                           long term damage Is speculative and Is Insupportable. The limited
             Issues.                                                                                   evidence collected by state and federal officials Indicates that
                   Oil spills are another problem. Since 1972. some 23,000                             air pollution, water pollution and habitat degradation are
             spills of crude oil, gasoline and diesel have been reported to     the                    widespread. It is therefore Irresponsible for the Department to
             Alaska Department of Environmental Conservation as a result of                            base its decision to recommend full leasing of the coastal plain
             operations on the North Slope. 521 spills were reported in 1985                           on the ability of the Industry to limit environmental damage.

             totalling 82,216 gallons. D.R. at 104. The Impacts of oil spills

    			3A

    V. Conslusion
    	The Arctic Refuge is the only conservation system unit that
    protects, in an undisturbed condition, a complete spectrum of the
    various arctic ecosystem in North America. D.R. at 45. The
    Administration has a large number of options to reduce oil imports
    and enhance national energy security other than leasing the Arctic
    Refuge to the oil industry. Very few of these options have been
    persued by the Administration. In fact, as noted above, the
    Administartion policies ferquently have undermined national energy
    security. If the Administration feels comforatable forgoing oil
    development in the Arctic National Wildlife Refuge.
    	Given the nationally significant reoverable oil and gas
    the Department projects to underlie the Refuge, the fact that
    alternative sources of energy are available, and that industrial
    development is clearly incompatible with the purposes of the
    Refuge, we believe the Refuge should be designated as wilderness
    in its entirety.
    	Thank you for considering these comments.

    Natuarl Resources
    Defense Council

    122 east 42nd Street
    New York New York 10168
    212-949-0049

    Comments
    of the
    Natural Resources Defense Council,
    Sierra Club,
    Environmental Policy Institute,
    Greenpeac, U.S.A.,
    Trustees for Alaska,
    and
    Oregon Natural Resources Council
    on the
    Proposed 5-year
    outer continental shelf
    OIL AND GAS LEASING PROGRAM
    for January 1987- December 1991
    and
    DRAFT ENVIRONMENTAL IMPACT STATEMENT

    Prepared by:
    Sarah Chasis
    Lisa Speer
    Dr. David Goldstein
    Dr. Michael Kavanugh
    James Love

    May 8, 1986

    	ATTACHMENT II
    COMMENTS ON DOI 5-YEAR LEASING PLAN

    	MAY 8, 1986

    	1. INTRODUCTION

    	The economic analysis provided  in the Department of
    interior's (DOI's) 5-year outer continental shelf oil and gas
    Lasing Program for January 1987-December 1991, dated February
    1986, generally uses the same conceptual framework as the 1985
    Draft 5-year plan in justifying a rapid disposal of federal OCS
    propertis. One noteworthy improvement in the new analysis is
    the extensive discussion of the appropriate discount rate for
    comparing present and future economic benefits form OCS
    development. The most glaring deficiency of the 5-Year plan is
    the use of oil price scenarios that are not appropriate in light
    of recent changes in world oil prices.
    	We have commented extensively on the previous DOI Draft 5-
    year plan. These comments will address new issues raised in the

     	James p. Love . I woudl liek to acknowledge the
    contributions of professor Joseph Stiglitz on an earlier draft of
    these comments.

    	Joseph stiglitz, "Economic Issues in Draft flow year OCS
    Leasing Plan," included as Attachment 1 in "Comments of the
    policy Institute, Conservation Law Foundation of New England, and
    Friends of the Earth, on DOI's Draft proposed OCS oil and Gas
    Leasing Program," May 20, 1986. James Love and Joseph Stiglitz,
    "comments on DOI's Draft 5-Year leasing plan: Revised July 1985
    Appendix P."September 12, 1985 James Love, "shortcomings of
    the U.S. Department of Interior Draft 5-Year OCS Leasing Plan"
    reprinted as "Prepared Statement of James P. Love." U.S. House of
    Representatives, committee on Horchant Marine and Fisheries,
    Subcommittee on OCS and Panoma Canal, Hearings on the Five-year

    				2

    current 5-year plan and restate our ____ ____ objections to DOI'S
    OCS leasing program. In particular, we beleive the current DOI
    plan suffers from the following ___________:

    1. 001 is using the wrong discount rate to evaluate the
    costs to the federal treasures of ________ leasing.

    2. The recent plunge in world oil prices has rendevoed DOI's
    quantitative cost benefit analysis obsolete.

    3. The changed outlook on oil prices requires, according to
    DOI'S own analytical framework a radical modification of
    the OCS Leasing schedule.

    4. DOI should change the 5 -year plan to offer fewer tracts
    for sale. Leasing of high cost acreade should be deferred.

    		II THE RELEVANT DISCOUNT RATES

    	one of the central problems for DOI cncerns the comparison
    of social and private benefits and costs over time. The acthod
    used to make that comparison in the 5-year Plan is discounting
    for time. Public and private groups are held to have certain
    rates at which they "discount" future benefits and costs. Those
    rates are used to determine the "present value' of different
    leasing options.

    	There are three important discount rates that DOI must
    consider in the 5-year plan. Those include the private discount
    rate used by firms that bid on OCS resources. The disocunt rate
    which reflects the federal governmetn's cost of borrowing money.

    Draft proposed Program for Oil and Gas leasing on OCS. and the
    State federal Consultation Process. In 99-20. Aaugust 5. 1986. p.
    280.

    			3

    and the "social discount rate" that DOI uses to determine how
    society as a group compares benefits and costs over time.
    	The privates discount rate is used to determine how much
    money private firms will pay today for the right to develop OCS
    resources over the term of a lease. The private discount rate is
    also used to determine the incentives that private firms will
    have to time the development of OCS resources. Since prices to
    OCS resources, and the costs of developing those resources are
    expected to change over time.
    	The federal governement's cost of borrowing money should be
    used to compare the present value of lease payments including
    bonus paymonts) that are expected to be collected, according to
    different leasing schedules. The lease schedule effects the
    present value of lease payments in two ways. First, bonus
    payments are made at the time of the auction, which is entirely a
    function fo the lease schedule. Bonus payments are in turn a
    function of the discounted profits that the firm expects to earn.
    Second, the timing of the lease auction effects the timing of the
    development of OCS resources, and henge the timing and size of
    royalty and other lease payments.
    	The social rate of discount is used to determine how society
    as a whole values the future economic benefits and costs. The
    social discount rate is not so much an interest rate that is
    observed in the market, but rather a theoretical construct that
    coflects the opportunity costs faced by consumers and firms, and
    profound philosophical and ethical judgements. The social rates of
    discount should be used to determine the present value of OCS
    development to society as a whole, given different leasing
    schedules. DOI proposes to use a social rate of discount to
    determine when OCS resources should be leased.
    	In the 5-year plan DOI discusses some of the different
    methods of estimating the social discount rate, but does not
    identify the specific methodology that is appropriate for OCS
    development. Instead, DOI simply states that it will use a range
    of social discount rates between 6 and 8 percent, adjusted for
    inflation. In fact, DOI uses the 8 percent discount rate as its
    baseline assumption, with only limited sensitivity analysis of
    the 6 percent discount rate. The 8 percent rate discount rate
    means that DOI places very little value on future OCS benefits.
    Economic benefits valued at one 1986 dollar adjusted for
    inflations that are receivedd 25 years in the future are valued at
    less than 15 cents by DOI todya. The same unit of benefits
    received 50 years in the future have a present value of 2.1 cents
    according to DOI.
    	DOI asserts that the private after-tax rate of discount
    falls within the 6 to 8 percent range used for the social
    disocunt rate. DOI also asserts that the real rate of interest
    on federal government bonds fails within this range. This would
    be a fortuitous coincidence for DOI. if it were true. because it
    would ____ much of the debate over the appropriate discount
    rate.
    	In fact. the real rate of interest in federal government

    				5

    bonds is considerably lower than 6 to 8 percent. Our own
    interviews with oil industry personal suggest that the real
    after-tax private rate of discount is considerably higher than
    the 6 to 8 percent range. We believe that economic theory and
    empirical evidence support the notion that the three discount
    rates are different. In particular, the private rate of discount
    is considerably higher than interest rate on federal goverernment
    bonds.

    	III THE RELEVANCE OF DIFFERENT DISCOUNT RATES

    	In designing a leasing program DOI must consider the impact
    of the plan on the timing of OCS development and the present
    value of expected federal government receipts from the sale of
    the resource.
    	DOI argues that the social discount rate should be used to
    determine the most efficient timing for development. By this,
    DOI _cans that development should occur on OCS properties as soon
    as the net social value (firm profits, plus taxes and royaltical
    is growing (the change in net value due to expected increases in
    price or decreases in development costs) at a rate that is less
    than the social rate of discount. This principle is referred to
    as the Hotolling Rule.
    	Maximizing the present value of government receipts from the
    sale of the resource is a --lated but conceptually distinct
    issue. An important component of federal lease receipts are the
    bonus payments that are paid at the time of the auction. The

    					6
    bonus payments have an economic effect that is similar to that
    which could occur if the federal government, we the landowner,
    borrows money from the oil industry against future expected
    profits from development. When the interest rate on government
    bonds is bionificantly lower than the discount rate used by the
    prisate firms that bid on OCS resoruces. the taxpayers suffer a
    loss when OCS resources are sold prematurely. In effect, the
    federal government pays the oil industry discount rate to borrow
    money against future profits.
    	The present value of federal government receipts are
    affected by timing of development and the timing of lease
    receipts. The lease schedule influences the testing of
    developments. and the timing of deveolpment influence the timing
    or less receipts. But lease terms are flexible enough that
    different development timing scenarios can be accommodated under
    different lease schedules. This is particularly true for high
    cost frontier areas where primary lease terms are 10 years, and
    are subject to extension upon filing development plans. It is
    also true of areas where unitization allows several lease _____
    to be grouped together to meet common diligence requirements,
    although actual development on some tracts may be delayed for
    years past the primary lease term. For example, on Aalaska's
    North Slope several leases that were issued in 1969 some 17
    years ago, are just now beginning production. A difference in
    the Industry discount rate and the government bond rate of 5
    percent, and a 10 year delay in development, would result in a

    			7

    loss in present value of bonus payments of nearly 40 percent. A
    fifteen year delay and an 8 percent difference in discount rates
    would result in a loss or nearly 70 percent in the present value
    of bonus payments.
    	In the example given above, the federal government should
    delay leasing of the property until it is ready to be developed.
    The best timing for development may be based on DOI's estimate of
    a social discount rate, while the timing of the lease sale would
    be based on the government's borrowing rate. There are, however,
    important distributive reasons for DOI to consider using the
    federal government bond rage to determine both the timing of
    development and the timing of the lease auction.
    	The use of the social discount rate to time development
    makes sense if DOI is concerned only with maximizing the net
    gains to society as a whole, regardless of the distribution of
    benefits. If , on the other hand, the benefits of OCS development
    accrue largely to the private firms that develop the resources
    and the federal government through collection of lease receipts
    and taxes, and DOI places a smaller weight on the welfare of the
    private firms than on the U.S. citizens who own the resources in
    their role as taxpayers and beneficiaries of public services. it
    should use the federal government's bond rate to determine both
    when OCS resources should be developed and when lease auctions.
    should be held. In the lattor case, DOI should only consider the
    benefits from lease payments and taxes, and development should
    occur when these benefits are growing at a slower rate than the

    					8
    government bond rate.
    	There are several reasons why DOI might place a smaller
    weight on the welfare of the private firms that develop OCE
    resources. First, it may beleive that the shareholders of the
    firms are better off than the citizens of the U.S. as a whole,
    and that a redistribution of income is desirable. Second, DOI
    might decide to place a smaller weight on the welfare of the
    private firms because their shareholders are not all U.S.
    citizens. Indeed, most oil producing countries rely hevily upon
    ______ _____ are owned by foreign shareholders. adn design leasing
    programs with one objective _____ - to capture economic rent
    for the government. While the United states  _____torical,
    dominated the oil industry world wide, the owenrship fo the lease
    oil companies is increasingly becoming international. and second
    large foreign firms control significant amounts of U.S. oil
    production. For example, half of the giant prudhou Bay oil
    reservoir is owned by Sohio, which in turn is controlled by
    British Pegroleum. Many other large U.S. firms are owned in part
    by foreign shareholders, including members of the OPEC cartal.

    	IV MEASUREMENT OF DISCOUNT RATES

    	We do not beleive DOI has accurately estimated various
    discount rates under discussion.
    	In the 1985 Draft 5-year Plan DOI assured that the real
    interest rate on long term government bonds was _ percent. In

    				9

    the new plan, DOI asserts that recent yeilds on government bonds
    are 6 to 8 percent in real terms. DOI arrived at the 8 percent
    number by taking a single year, 1983, and subtracting the current
    rate of inflation from the long term nominal interest on long
    term treasury bonds. By comparing the long term bond rate to the
    short term inflation rate DOI ignored the effects of anticipated
    inflatin. The interest rate and inflation from the single
    period were not typical of other periods. 3 In previous comments
    we calculated real ex post yields on teasury bonds from 1950 to
    1984 and anticipated yields on future bond offerings using CBO
    projectionis and estimated real interest rates of 2 to 4 percent.4
    The February 1986 CBO budget projections estimate onminal rates
    on short term treasury bonds falling to 5.4 percent by 1991, with
    real rates declining from the 1985 level of 3.4 percent to 1.1
    percent by 1991.5
    	Recent movements in interest rates provide further evidence
    than an 8 percent real rate is too high. The yield for three
    month Treasury bills was 6.04 percent on may 7 , 1986. The same

    	3 Using the DOI method, the real rate of interest on 10
    year constant maturity Treasury bills were 6.9 percent for 1982
    3.5 percent for 1981 minus 2.04 percent in 1980, minus 1.86
    percent in 1979 and .71 percent in 1978.
    	4 Love and stiglitz "comments on the Department of
    Interior's Draft 5-year leasing plan: Revised July 1985 Appendix
    p."

    5. The Economic and Budget Outlook: fiscal years 1987-1991.
    CBO, February 1986. P. ___

    			10
    day yield for 30 year Treasury bills was 7.51 percent. IF the
    long term inflation rate is expected to be 3.5 to 5 percent the
    Federal government's real borrowing cost would be in the
    neighborhood of 2.5 to 4 percent.
    	On an after tax basis, government interest rates are
    considerably lwoer. A 30 percent income tax rate would mean that
    an 6 percent nominal yield, accompanied by 4 percent inflation,
    would have a real pre-tax interest rate of 2 percent but an
    after-tax interest rate of only .2 percent. Likewise, an nominal
    bond yield of 7.5 percent and an inflation rate of 5 percent
    would result in a pre-tax real yield of 2.5 percent, but an
    after-tax reral interest rate of only .25 percent.
    	DOI has cited two studies that estimate a real after-tax
    industry discount rate of 7 percent. One of the studies is a
    surfvey of large oil and gas producers. The second study
    estimated rates of return for gulf of Mexico OCS leases form 1954
    to 1975." Thus, according to DOI. private firms bidding on OCS
    resources use a "hurtle rate" on new investment that is the same
    as the return that DOI says investors could obtain by purchasing
    Treasury bonds. While we are not prepared to critiquo in detail
    eigther study, it is worth noting that the _____ study covered.

    	4 H. boylo and G. Scheknd. 1983, "Investment Analysis:
    U.S. Oil and Gas producers Score High in University Study."
    Journal of Petrouleum Technology vol. 37. 10. 4.

    	H. Nead et. al., 1980 studies of competition and
    performance in OCS oil and gas sales, 1954-1975, Final Report,
    USDS contract no. 14-08-0001-iso73.

    			11

    period when real yields on government bonds were close to zero
    and sometimes negative. Moreover, when we interview oil industry
    sources they claim to use a private after-tax real discount rate
    of 10 to 14 percent.
    	The pre-tax industry discount rate is higher than the after-
    tax rate. It is more difficult to make the adjustment for oil
    development projects than for bonds, due to provisions in the
    federal income tax laws that provide for deductions of interest
    expense, rapid depreciationi, investment tax credits, expensing of
    intangible drilling expenses and dry hole drilling costs,
    deplution allowances, and other items. Industry income tax rates
    are not trivial, however, and average effective rates have
    climbed following the recent curtailment of the percentage
    deplation allowance.
    	When comparing the industry discount rate to the government
    bond rate, the appropriate comparison would be the pre-tax
    industry rate against the pre-tax rate, or the after-tax
    (net of corporate and personal income taxes) industry rate to the
    after-tax bond rate (net of personal income taxes).
    	We believe the industry discount rate is higher than the 7
    percent figure estimated by DOI. Our interviews with industry
    sources suggest that the industry rate is relatively greater for
    the higher risk projects that have greater uncertainly regarding
    geology and oil prices.
    	Both types of uncertainty are more significant in frontier
    areas where there has been little exploration and where projects
    				12

    require longer lead times. DOI itself considors the oil industry,
    to be averse to bearing such risks. DOI's recent analysis of
    minimum bid policy assumes that this risk aversion results in
    private firm's under asscessing the vaue of frontier acreage.
    Thus the difference between the government bond rate and the
    industry discount rate will be greater in those wales that are in
    frontier regions.
    	The social discount rate presents a unique act of
    measurement problems. DOI has provided a review of many of the
    important theoratical and ethical questions to be addressed in
    choosing a social discount rate."
    	In traditionial cost benefit analysis. economists have
    debated the relative mertis of using the after-tax return to
    savers. the pre-tax return on private investment, or some
    weighted average of the two. In recent years there hase been a
    growing recognition that the theorotical basis for one rate or
    another is very sensitive to the particular problem the discount
    rate is used to address. and to the constraints that are
    implicitly or explicitly assumed to limit the options of

    	Harten, Carol, and Macthall Pose, "Analysis of minimum
    bid policies."Branch of economic studies, offshore resources
    Evaluation Division. DOI. June 7, 1985

    	Our previous comments on the proposed changes in minimum
    bid policy unfairly cirticized the current 5-year plan's analyzis
    of the discount rate for failing to recognize the ethical
    questions at stake. Love, "comments on Proposed minimum bid
    requirements" While that ws true of the previous 5-year plan
    the current 5-year plan provides a much richer discussion of each
    issue.

    		13

    consumers, firms or policy makers.
    	DOI has discussed some of thes issues. For example, DOI
    asserts that federal policy makers cannot make rational decisions
    to finance federal government operations from OCS receipts.
    	The ethical question concerns the value we place on the
    welfare of future generations. OCS resources are exhaustible,
    and depletion today will proclude their development later. The
    new 5-year plan discusses arguements for increasing or lowering
    the discount rate due to perceived market failures that lead to
    systematic under or over valuation of the welfare of future
    genrations, but offers few suggestions except to say that
    disputes over such issues are best resolved through the political
    process.
    	After navigating its way through the thicket of ethical,

    	10  DOI asserts that federal policy makers are not able to
    distinquish between current income and the depliction of a capital
    asset such as OCS oil and gas properties, adn hence will change
    spending priorities based solely on when the money is received.
    If true, this would be an arguemtn to avoid early liquidation of
    OCS assets, or to use a lower social discount rate.

    	" Doi cites a paper by Joseph Stilglitz to support the view
    that intertemporal equity is served by providing future
    generations with fewer natural resources endowments than present
    generations, because future generations will have a larger
    capital stock and better technology. J.E. Stiglitz, "A
    Neoclammical Analysis of the Economics of Natuarl Resources. " In
    V. K. Smith, ed., Scarcity and Growth Reconsidered, Baltimore,
    Johns Hopkins Press. 1979. In recent years, however, the trend
    rate of growth in GNP has significantly decreased. Due largely
    to current federal governemnt fiscal policies, the U.S. savings
    rate is also much lower today than the historic norm. Thus.
    policy makers do not have such assurances of improved welfare of
    future genrations.
    				14

    theoretical and empirical problems, in estimateion, DOI finally
    seller on a range or real social discount rates between 6 to 9
    percent. Just now this range was chosen is unclear.

    	v THE SIGNIFICANCE OF CHANGED OIL PRICES

    	As noted above. DOI is relying upon the HOteline rule to
    justify the pace and scope of the OCS leasing plan. According to
    this theory. exhaustible resources are expected to appreciate in
    value as low costs stocks are depleted. Increases in the
    resource price will lead to greater profits. as long as prices
    are inclosing at a greater rate than costs. The problem for
    firms and resource planners is decide when no resources should
    be left in the ground to appreciate, and when stocks should be
    developed.
    	Hoseiling poved that in a competitive market, firms have
    the incentive to defer development until the net benefits from
    production ( price minus production costs) are appreciating at a
    slower rate than the rate of interest. Hotelling further around
    that so long as there are no other market distortions. the
    incentives facing the firm were socially officient.
    	As noted in the above discussion of discount votes, and in
    our previous comments, the markets for petroleum are not
    necessarily competitive, and substantist differences exist
    between this firm discount rate. THe social discount rate, and the
    interest rate on government bonds. In particular. the firm's

    			15

    discount rate is considerably higher than both the federal
    government bond rate and DOI's estimated social discount rate.
    LEases that require royalty payments and diligence requirements
    also change firm incentives in ways that are not reflected in a
    simple application of the hotelling rule.
    	While a simple application of the Hotelling rule is
    impractical in today's world, an examination of the fundamental
    concept is important for understanding how the recent plunge in
    wolrd oil prices has changed th economic analysis in the current
    5-year Plan. According to this rule, which is quoted and relied
    upon extensively throughout the 5-year Plan, society should
    determine the rate of appreciation in the net value of OCS
    resources, and initiate development as soon as that rate of
    appreciation falls below the appropriate rate of discount. If
    the cost of oil is $25, and the price is $28 and appreciating in
    real terms at 1 percent per year, the net benefit of developing
    the oil today is $3, and $3.28 percent next year. The increase
    in net benefits is thus 9.3 percent. For oil with a production
    cost of $27 the net benefits would be $1 adn $1.28 respectively,
    for a rate of appreciation in net benefits of 28 percent. If the
    social rate of discount is 6 percent, development should be
    deferred until the rate of appreciation of the resource stock
    falls below 6 percent.
    	Oil that cost $20 to develop would be evaluated in the same
    way, produced today at a price of $28 it would yeild net
    benefite of $8 Produced nest year it would yield net benefits

    				16

    of $8.28. for a rate of appreciation of cost 3.5 percent.
    Because the resource was appreciating at a rate which net loss
    than the rate of discount, the $20 oil should be scheduled for
    development now.
    	Holding everthing else equal, development should be delayed
    more, the higher the rate of increase in oil prices, the higher
    the cost of preduction, and the lower the beginning price of oil.
    As DOI has recognized if the 5-year Plan, changes in expected oil
    prices require a reassessment of the OCS leasing schedule. In
    the Appendix F. DOI used three catagories to describe potential
    oil resources.

    A. uneconomic deposits: those that are not economical
    udner the prices expected during the upcoming
    production period. (COsts exceed price on these
    deposits.)

    B. Marginal deposits: those that are economical but
    whose net benefits are growing at a rato greater than
    the discount rate.

    C. Economic deposits: those that are economical and
    whose not benefits would increase at a rate loss than
    the discount rate.

    The following DOI discussion from the 5-year Plan is quoted
    extensively, as it describes the detail the modifications to the
    5-year plan that DOI anticipated would be necessarily for certain
    price contingensies;"

    p. f-32
    IBID.

    			17

    Because of the abrupt and unanticipated oil price
    changes of the last decade or so, it is worth examining
    how a manager using this sequencing rule (the Hotelling
    rule) would react to such price changes. Assuming the
    sequence of development prior to a price increase has
    followed th rule, the manager would have his inventory
    of non producing oil and gas deposits divided into
    groups A, B, and C as decribed earlier. An abrupt and
    unanticipated increase in oil prices, assuming that it
    woulod raise prices throughout the upcoming prodcution
    period but leave the rate of price increase during the
    period unchanged, would cause him to regroup his
    deposits. Hunerous deposists would be shifted from
    group B to C because they now yield such great net
    benefits that fugure price increases would not increase
    then at a rate greater than the discount rate. . . .
    In addition, some of the uneconomic deposits in group
    A. those that were close to being economical before the
    price increase, would be shifted to group B. A large
    enough price increase could maek some deposits that
    were uneconomic shift directly from group A to group c.

    The effect of an abrupt and unanticipated oil price
    increase is thus to greatly increase the number of
    deposits economically ready for development and to
    substantially increase the net benefits which the
    economy can realize from the production of those
    deposits. The manager under these conditions would
    reasonably be expected to substantially increase the
    pace of development in order to realize these net
    benefits.

    Other unanticipated changes in oil prices could occur.
    For example, some external factor could cause an
    increase in the long run rate of oil price growth.
    THis would cause shifts in the grouping of oil and gas
    deposits similar to the abrupt price increase scenario,
    but the increase long-term price growth rate would
    reduce the extent of shifting form Group B to Group A
    and some freom group B to group C. The deposits moved
    to group A would be those that were barely economical
    given the higher prices that were expected later in the
    production period. Without such continued increases.
    such deposits become uneconomical.

    Recent price trends in the world oil markets show the
    possibility of a decrease in the rate of future oil
    price growth. If the OCS manager were confronted with
    an unacticipated levelling off of oil prices for the
    coming productin period after expecting continued
    increases, he would find it necessary to regroup his
    inventory to deposits, moving some from group B to

    				18

    group A and some from group B to group C. The deposits
    moved to group A would be these that were barely
    economical given the higher prices that were expected
    later in the production period....

    On the other hand, some deposits that were increasing
    in value under previously expected price increases
    should be shifted to group C because there is no _____
    any increase in the economic benefits to be had by
    waiting for higher oil prices. Thus an unanticipated
    leveling off in the ratet of future price growth. like
    an abrupt, unanticipated increase in prices, could
    bring the OCS manager to order an increased number of
    deposits into production in order to achieve the
    greatest gain for the economy

    	The DOI 50-Year plan was written prior to the recent plunng
    in world oil prices. The fact that the price decrease was
    unanticipated is evidenced by the fact that DOI used a base price
    of $24 dollars in 1984, increasing in real terms by 1 percent a
    year, with alternate price scenarios beginning at $19 and $28 in
    1984 dollars. Horeover, the possibility of a dramatic drop in
    the beginning price of oil was one of the few alternatives not
    discussed in Appendix F.
    	World oil prices were falling in real terms since 1980, but
    at a gradual rate until early 1986. This pattern lead DOI on
    more than one occasion to suggest that prices will continue to
    fall slowly for several years prior to beginning an expected
    rebound by the end of the century. Within the analytical
    Framework fo the Hotelling rule, as applied by DOI, calculation
    were made of the economic benefits of leasing huge areas of OCS
    resources. The same logic which supported such an aggressive
    leasing program now requires DOI to radically scale back the
    leasing schedule.

    				19
    	There can be little doubt about the implications of the drop
    in world oil prices. First, the starting price of oil is far
    lower than predicted in the base case, and even lower than the
    lowest price used in the sensitivity analysis. Second, assuming
    that long term supply and demand predictions were reasonable, the
    expected future rate of growth in prices has increased. The
    combination of a lower starting price and a higher rate of
    increase in prices means DOI must return to the drawing board to
    reevaluate its leasing schedule.
    	In DOI's words, many deposits that were previously
    classified in group C should be placed in groups B and A.
    likewise, many, if not all, deposits in group B should be placed
    in group A. Moreover, all the cost benefit calculations will
    have to be redone, to determine if the lower economic value of
    OCS resources still outweigh the costs of environmental damage
    and other negative externalitics. Finally, the expected loses to
    the Federal treasury from high private discount rates are
    expected to grow, as development will be deferred by the lower
    oil prices.
    	Recent oil prices have been unstable, but over the past two
    months have generally moved in a range of $10 to $15 per barrel.
    Crude oil deliveries from Alaska's North Slope are currently
    reporting a delivered price of 12.50 and a wellhead price of
    about $4.50. How oil production from the Hilne Point field on
    Alaska's North slepe was recently estimated to have a wallhead
    value close to $1 per barrel, leading Conoco and other producers.

    					20

    to ask the ALaska State Legislature to lower royalty payments to
    prevent a shut down of the field.

                                                                                                        1. Introduction:
                                                                                                                   The New England Fuel Institute ("NEFI")II and the Inde-

                                            COMMENTS                                                    pendent Fuel Terminal operators Association ("IFTOA") hereby

                                             of the                                                     submit comments to the Secretary of the interior concerning the

                            NEW ENGLAND FUEL INSTITUTE ASSOCIATION                                      proposed leasing and development for petroleum production of the
                                             and the
                       INDEPENDENT FUEL TERMINAL OPERATORS ASSOCIATION                                  Section 1002 area within the Arctic National Wildlife Refuge

                                             to the                                                     ("ANWR"). NEFI is the association of home heating oil marketers

                               U.S. DEPARTMENT OF THE'INTERIOR                                          serving the six New England states; IFTOA is the association of
                                             on the                                                     independent terminal operators marketing fuel oil and other pe-

                          REPORT AND RECOMMENDATION TO THE CONGRESS                                     troleum products along the East Coast from Maine to Florida.
                      CONCERNING ARTIC NATIONAL WILDLIFE REFUGE (ANWR)                                             The Section 1002 area consists principally of.the
                                                                                                        Coastal Plain at the Northern tip of the ANWR.I/ Preliminary

                                                                                                        surveys indicate that this area has the potential for containing

                                                                                                        one or more giant (more than 100 million barrels) or super giant

                                                                                                        (more than 500 million barrels) oil fields. ANWR recoverable

                                                                                                        resources could equal, or exceed, the enormous field developed on

                                                                                                        Alaska's North Slope ("ANS") at Prudhoe Bay.

                                                                                                                   The U.S. Fish and Wildlife Service of the Department of

                                                                                                        the Interior ("DOI") has prepared a draft Resource Assessment and

                                                                                                        Environmental Impact Statement regarding development of the Sec-
                                       Washington, D.C.                                                 tion 1002 area.   In this report, DOI outlines five possible al-
                                        January 23, 19.87                                               ternatives:

                                                                                                             A description of IFTOA and NEFI is included as
                                                                                                             Attachment A.

                                                                                                             Draft, Arctic.National Wildlife Refuqe, Alaska, Coastal Plain
                                                                                                             Resource Assessment. Report and re.--.)mmendacions to the
                                                                                                             Congress of U.S. and legislative environmental impact
                                                                                                             statement; U.S. Department of the Interior (November 1986).

                                                 2                                                                                          3

                        A.   The full leasing of  the Section 1002 area;                                  enormous contribution to domestic production from ANS reserves,
                        B.   The partial leasing  of the area excepting   the core                        which began production in 1977 and has already produced about 4A

                             calving area of the  porcupine caribou herd (PCH);                           billion barrels.

                        C.   Further exploration  of the area, including explora-                                   However, the 1985 decline in the*price of oil has ab-

                             tory drilling;                                                               ruptly ended the extraordinary private incentives to maintain

                        D.   No action;                                                                   domestic production. Production declined in 1986, and barring

                        E.   Designation of the Section 1002 area as wilderness.                          unforeseen events, will continue to decline.     Moreover, ANS pro-

              For the reasons discussed below, NEFI and IFTOA recommend adop-                             duction cannot be sustained at current levels beyond 1988, and
              tion of Alternative A, and urge DOI to proceed promptly with                                will decline significantly in the 1990's.     The National Petroleum

              development.                                                                                Council ("NPC") predicts that U.S. crude oil production will fall

              1. The U.S.  Needs to Develop ANWR Reserves                                                 from 8.9 million barrels a day ("MBD") in 1986 to 8.0 MBD in
                        A.   Domestic Production Is Declining                                             1990, and to 7.0 MBD in 1995.1/ To a large extent, this decline

                        oil is.the most important energy resource for the U.S.                            is inev itable and unavoidable; much of this declining production

              economy.  Oil supplies almost 43 percent of total U.S. energy                               is totally independent of price, particularly the projected de-

              demand.  Because of its relative worldwide abundance, and its                               cline in Alaska North Slope production.     Now, more than ever., new

              ease of transportation and distribution, oil will remain                                    incentives are needed.
              America's most vital energy resource for at least several de-                                         B.   Maintenance of  Domestic Production is Essential
              cades, and probably much longer.    Oil is clean, portable and                                        The maintenance of   domestic oil production, or limiting
              safe, and burns more efficiently than other fossil fuel re-                                 the decline in production, is important to the nation's economic

              sources.                                                                                    and military security.    No price support or artificial, protec-
                        Despite the enormous increases in the price of oil in                             tionist measures could maintain domestic production as effec-

              the 1970's, it remained America's fuel of choice, never. falling                            tively as prompt development of ANWR.

              to less than 41 percent of total energy demand. When prices for

              petroleum were high, incentives for maintaining and increasing

              U.S.. production were adequate. U.S. production remained virtu-
              ally steady from 1973 to 1985, in large part because of the                                     see American Petroleum Institute, Domestic Petroleum
                                                                                                              Production and National Security (December 30, 1986).

                                                  4

                          Maintenance of domestic production reduces the likeli-                                          Because of the 10 year lead time needed for Arctic
               hood of a supply disruption and lessens the costs of such a dis-                                petroleum development, it is essential to commence developmen         t of
               ruption to the economyj should one occur.       increased domestic                              ANWR now. ANWR is the single most potent weapon currently avail-
               production benefits the national economy most signif      icantly by                            able to the U.S. in its battle to prevent OPEC from regaining
               generating billions of dollars in income and related taxes; con-                                control over world oil prices and supply.
               versely, the added domestic production eliminates a comparable                                             D.  Production from ANWR Will Have a      Maior Imnact
               level of imports that would further enlarge the U.S. trade im-                                             The 001 states in its draft report:       "The (Section
               balance.   In the light of these considerations, a major opportun-                              10021 area is clearly the most outstanding oil       and gas frontier
               ity to increase domestic oil production significantly should be                                 remaining in the United States and could contribute substantially
               pursued vigorously.    Development of ANWR is such an opportunity                               to our domestic energy supplies." The mean estimate for economi-
               with virtually no adverse economic costs.                                                       cally recoverable oil in the 1002 area is 3.2 billion barrels
                          C.  ANWR Develooment Will Moderate the Level of Imports                              ("BB"). There is a 5 percent chance that 9.2 BB of economically
                          The second consequence of the decline in the price of                                recoverable oil lies within the area.. The mean estimate of 3.2
               oil is rising import levels.     The U.S. imported 24 percent more                              88 is 11.35 percent of the total current U.S. proved reserves of
               oil in 1986 than in 1985.     The NPC  predicts increases in imports                            oil.  Further, IE U.S. reserves decline as is now projected,Y
               from 4.3 MBD in 1985 to 6.2 MBD by     1990, possibly reaching 50                               ANWR could provide more than 25 percent of total U.S. proved
               percent of consumption, and to 7.9     MBD in 1995.4/                                           reserves by 2000.
                          Development of ANWR will    significantly reduce the like-                                      In addition, output from the oil fields at Prudhoe Say
               lihood of reaching these projected     levels of imports.     Unneces-                          currently constitutes about 20 percent of domestic production.
               sary reliance on imports weakens the economy by costing jobs,                                   However, this production has peaked at about 1.8 million barrels
               income and taxes that would otherwise be generated through domes-                               per day, and is expected to decline by 1988; it is estimated that
               tic production.    It has a serious impact on the U.S. trade defi-                              Alaska North Slope production will decline to only 500,000 bar-
               cit.  In 1984, crude oil and petroleum product imports were more                                rels per day by 2000.    However, if ANWR is leased and developed
               than $59 billion, almost 50 percent of the trade deficit.                                       promptly, oil production from ANWR could offset the decline in

               -4/ See API, Domestic Petroleum Production and National S       ecurity                         Y The DOI report estimates that by the year 2000 the U.S.
                   (December 30, 1986).                                                                            proved reserves could drop to 11.6 BB.

                                              6                                                                                        7

              production from Prudhoe Bay. Thus, much of the transportation                           develop oil and gas. underneath the lands which were granted
              and distribution facilities developed for ANS crude could be                            us."Z/ The direct financial benefits of development from Inupiat
              utilized for ANWR production.                                                           lands will go to these landholders. Furthermore, employment
              III.  Benefits of Development of ANWR to U.S. and Alaska Economy                        opportunities will be created where few exist; and severance tax
                        The development of ANWR will significantly benefit the                        payments to the State of Alask Ia will generate further income to
              U.S. economy.  "The net national economic benefit ("NNEB") is the                       the State.
              expected net value of oil production, or the difference between                         IV.  Mitigation of Environmental Impact Mitigation
              revenues from the.sale of oil and the costs of exploration, dev-                                  Development should not occur if it inflicts significant
              elopment, production and transportation." The DOI draft report                          and permanent damage on the environment.    Fortunately, oil devel-
              estimates the NNEB from development of ANWR could range from                            opment in the Section 1002 area can be achieved successfully with
              $79.4 billion to $325 billion, depending upon the price of crude                        little or no impact to the environment.    Alaska is a vast land;
              oil.  In addition, primarily by creating new jobs, development of                       oil development and wildlife preservation goals can be achieved
              ANWR can decrease unemployment in the depressed oil production                          side by side.  The successful development of Prudhoe Bay provides
              and services industries, where 878,000 jobs have been lost.Y                            convincing evidence that mitigation of adverse environmental
              Furthermore, the more favorable balance of trade created by dev-                        effects is possible.
              elopment of ANWR will significantly alleviate one of the most                                     One example of the favorable environment consequences
              troublesome and intractible problems facing America today.                              of ANS development is the increase in numbers of the Central
                        Development of ANWR also will benefit the native land-                        Arctic Herd ("CAH") of caribou.   Many felt this herd would be
              holders of the area.  The testimonies of various resident corpor-                       threatened by development of Prudhoe Bay and the Trans-Alaska
              ations and Inupiat Eskimos at the hearing conducted by DOI in                           Pipeline-System, the Trans-Alaska Pipeline System ("TAPS"),
              Kaktovic, Alaska, the one major village in the 1002 area, reveal                        Dalton Highway corridor and Prudhoe Bay-Kuparuk oil fields all
              the strong native support for opening ANWR to oil production.     In                    lie within the CAH's range.   Nevertheless, due to careful engi-
              fact, the Inupiat representative said: "The North Slope of Alaska                       neering of facilities and extraordinary precautions, the CAH has
              is Inupiat land     we should not be denied the opportunity to                          continued to co-exist with the development. In fact, the CAH has

              6/ National Defense Council Foundation, "The Hidden Oil Crisis,"                        Z/ Testimony of Oliver Leavitt, Elected Assemblyman from the
                  1986.                                                                                   North Slope Borough.

                                                  8                                                                                              9

               increased from 3000 in 1972 to more than 13,000 presently living                              by looping or improving pipeline hydraulics.       Furthermore, any
               near Prudhoe Bay.    In addition, water fowl that were deemed ex-                             connecting pipeline from ANWR.to TAPS can be elevated to protect
               tremely vulnerable, continue to nest and rear their broods w       ithin                      the permafrost and allow free passage to the caribou.         Conse-
               the developed area. This demonstrates that wildlife in Alaska                                 quently, the transportation facilities needed to bring ANWR crude
               can thrive if oil development is undertaken carefully and with                                to market are largely in place, and supplemental facilities can
               mitigation of environmental effects as a principal goal.                                      be built with no adverse environmental ef     fect.
                          A comparable situation exists in the ANWR, and can be                                         In countless other ways oil can be produced in the

               resolved similarly. The core calving area of the Porcupine                                    Section 1002 area with little or no adverse impact on the envir-

               Caribou Herd (PCH) is centered in the Section 1002 area of-ANWR.                              onment. Consolidating production facilities to the maximum ex-

               This zone is particularly important as an identifiable habitat                                tent will minimize effects on vegetation; insect relief habitat

               that the PCH has repeatedly used during critical life stages.                                 for the caribou can be protected by limiting surface occupancy in

               NEFI and IFTOA recommend that DOI seek authority to lease this                                that particular zone; federal performance and design standards
               area  last, in order to apply to   this critical region the exper-                            can.be enforced to meet environmental and safety requirements.
               ience learned  through prior development of other Section 1002                                in short, environmental protection is not a sound basis for pre-

               land.                                                                                         venting or deferring development of ANWR.

                           The planning and construction of transportation facili-                           V. Conclusion

               ties can also  be done in a way that minimizes the adverse econom-                                       The Section 1002 area of ANWR is the outstanding oil

               ic impact. As indicated, if the Section 1002 area is fully                                    and gas frontier in North America. Declining domestic production

               leased, oil production from ANWR is expected to grow as produc-                               and the inherent dangers to U.S.     economic and national security

               tion at Prudhoe Bay declines. Thus, existing pipeline capacity'                               resulting from such declining production makes development of

               will be available to transport ANWR crude oil most of the dis-                                this vast domestic resource imperative. Mitigation of adverse

               tance to Valdez.                                                                              environmental impacts is clearly possible, as demonstrated by the

                          Not only will this eliminate the need for construction                             previous development of Prudhoe Bay Moreover, by leasing the

               of a major new pipeline, it will also     prevent the deterioration                           core calving area of the Porcupine Caribou Herd last, further
               and premature abandonment of the existing TAPS facility.        If TAPS                       experience in mitigation can be applied to development.         In light

               capacity is inadequate, it would be possible to increase capacity

                                            10

            of these considerations, NEFI and IFTOA strongly recommend that

            the entire Section 1002 area be leased promptly for exploration

            and petroleum production.

                                           Northern Alaska Environmental Center
                                                                  219 ORPIEWAY                                            affected most significantly by the actions recommended in the report was not
                                                              FAWLBANKS, ALASKA 99701                                     on the list to receive a copy. We understand that members of the Arctic
                                                                   (907) 452-5021                                         National W1 Idlife Refuge staff had to Intercede and have copies sent to the
               February 4, 1987                                                                                           village, though not without some difficulty since such a limited number of
                                                                                                                          the reports were initially printed. The village almost had to wait until
               U.S. Fish and Wildlife Service                                                                             the second printing (three weeks later) to receive theirs.
               Attn: Division of Refuge Management
               2343 Main Interior Building                                                                                The DOI made it quite clear that it did not want public review of the report
               18th and C Streets, NW                                                                                     through its appeal of a District Court decision mandating public comment.
               Washington, DC 20240                                                                                       This is bad enough for a public agency in our democracy. However. once the
                                                                                                                          report was released, its limited availability was another serious
               Dear U.S. Fish and Wildlife .Service:                                                                      shortcoming. so few reports were initially printed that the FWS was being
                                                                                                                          extremely selective as to who received the reports during the first few
               This letter constitutes the comments, views and opinions of the Northern                                   weeks of Its availability. Considering the short time period available to
               Alaska Environmental Center (NAEC) an the draft Arctic National Wildlife                                   review such an important and complex document, not having It available to
               Refuge, Alaska, coastal plain resource assessment. report and recommendation                               the public-st-large in a timely manner was a serious and obvious effort to
               to the Congress of the United States and legislative environmental Impact                                  limit the extent of the report's circulation and comments on It. This
               statement, as solicited In the draft report. This report was prepared to                                   demonstrates to us that the DOI in still not really interested in public
               fulfill the requirements of Section 1002(h) of the Alaska National Interest                                review of the report, but allowed the draft report to be reviewed merely to
               Lands Conservation Act (AMILCA) and will hereafter be referred to as the                                   comply with the letter of the court decision. If review of Lhe report had
               1002 report or simply the report. To facilitate your review of our                                         been delayed until after the ChrietwaSholidays or if a longer comment
               comments, we have consolidated then Into broad categories according to                                     period had been provided (at least 90 days), we seriously doubt whether
               subject.                                                                                                   Congress would have minded all that such. considering that the report was
                                                                                                                          already almost three months late.
       9       For reasons outlined below, the Northern Alaska Environmental Center
               recommends the adoption of Alternative E, Wilderness Designation, as being                                 A member of our staff was informed by DOI's Susan Reece in a phone
                                                                                                                          conversation on December 11 that hearings on the draft 1002 report were
               the most prudent and responsible course for management of the Arctic Refuge                                being held only as a "courtesy" extended to the public by DOI. This seems
       D3      coastal plain. Due to the many oversights, misstatements, and problems in
       OD      the draft 1002 report, we also feel that a near total rewrite of this                                      preposterous in view of the court decision mandating public involvement. It
                                                                                                                          is noteworthy that public comment periods held by FWS In Alaska on refuge
               document will be necessary before It can be presented to Congress In a                                     draft Comprehensive Conservation Plans (CCP), which are decidedly less
               useful form.                                                                                               controversial and complex documents than the 1002 report, are a standard 90
               ADMINISTRATIVE IRREGULARITIES                                                                              days in length. The number of public hearings held on these plans is also
                                                                                                                          typically far greater than the number that were afforded for the 1002
                                                                                                                          report. If FWS can provide double the minimum 45 day comment period
               Public Comment                                                                                             (stipulated In Council on Environmental Quality Regulations) for draft
                                                                                                                          CCP's, why could It not do so for the draft 1002 report, as the public
               The NAEC is composed of over 700 members in Alaska and most of the other                                   requested? The fact that there will be opportunity for lobbying after the
               states.  It to the only environmental conservation advocacy organization                                   matter reaches Congress does not relieve the DOI from Its responsibilities
               that is entirely devoted to maintaining the environmental quality and                                      as an agency within a democratic governmental system, especially when such
               promoting sustained, Intelligent. long-term use of the natural resources     of                            an important recommendation Is to be made to the legislature. The agency's
               Arctic Alaska.   It was, therefore, with particular displeasure that we                                    attempts to prevent and later limit and stifle public involvement in the
               observed that our organization had been left off of the original                                           report are a terrible miscarriage of Its responsibilities to the people of
               distribution list at the back of the report. We had to call the U.S. Fish                                  the United States.
               and Wildlife Service (FWS) regional office in Anchorage to request our copy,
               and then had to wait many days after the report was released (organizations                                The fact that only three public hearings were held on the report represents
               on the list had already received theirs) to receive it. We would like to                                   a significant shortcoming relative to DOI's public involvement process. The
               think that this was merely an oversight. but leaving a key group like HAEC                                 hearings were held In Kaktovik and Anchorage, Alaska, and in Washington,
               off the distribution list seems rathly a deliberate omission on the part of                                D.C. The following groups or organizations have requested public hearings
               the FWS or top Department of the Interior (DOI) officials, who we realize                                  in Fairbanks and/or Arctic Village, Alaska: Greater Fairbanks Chamber of
               are really responsible for the report.                                                                     Commerce, Fairbanks North Star Borough, Arctic Audubon Society, Citizens'
                                                                                                                          Advisory Commission on Federal Areas, National Audubon Society, the Northern
               The other blatant omission that was even more puzzling and just as serious                                 Alaska Environmental Center, and the people of Arctic Village. There can be
               was the village of Kaktovik. The very village that would be changed and                                    no doubt that Fairbanks and Arctic Village will be two Alaskan communities
                                                                                                                          greatly affected by decisions relating to the Arctic Refuge coastal plain.

                                                       1                                                                                                           2

               There can also be no doubt that, while written comments are supposed to be                                The resources In question belong to the American people. These dat    a should
               equivalent to verbal ones, many people are more comfortable speaking than                                 be publicly,available In order for the report to be adequately evaluated.
               writing. Public hearings afford the opportunity for FWS to make a verbal                                  The fact that the data were collected by private entitits should not be used
               presentation concerning the contents of the 1002 report. With its 172-page                                as an excuse for keeping the data secret. This is a matter that the FWS
               length, technical jargon, and lack of availability, the 1002 report                                       should have recognized and dealt with long ago, prior to the data being
               represents a formidable document to most lay people.    Public hearings in                                collected. We think that greater creativity could have been used Irk
               Fairbanks and Arctic Village, which were desired and requested by the                                     satisfying this important concern.    It is interesting to note that
               public, would have helped alleviate these problems.                                                       Alternative C. further exploration, contains no stipulations to avoid such
                                                                                                                         problems In the future.
               Baseline Report Availability and Adequacy
                                                                                                                         Although the 1002 report purports to be an objective document, it is in fact
               The 1002(h) report was released prior to finalization and publication of the                              biased in many ways so that It favors support of full oil and gas leasing of
               1985 update and final baseline study reports that were required by Section                                the coastal plain. One of these subtle biases to reflected in the report's
               002(c) of ANILCA. Since the 1002 report was partially based upon                                          imbalance in its descriptions of the resources of the 1002 area. A total of
               information gathered In these studies, how could it have been written in                                  24 pages was devoted to describing the area's geologic and oil and gas
               compliance with ANILCA without the benefit of these reports? Just as                                      resources. However, only 11 pages were devoted to describing the area's
               Importantly. these reports should have been available to reviewers of the                                 fish and wildlife resources, which we think are equally, If not more
               draft 1002 report during the entire review period for an adequate                                         Important, especially considering that the area is supposed to be a wildlife
               evaluation. The final baseline study report was not distributed until late                                refuge. The area's living resources are just as complex as the area's
               December 1986. At 695 pages in length, it Is not a document that can be                                   geology. so that can't be used as an excuse. The report makes only minimal
               quickly perused, Under these cirumstacest it is not surprising that very                                  attempts to describe the complex ecological processes and relationships in
               little information from the baseline reports is Included in the 1002 report.                              this Arctic area, which we believe are important In understanding what the
               The 1985 update report is still not available at the end of the review                                    long-term effects of oil and gas development might be. Other biases in the
               period.                                                                                                   report will be illustrated elsewhere In our comments.
               A further apparent irregularity to the availability of the'final.baseline
               report before completion of the 1985 update report. We understand that some                               LACK OF BACKGROUND INFORMATION
               of the 1985 data were still being analyzed and the report was still being
               -written at the time that the t002 report to Congress was released. It also
               seems that the 1985 update report should logically have been completed prior                              The introduction in Chapter I (page 9)  'does not include enough background
               to the final, since the final report Is supposedly based upon information in                              information on the history and actions   leading to the establishment of the
               the 1985 update. This irregularity raises serious questions concerning the                                Arctic National Wildlife Range, which later became the Arctic National
               validity of the final baseline study report as well as the 1002 report to                                 Wildlife Refuge. this information to important In understanding the
               Congress.                                                                                                 purposes for which this conservation system unit was established. This is
                                                                                                                         especially important In light of the fact that many people reviewing the
               We further believe that the ANILCA 1002(c) studies were themselves                                        report, most importantly members of Congress, may not know that creation of
               deficient. Subsection 1002(c)(D) requires that the Secretary of the                                       the wildlife range was the culmination of many years of hard work by
               Interior "analyze the potential impacts of oil and gas exploration,                                       conservationists in Alaska and other parts of the country.
               development, and production on. . ." the wildlife and habitats of the ANILCA
               Section 1002 study area. Few of the great number of research projects that                                The original Inspiration and idea for establishment of a conservation unit
               constituted the baseline studies included work with the expressed objective                               in Arctic Alaska is attributed to Robert Marshall, who journeyed through
               of determining the impacts of such activities. These were the study of                                    what is now Gates of the Arctic National Park between 1929 and 1939 (Spencer
               seismic exploration impacts on muskoxen and limited work on the effects of                                et al. 1979). Marshall proposed the idea that large portions of Alaska
               aircraft disturbance to staging snow geese. All of the studies focused     on                             should be protected as wilderness, since most original landscapes and
               the 1002 area itself. We believe that certain key studies should have been                                ecosystems were disappearing rapidly in the rest of the United States. He
               conducted in the Prudhoe Bay oliffeld 80 miles to the west. These studies                                 early recognized the importance of keeping significant areas of the earth
               could have significantly helped In analyzing the potential impacts of oil                                 free of human domination.
               and gas development on the coastal plain of the Arctic KWR. For the reasons
               stated above, we believe that the FWS and the DOI did not comply with                                     The first attempt to act upon Marshall's ideas occurred in 1949 when the
               Congress- intent relative to preparation of the 1002(c) reports.                                          National Park Service (NPS) conducted a survey to determine areas in Alaska
                                                                                                                         that deserved formal protection as conservation units. Two NPS workers,
               Information unavailable to public or presented in a biased manner.                                        George Collins and Lowell Sumner, spent two summers exploring and studying
                                                                                                                         the eastern Brooks Range in this survey. They wrote a report proposing that
               Yet another shortcoming is the non-availability of the geological data that                               the northeast corner of Alaska and adjacent portions of Canada be protected
               the projections of oil and gas resources In the 1002 report are based upon.                               as a unique ecosystem (Collins and Sumner 1953).
                                                      3                                                                                                         4

                The report's recommendation soon attracted the attention of the conservation                          an alternative route for the Arctic Gas Pipeline and because of the Alaska
                community and concerned citizens nationwide, who began promoting the                                  Native Claims Settlement Act (ANCSA) Section 17(d)(2) 4ebates in Congress
                report's findings and lobbying the DOI to establish a park or wildlife range                          which culminated with passage of ANILCA in 1980. The Arctic Gas Pipeline
                In the area. Notable leaders in this effort included Olaus and Margaret                               proposal died in 1976. Early House versions of ANILCA, passed
                Muria, who made several trips into the area that later became the refuge.                             overwhelmingly, would have designated the 1002 area as wilderness along with
                Olaus Hurle had worked as a biologist for the Bureau of Biological Survey                             the rest of the original wildlife range, but the question of oil and gas
                (FWS predecessor) studying caribou in various parts of Alaska (Hurls 1978).                           potential prevented that. The final version resulted in the 1002 area being
                Nurie was also a co-founder of the Wilderness Society, which played a key                             excluded from wilderness designation. with the requirement for the present
                role in establishing the wildlife range. These and other conservationists                             report incorporated therein.
                worked extensively during the 1950's to get a conservation system unit
                established In the area.                                                                              The second wilderness review was specific to the 1002 area as designated in
                                                                                                                      ANILCA. That study (Thayer 1982) also concluded that the entire area,
                As stated in the report, their efforts finally resulted in establishment of                           except for the abandoned DEW Line stations, was suitable for wilderness
                the Arctic National Wildlife Range by Public Land Order in 1960. The                                  designation.
                purposes stated were to preserve "...unique wildlife, wilderness and
                recreational values." To the extent that these purposes do not conflict                               The area exceeds the 5000-scre minimum size specified in the Wilderness Act.
                with those stated In ANILCA Section 303(2)(B), which re-established the                               With few exceptions the area is In near pristine condition. It is currently
                range as the Arctic NWR. these same purposes still apply today. The report                            the most pristine large segment of Arctic tundra remaining in the United
                should be reviewed in light of this fact.                                                             States that to protected from human development. The entire balance (over
                                                                                                                      90%) of the Alaskan North Slope is currently open to oil and gas
                                                                                                                      development. The same to largely true for the Canadian Arctic as well, the
                WILDERNESS REVIEW                                                                                     exception being the new Northern Yukon National Park. which protects a very
                                                                                                                      small segment of.the Canadian North Slope. These factors drastically
                                                                                                                      increase the wilderness significance of the tOO2 area.
                Wetb I:ve that   the DOI has not complied with the provisions of ANILCA
                Sec  n  004 which calls for a wilderness study and report an the 1002 study                           The 1002 area Is primeval land and provides excellent opportunity for
                area. This study should be completed before the final report to submitted                             solitude. This factor to further enhanced by the wilderness status of the
                to Congress. A blatant shortcom *Ing of the 1002 report to the fact that                              lands Immediately to the south and east. There are no roads or designated
                there is only one-half page of text describing the area's wilderness and                              trails for travel; most travel occurs along the river courses. Visitors to
                aesthetic values. We acknowledge that describing the oil and gas resources                            the area can experience true solitude and wilderness equaled In few other
                could rightly be more complicated and thus might require more text then the                           places on earth. The area's present relative Inaccessibility Is a major
                wilderness resources description. However, we believe that the wilderness                             reason for this. Travel across the area by primitive means is reminiscent of
                values should have been described at least as thoroughly as the oil and gas                           the hardships, challenge, drama and peril faced by early American people,
                resources. As the report is written, it barely does justice to this                                   but which Is becoming Increasingly difficult to experience today. There are
                Important aspect of the area. The area's wilderness resources are Indeed                              few signs of human presence, these mostly being archeological sites and
                the crux of the current controversy surrounding this Issue. We note on page                           scattered artifacts. Occassionally one may see or hear an aircraft. Many
                46. first paragraph, that the report states that the area "could" meet the                            people spend days without seeing a single sign of human existence.
                criteria for wilderness status as described In the Wilderness Act. We
                believe that the area DOES meet these criteria.                                                       The area provides unexcelled opportunity for primitive and unconfined
                                                                                                                      recreation. The special features of the area that contribute to this are
                This lack of detail concerning wilderness values to an obvious attempt to                             its openness and feeling of unconfinement. The close proximity of the
                downplay the significance of the area's wilderness resources, and is an                               mountains and the Arctic coast In the 1002 area presents a unique wilderness
                Important omission In terms of report review by persons who are not already                           situation In the North American Arctic, offering the wilderness
                familiar with the area. We will therefore provide below augmentation to the                           recreationist the opportunity to experience. in a comparatively contracted
                report's meager description of the area's wilderness values.                                          zone, a variety of habitat and terrain types whether traveling by foot or
                                                                                                                      river. A visitor can, within the apan of a few days, go from the alpine
                At least two formal wilderness reviews have been conducted for the 1002                               zone of ice, snow and rock, to alpine meadows, to arctic tundra valleys. to
                area. One of these considered the wilderness qualities of the entire                                  tussock tundra foothills, to braided river floodplains, to rolling tundra
                wildlife range (USFWS 1973). Though this study was never finalized, the                               plain, to flat thaw take plain, to the coastal zone of wetlands, lagoons,
                preliminary draft concluded that the entire wildlife range was suitable for                           barrier islands, and the ocean. This recreational variety is unavailable
                wilderness designation. except for the two abandoned DEW Line sites on the                            within such a short distance anywhere else on the Alaskan North Slope.
                coast, the Barter Island military withdrawal, and the Kaktovik Inupiat
                Corporation land selections. The reason this study was never finalized and                            The shallow valleys of the numerous streams that flow across the area to the
                submitted to Congress for action was that the area was being considered as                            Arctic ocean provide good camping sites. Gravel outcrops an the plain bove
                                                                                                                      the rivers provide camp sites with broad views. The streams In the r:a are
                                                      5
                                                                                                                                                             6

                                                                                                                                      The region offers science the beat opportunity of.any
                not navigable by conventional power boat, and most are not easily navigable                                      place in Alaska, if not in the whole of North America, for
                by canoe.  Rafts or kayaks provide the beat crafts for river running.                                            studying the processes by which these and othen Arctic
                In terms of scenic quality, the Arctic NWR coastal plain is splendid and'                                        animals maintain theirnumbers through the natural checks
                varied. To a person situated midway between the Brooks Range and the ocean,                                      and balances of climate, food supply, and predation.
                the mountains dominate the southern skyline. Mounts Isto, Chamberlin, and                                             The whole field of cyclic population fluctuations. so
                Michelson, the three tallest peaks in the Brooks Range, are always snow-clad                                     characteristic of the smaller animals in the Arctic, can
                and are impressive when viewed from the coastal plain, their grays and                                           be studied here with no Interference by agricultural or
                whites contrasting with the greens and browns of the tundra. To the.east                                         other human activities. Such research possibilities are.
                and west, one sees the vast expanse of treeless tundra rolling into the                                          of.outstanding Importance to various applied sciences such
                distance creating the illusion of limitless wilderness in both directions.                                       as game. fur and fish management, and human survival
                If one is situated In the right place and given-the right weather conditions                                     techniques.,
                it is also possible to see to the north the coastal lagoons, the ocean and
                the permanent pack ice beyond. Because vegetation is mostly very low. only                                             Ecologists recognize that research in an Arctic
                a few centimeters tall over most of the area, both visitor and wildlife are                                      wilderness study are& has special usefulness beyond the
                conspicuous. Animals are easily visible and, because of the relative lack                                           fines of the region because the comparative simplicity
                of human presence, are often unwary or even curious when confronted by                                           con
                humans.                                                                                                          of environmental factors In the Arctic makes them easier
                                                                                                                                 to isolate and analyze.
                The Arctic coast, with the Arctic Ocean to the north and the broad coastal                                                             rue In.1953, their truth and relevancy In
                plain to the south and the general absence of man's work offer-extensive                                   If these statements were t
                primitive and unconfined camping and wilderness enjoyment opportunities.                                   1987 cannot be doubted; that 'are far fewer acres of such wild
                                                                                                                           richness today than there we:e then.
                The Arctic NWR is one of  the soot primitive and isolated wild regions left                                In 1969 the Tundra B .lose Section of the International Biological
                on earth protected as a conservation area. The tOO2 area to an integral part                               Program (IBP) passed a resolution urging that all ora major portion
                of the wilderness ecosystems encompassed by the Arctic NWR, as most of the                                                                                  .41A ------ ----------
                major wildlife species occurring on the refuge (carlNou, moose. grizzly                                                                                        ........ ........  -..
                                                                                                                           System. and that scientific research be recognized as a priority use
                bears, wolverines, wolves, muskox, polar bears, numerous species of birds)                                 of the range (USFWS 1973). The resolution also 'alled for       minimizing
                utilize the coastal plain habitats for all or critical portions of their                                   san-induced physical and biological change In the area. A major
                life cycles (i.e., calving, denning, nesting, breeding, stagIng).                                                                                             e
                                                                                                                           purpose of the IRP was to study natural ecosystems to predict the
                Seasonal abundance of wildlife on the coastal plain to high. Many species of                               consequences of Inatural or man-induced environmental changes or
                migratory birds utilize the coastal plain wilderness for nesting and rearing                               stresses.
                young. These species travel far beyond the boundaries of the refuge. The
                report correctly states that the coastal plain is the most biologically                                    The Arctic NWR Is.the only conservation system In North America and
                productive part of the entire Arctic NWR and to the center of wildlife                                     perhaps in the world that protects a complete spectrum of the various
                activity on the refuge (USFWS 1978).                                                                       arctic ecosystems In an undisturbed condition, and the 1002 area to an
                                                                                                                           integral part of that spectrum. The area presents unique
                The biological diversity and uniqueness of   Ithe Arctic NWR has been                                      opportunities for scientific study of an undisturbed ecosystem. The
                                                                                                                           area also presents excellent opportunity for wilderness environmental
                recognized by many scientists. A symposium was held concerning the wildlife
                range at the 12th Alaska Science Conference at the University of Alaska In                                 education.
                1961 (DahIgren 1962), 'At this symposium, many scientists went on record.
                stating the Importance of the wildlife range  Ito science. This importance                                 The 1002 area to the only portion of Arctic coastal plain in Alaska
                was attributed to the relatively undisturbed condition of the area and the                                 that has not been committed to man's development activitiesq except
                ecological diversity found within such a contracted zone.     It was stated                                for a tiny stretch from the Aichilik River to the Canadian border. As
                that the area could serveas a control against which we can measure the                                     such it has extremely high values as a remaining example of the
                                                                                                                           natural coastal Arctic ecosystem. Its ecological, scientific and
                effects of land-use practices elsewhere In the Alaskan Arctic, so
                opportunity that has been forgone for most other North American ecosystems.                                educational values as such an example are incomparable.
                The range's combination of habitat and species-variety was compared to that
                of Africa's Serengeti Park and it was thought that the area could      ...                                 The 1002 area in Its present state has outstanding wilderness
                provide topics for an untold number of scientific publications."                                           qualities, and completely meets the definition of wilderness contained
                                                                                                                           in the Wilderness Act. The area has been described as being,de facto
                In originally recommending the area for preservation, Collins and Sumner                                   wilderness (HR Rep. No. 95-1045, Part 1, 95th Congr., 2d Seas. 151,
                (1953) wrote:                                                                                              1978; MR Rep. No. 96-97, Part 1, 96th Congr., lot Seas. 483 and 487,
                                                                                                                           1979). In fact, the Arctic NWR Is regarded by many as epitomizing the

                                                        7                                                                                                           8

              values intended to be preserved by formal wilderness designation (S.                                       levels), vehicle trails, gravel cover, erosion and sedimentation,
              Rep. No. 96-413, 96th Congr.. Ist Sess. 376, 1979).                                                        impoundments, gravel spray. dust, snow drifts, thermokarst (permafrost
                                                                                                                         degradation), fuel spills, drilling muds and reserve pits, and
              'A number of publications have described the wilderness qualities of                                       seawater spills.  Some of the adverse impacts due to tfie
              the Arctic NWR and the 1002 area.   Some of these are Abbey (1984).                                        above-mentioned causes:   permanent changes in species composition and
              Brower (1971), Chadwick (1979). Kerasote (1984), Laycock (1976),                                           distribution, severe loss of vegetative cover, exposure of peat and
              Hilton (1969)0 Sumner (1956), and Tall (1959),                                                             mineral soil, thaw settlement, changes In moisture regime and drainage
                                                                                                                         patterns, slumping, early snow melt, and delayed plant phenology.

                                                                                                                         Although some causes and effects have been documented, there have not
                                                                                                                         been many studies done that quantify impacts to fish and wildlife
                                                                                                                         populations and habitats from oil development activities. For
                                                                                                                         example, "Few studies have been done on the effects of drilling muds
              EXECUTIVE SUMMARY                                                                                          and reserve pit fluids on tundra vegetation, and the long-term effects
                                                                                                                         are essentially unknown" (USFWS, 1986, p. 560). From page 34 of the
                                                                                                                         same report: "Little Information to available on the distribution of
              Impacts of Oil and Gas Production in the Arctic                                                            ground ice In the study area and the extent and origin of massive ice
                                                                                                                         beds. The amount of ground ice Is an important factor In determining
              The Executive Summary portion of the report does not accurately                                            the-effects of oil exploration and development on surface stability."
              reflect material contained in the body of the report. This section                                         As indicated repeatedly in both the 1002 report and the final baseline
              contains major flaws, one of which to self-contradiction. On page 2.                                       study report, many types of adverse Impacts are Inevitable
              we read: "Most adverse effects would be minimized or eliminated                                            consequences of development, even using current te-c9n-ology and
              through carefully applied mitigation, using the lessons learned and                                        mitigation procedures. The logical conclusions to be drawn from this
              technology acquired from development at Prudhoe Bay and from                                               information are that devlopment In the arctic cannot be conducted with
              construction of the Trans-Alaska Pipeline System (TAPS)." Later, on                                        only minimal impacts, and that it is presently unknown whether or not
              page 6, we read:  "Long-term losses in fish and wildife resources,                                         developed areas can be rehabilitated to their original state.
              subsistence uses, and wilderness values would be the inevitable
              consequences of a long-term commitment to oil and gas developmento                                         The 1002 area's estimated oil and gas potential
              production, and transportation." How can long-term losses occur if
              want adverse effects are minimized or eliminated? The two statements                                       What isn't provided anywhere In the executive summary Is the fact that
              quoted above are mutually exclusive. In view of the evidence compiled                                      there Is only a 19% chance that an economic size field exists In the
              to date (some of which to presented in the 1002 report), the latter                                        1002 area.  In the introduction to the executive summary it is stated,
              statement is eminently believable while the former to not.                                                 "The area Is clearly the most outstanding oil and gas frontier
                                                                                                                         remaining in the United States, and could contribute substantially to
              On page 2 of the Executive Summary we also read: "The evidence                                             our domestic energy supplies". In support of this statement. the
              generated during the 18 years of exploration and development at                                            in-place estimates for oil and gas are given. The amounts of
              Prudhoe Bay indicates minimal impact on wildlife resources." This                                          economically recoverable oil and gas. the really significant
              statement is totally insupportable. Perhaps the authors of the                                             estimates, are provided obscurely In a single paragraph an the second
              Executive Summary should have read the final baseline study report                                         to last page of the 7-page summary. We see this as a deliberate
              prepared pursuant to ANILCA Section 1002(c), before making such                                            deception, which must be rectified In the final report.
              statements. "On the north slope oil fields, new facilities are
              presently being built, and successful rehabilitation techniques    have                                    The high oil and gas potential for the area that to described In the
              not yet been developed." (USFWS, 1986, p. 563).    it Is too early to                                      executive summary and in the Secretary of the Interior's
              determine many of the long-term impacts that fish and wildlife                                             recommendation is not supported by the text of the report. our
              resources (i.e. populations and habitats) have suffered or will suffer                                     reasons for this observation are elaborated below.
              at Prudhoe Bay. In most cases. baseline studies of fish and wildlife
              resources were not conducted at Prudhoe Bay prior to oil development                                       1. on pages 49, 68, and 72, the report states that there is only a
              activities there. This makes It nearly Impossible to tell what kinds                                       192 chance of there being at least one economically recoverable oil
              of changes have occurred to date.                                                                          deposit in the 1002 area. We do not see this I in 5 chance as being
                                                                                                                         very encouraging from the standpoint of discovering oil. Where did
              The December 1986 final baseline study report devotes many pages to                                        this figure come from? The derivation of this estimate should be
              consideration of some of the adverse environmental impacts of oil                                          provided, as should estimates for each of the prospects 1-26 that are
              development, production, and transportation. Here is a partial list                                        shown in Figure 111-1. Also, what is the chance of finding other
              of the causes of some of the impacts; human activity (including                                            prospects not mapped?
              aircraft overflights, traffic, and increased legal and illegal harvest

                                                     9                                                                                                          10

                2. On page 50, Figure 111-2 compares the conditional resources of oil                                       problematical. Hue Shale to stated as the only possible source rock
                on the refuge with the recoverable reserves of proven fields. These                                         in the Brooklan Sequence. The report states that no prospects were
                data are not comparable, although the manner in which they are                                              discovered in Brookian Sequence rock. Please indicate how this
                presented makes it seem that they are.    It would be more appropriate                                      information helps support the conclusion stated in the Executive
                for the estimated reco@erable reserves In the 1002 area to be                                               Summary and on page 50 that "the 1002 area to clearly one of the most
                portrayed here. Conditional resources should be portrayed elsewhere                                         outstanding prospective oil and gas areas remaining In the United
                and identified by number (1-26) for the eight largest prospects. Even                                       States."
                if these data were comparable, for all possible prospects an the
                refuge, the most likely (95Z probability) resource estimates are     well                                   6. On page  66 the report states that the two largest prospects (18
                below the estimated reserves of most of the largest known fields. Yet                                       and 19) account for the majority (50%) of the estimated in-place oil.
                in the paragraph at the top right of this page the report concludes                                         Yet it is also stated that these prospects, which are in the Folded
                that the area is one of the most outstanding prospects to the United                                        Elleamerian / Pre-Mississippian Play, are dependent on the presence of
                States. This conclusion does not logically follow from the data                                             Elleamerian rocks as reservoirs and also an Hue Shale as the most
                presented.                                                                                                  probable source rock. The report also states that the former rocks
                                                                                                                            are likely not present in the area and that the Hue Shale is only
                1. Table 111-1 on page 50 to ambiguous. The caption states that the                                         possibly present. Again. this Information seems to Indicate
                data do not reflect the risk that economically recoverable oil may not                                      conclusions contrary to those drawn in the Executive Summary and
                exist in the "planning area". Does this man that this risk to not                                           elsewhere In this report.
                reflected only for the 1002 area, or for all of the areas compared?
                If the former to true, then this table does not represent a valid                                           7. On page 68, Figure 111-6 should show the mean estimates of
                comparison of data.                                                                                         In-place oil and gas by prospect. not by resource block.

                4(a). In several places in the report, the proximity of the area       to                                   8. Page 70: It seems that for the PRESTO model a I In 20 risk level
                Prudhoe Bay to cited as an encouraging factor In the 1002 area being                                        would more closely coincide with what was reported, particularly for
                highly prospective for oil and gas. on page 54 the report states that                                       the very large prospects. The geologic risk section on this page
                most of the Prudhoe Bay production to from Ledge Sandstone rocks of                                         needs to be..clarifted so that the lay person can understand the
                the Ellesmerian Sequence. Yet it is also stated that these rocks are                                        assumptions upon which the estimates are based.
                likely non-existent In the 1602 area. On page 54 the report also
                s,t*a-tes that if Ledge Sandstone rocks are not present, then the chances                                   9. The report uses the mean estimate as the most reasonable estimate
                of oil being present In the area are much reduced. These rocks are                                          for In-place oil. Yet the probability associated with this estimate
                cited as being the major possible source rocks for oil and gas                                              is only 402. It seems that a more meaningful estimate would be that
                production in the area, but their existence In the area is uncertain.                                       at the 5OZ level (I In 2 chance of occurrence). The amount of
                Other possible source rocks are given on page 55 as being the Shublik                                       In-place oil at this probability level Is somewhat less. 11.9 billion
                Formation and the Kingak Shale. Howevert the existence of these rocks                                       barrels of oil (BBO), compared with 13.8 BBO, the figure used In the
                in the area is uncertain. On page 62 the report indicates tharthese                                         report. However, the most reliable and most probable estimate would
                source rocks are probably gas-prone in the 1002 area. and further that                                      be that at the 952 probability level, which we note to only 4.8 BBO.
                "these rocks may not be present in much of the 1002 area." Page 54
                contains the vague statement that "drilling one or two wells in                                             10. The most likely or expected amount of economically recoverable
                critical areas would help resolve this question" of the presence or                                         oil is given in the report as the mean value (3.23 BBO). As with the
                absence of Ellesmertan rocks. This statement should be supplemented                                         In-place estimate we question the meaningfulness of this value. It
                with a map showing where these "one or two wells" would be placed. If                                       seems that a more reasonable estimate would be that associated with
                it is indeed true that drilling one or two wells would resolve this                                         the 502 probability. That estimate would be 2.21 BBO. As with the
                important queston, please explain why the draft report recommends full                                      in-place estimate, the moot probable or reliable figure would be that
                oil and gas leasing rather than exploratory drilling. This does not                                         atthe 95% probability level -- O.S9 SRO.      Me note that this is only
                :sea logical and prudent considering the predicted environmental                                            slightly more than the minima economic field size for the 1002 area
                 onsequences of fu.11 leasing.                                                                              given on page 71 as 0.44 BSO.
                (b) Also, on page 62 the report states that analyses of oil from the                                        11. The evaluations of economically recoverable oil are made with an
                Hue Shale in the 1002 area (natural oil seeps) show that this oil to                                        assumed oil price of $33 per barrel. The current oil price to less
                not chemically similar to oil from the same formation in the Prudhoe                                        then $18 per barrel. The report sakes no predictions of the future
                Bay area.                                                                                                   price of oil. Considering the recent drop in world oil prices, the
                                                                                                                            $33 per barrel figure sounds unrealistically.high. The report should
                5.  On page 58 the report states that the extremely complex geology of                                      have provided an evaluation of future expected oil prices. Otherwise,
                the southeastern half of the 1002 area makes location of structural                                         reviewers have no basis to judge whether the economic assumptions are
                traps and possible source rock In the Brooklan sequence very                                                realistic.   it should be noted that lower oil prices would result in

                                                        11                                                                                                         @12

                                                                                                                       7. An explanation of what the Kaktovik Inupiat Corporation (KIC)
               larger minimum economic fields. At current oil prices the predicted                                     lands are, their ownership history and future, should be provided.
               most likely amount of recoverable oil In the 1002 area would probably                                   Some mention Is made of these lands on pages 13. 15, and 42, yet no
               be well below the minimum economic field size.                                                          detailed explanation is ever provided. Mention should be made of what
               12. It should not ,be "expected that this LEIS will suffice for                                         effect the "1991" provisions of the Alaska Native Claims Settlement
                                                                                                                       Act (ANCSA) might have In terms of land ownership in the 1002 area,
               Initial leasing'"'Tpage 13). This statement shows a blatant disregard                                   and the significance of ANCSA Section 22(g) relative to these lands.
               for the provisions of the National Environmental Policy Act (NEPA).                                     The fact that a land exchange in 1983 allowed private entities to
                                                                                                                       drill an exploratory well Inside refuge boundaries to significant.
                                                                                                                       The trunk oil pipeline proposed under Alternative A "will transport
               EXISTING ENVIRONMENT                                                                                    oil from Federal leases and from any private lands In the 1002 area to
                                                                                                                       Pump Station I" (p.89). The report's failure to address the
                                                                                                                       additional Impacts that night occur from leasing and production on
               1. A section on water quality should be added.                                                          these private lands to another of Its many flaws.
               2. The section on air quality is totally inadequate. All references                                     8. On page 37 sport fishing to mentioned as being minimal in the 1002
               cited predate development at Prudhoe Bay and In no way represent                                        area. Although we acknowledge that sport fishing to not a primary
               current conditions. Monitoring data collected in the late 1970's                                        reason why people visit the area, it to an activity that is engaged In
               should be cited. Ambient air quality monitoring at Prudhoe Bay began                                    by'alaost everyone who does visit the coastal plain.
               In late 1966. Permitted discharge for nitrogen oxiles is currently
               100,000 tons annually. Until results are available from this                                            9. on page 41 in the lost paragraph in reference to Kaktovik whaling.
               research, effects must be considered unknown and warrant further                                        what to the definition of "historic" period? The next sentence
               evaluation. Some attention should be given to emissions from start-up                                   appears to contradict the statement that no whaling took place at
               and upset flaring. Measures must be established to ensure that                                          Kaktovik during the historic period.
               appropriate monitoring is conducted. Stipulations and operational
               pr c dures should be based on real data rather then supposition, in                                     10. On pages 75-76 the lack of water and gravel resources are
               .r:e: to be effective.                                                                                  highlighted as major engineering problems. We see these as major
                                                                                                                       environmental problems as well If oil and gas leasing to authorized.
               3. it should be mentioned on page 17 that average snowfall on the                                       The report's failure to adequately address these problems Is one of
               Arctic NWR is significantly less than in the Prudhoe Say area.                                          Its major flaws.
               4. On page 26 the Sadlerochit Spring area was mentioned as having                                       11. Beginning on page 84 and becoming more common from there on the
               been nominated as a National Natural Landmark. However, the report                                      word "will" is used In places where the word "would" seems more
               failed to mention another site that was likewise nominated. This is                                     appropriate. This implies a presumption on the part of the authors
               the Beaufort Lagoon-Demarcation Bay area (Bliss and Gustafson 1981).                                    that development "will" take place, rather than "might" take place.
               Another site that was nominated for inclusion in a State system of
               ecological reserves is the Jago River drainage. This site was                                           12. Assumption 7 on page 89 states that additional geophysical
               described by Steneark and Schoeder (1974) to contain "a complete array                                  exploration would be allowed prior to lease sales. We believe that
               of tundra and floodplain vegetative and animal types typical of the                                     additional exploration of any kind should be allowed only following a
               North Slope." The Secretary's recommendation would allow oil                                            lease sale.
               development over the entire extent of this proposed ecological
               reserve. Yet it was not mentioned at all in the reportl                                                 13. The exclusion of the 1002 area from the operation of the
                                                                                                                       comprehensive conservation planning (CCP) process to a perversion of
               5. The goals of the State's Coastal Zone Management Plan are                                            Congress' intent In setting up that process. The CCP should proceed
               mentioned frequently in the report (pages 27, 42, and 43). We note                                      independently of the 1002 process, for the entire refuge. Congress
               that most of these goals point toward the maintenance of a natural                                      will have the ultimate decision concerning any lease sale authority or
               environment on the North Slope. The Secretary's recommendations                                         wilderness designation. We see this as another example of the
               should have addressed this.                                                                             Department-a attempt to limit public comment and involvement In
               6. on page 34, specific Information Is lacking for loons. Plate 3A                                      decisions concerning the 1002 area.
               implies that waterfowl and loons only nest in the shaded areas. This                                    14. No exact boundaries were presented In the report as to the area
               is inaccurate. The map should also depict the important                                                 or areas that would be excluded from leasing under the limited leasing
               staging/molting areas for oldequaw and other waterbirds in the coastal                                  alternative. The boundary of the core calving area for the Porcupine
               lagoons. More detailed habitat use data should be provided for all                                      caribou herd is Inexact. What rationale was used in deciding to
               migratory bird species.                                                                                 exclude only the core calving area from leasing under Alternative B?

                                                                                                                                                             14
                                                      13

                Why not exclude the entire concentrated calving area? Apparently the                                       (c) Another way to ensure the use of effective mitigation measures would be
                basis for the difference between full and lipited leasing relates                                          the inclusion of stipulations for such measuresin lease sale
                entirely to caribou. Other resource values, of at least equal                                              authorizations. This would likely be much more effective then the use of FWS
                significance, are not even mentioned. Why?                                                                 special use permits or other authorizations.

                                                                                                                           (d) In light of the above, Assumptions 2 and 3 used in assessing
                ENVIRONMENTAL CONSEQUENCES                                                                                 environmental impacts as stated on page 98 are invalid.

                                                                                                                           4. Page 98 - Assumption 4 - these standards and stipulations cannot be
                This chapter focuses primarily on wildlife and habitat issues. We                                          assumed to be adequate for the entire 1002 Area nor should standards and
                found several problems with this section (Chapter VI). These problems                                      stipulations used for exploration be considered acceptable for development.
                are detailed below.                                                                                        We are concerned that the excessive issuance of variances and special
                                                                                                                           permits could render all of these standards and stipulations irrelevant.
                1. A major omission.in the 1002   report to its failure to consider the
                impacts of possible'development associated with gas production.                                            5. We question the statements on page 99 that ice roads on NPR-A had
                Please provide concrete substantiation for the statement on page 95                                        "virtually no effect" on the tundra and that ice airstrips can be used on
                that "no appreciable increase In environmental impacts is anticipated"                                     the tundra in the same place for more than one year without any effects. We
                due to gas production. Referring to gas In the 1002 area, the 1002                                         would like to see documentation for these statements. Also, are we to infer
                report states on page 143 that "...it to expected that gas production                                      from this Information that the same would be true in the 1002 area?
                from this area would also be economic within two to three decades."                                        Differences in microsite characteristics between MPR-A and the 1002 area are
                It seems likely that there would indeed be impacts associated with gas                                     liable to be significant.
                production that would be additional to those associated with oil
                production. The largest gas production facility in the world recently                                      6. The discussion of reserve pits on pages 99-100 is inadequate. There
                began operation on Alaska's North Slope, and DOI Is currently                                              needs to be a review of practices used to date, and needed Improvements.
                processing an application to build the Trans-Alaska Gas System (TACS).                                     "Approach I." - leaving reserve pits open is NOT ACCEPTABLE1 Page tOO is
                For these reasons, ,a feel that . detailed discussion of additional                                        the ideal location for discussing alternatives to using reserve pits     for
                facilities and Impacts associated'vith gas production would be                                             exploratory drilling. Recycling, backhaul, annular injection, and
                suitablefor inclusion In the final 1002 report.                                                            Incineration are alternative methods that merit detailed discussion,     given
                                                                                                                           the problems with reserve pit fluid discharges. ,

                2.  In paragraph 4. the.process for consultation   and coordination                                        7(a). On page 101, further explanation of the "possible creation of      20-30
                should be formalized so that each party is aware   of their specific                                       elongited deep pools" would be germane to the discussion of probable     water
                responsibilities.                                                                                          sources. We recommend that you describe the size (length and width)
                                                                                                                           required, and show probable sites on a map, along with gravel borrow     pits.
                3(a). On page 97  most of the discussion sounds good in theory, but we
                see this as being wishful thinking on the part of the authors. The                                         M The discussion of unavoidable effects on the physical environment* also
                demonstrated environmental track record of the oil industry and the                                        found on page 101. Is incomplete. Additional unavoidable effects to address
                success (or lack of it) of the regulatory agencies In enforcing                                            include: construction of a minimum of 50 miles of road from Prudhoe Bay to
                mitigation procedures, does not give us such confidence that proposed                                      the Canning River, thermokarsting of tundra, and flooding due to
                mitigation provisions are realistic expectatons. The chapter on                                            Impoundment. Also, a significant difference between Prudhoe Bay and the
                environmental consequences should have been written with the                                               1002 area to that oil development in the 1002 area will require many more
                assumption of realistic mitigating measures. To do otherwise would be                                      crossings of major river drainages than were necessary at Prudhoe Bay. This
                misleading.                                                                                                is Important, as experience at Prudhoe Bay and Kuparuk has shown that
                                                                                                                           industry favors the use of culvert crossings over bridge construction.
                M The Fish and Wildlife Service is primarily a land management                                             Culverts are frequently ineffective for providing cross drainage of water.
                agency, not a regulatory agency. While general suggestions sound
                fine, it would be more appropriate to propose specific additional                                          8. On page 102 It should be noted that changes in plant species composition
                regulations to be added to the Code of Federal Regulations. Such                                           result from seismic survey activity.
                regulations could be designed to Increase the Fish and Wildlife
                Service's ability to promulgate effective and enforceable mitigation                                       9.  Page 103 should include Information on the number and size of reported
                procedures.  In the past, the oil industry has frequently balked at                                        fuel spills which have occurred along the TAPS corridor, both during
                Implementing mitigation procedures thought to be too expensive,                                            construction and production. This might also be a good place to indicate
                regardless of their demonstrated effectiveness. An example of this      is                                 the number and size of unreported spills for which fines or other punitive
                industry's steadfast opposition to timing restrictions designed to                                         action has been levied.
                protect goose nesting and brood-rearing.

                                                                                                                                                                    16
                                                    15

               10, On page 105, the probability of a catastrophic oil spill should be                                 "Brown bears are not readily displaced by human activity" is highly
               determined. Cumulative impacts of offshore development, as well as 1002                                questionable. "if the petroleum development program results in a decline In
               area development alone, should be considered.                                                          use of the area by PH caribou, a corresponding dectin& in brown bear
               Il.(a) Plain English should be used throughout the report. On page 108,                                population will be expected." (USFWS, 1986, p. 603). A population decline
               the statement "The lack of observable adverse effects from displacement                                or distribution change for 20-40 percent of the Porcupine Caribou Herd to
               exhibited by the CAM would be unlikely for the PCH" should be changed to                               projected in the 1002 report.
               "Observable adverse effects from displacement are likely for the PCH."                                 (b) Brown bears   are also likely to suffer the adverse impact of increased
               (b) According to the second to last paragraph on page 108, the Secretary's                             man-caused mortality if full oil and gas leasing of the coastal plain
               recommendation directly violates the FWS mitigation policy. Full oil and                               occurs. Under the summary of unavoidable impacts, Alternative A (p. 132),
               gas leasing would ensure the projected displacement from preferred calving                             it Is predicted that development would cause the loss of one brown bear per
               habitat of the Porcupine Caribou Herd. This displacement represents a                                  year in the 1002 area. Upon what is this prediction based? The final
               complete lose of habitat values from at least part of an area which to                                 baseline study report says "Brown bears have historically not abandoned
               designated as Resource Category I habitat. The mitigation goal for Resource                            previously occupied areas when those areas were developed by man. Instead
               Category I habitat is no lose of existing habitat value. What to the                                   bearwcontinue to use the newly occupied areas and eventually are eliminated
               justification for a wildlife protection agency violating its own goals?                                by killing because they pose a threat to human safety. The mortality rate
                                                                                                                      of these encounters are unknown." (USFWS, 1986, p. 603). The same report
               .12. The negative stimulus conditioning for caribou described on page 110                              indicates that increased access has the potential for increasing the hunting
               would have the additional negative effect of reducing the quality of                                   mortality of brown bears, citing other studies showing that this occurred
               wildlife viewing opportunities on the Arctic NWR. This activity is a major                             during the construction of TAPS. In view.of the above, It seems reasonable
               recreational use of the refuge.                                                                        to propose that death in another, and perhaps the ultimate, form of
                                                                                                                      displacement.
               13. on page III under Mitigation, Item 9 states that additional mitigation                             -(c) Once again, proposed mitigation measures  sound good on poper.but         IIn
               measures would be implemented after the Porcupine Caribou Herd started to                              reality are likely to be ineffective in their  present form. Strict
               decline. We believe It would be too late at that time. Also the discussion                             enforcement and active monitoring programs cost lots of money. What level
               of additonal mitigation measures is very general and nebulous. We would                                of increase to proposed for the annual refuge budget, in order to fund these
               like to see some elaboration and clarification of what these additional                                programs? It seems probable that under a full leasing program brown bears
               measures might be. What does "state-of-the-art" mean In this context?                                  would suffer a major decline In the 1002 area.
               14. The conclusion on page 114 about negligible effects on Doll sheep       is                         18(a)'  The conclusion with regard to possible  development impacts on polar
               flawed. We think that the Increased human population In the area would have                            bearo*(page 118) to flawed. This section states that development In the
               at least a moderate if not a major effect on the Doll sheep population of                              1002 area causing "...exclusion and decline in natality would likely not
               the northern Brooks Range. The report assumes more restrictive hunting                                 affect the species' overall survival, so long as similar intensive
               regulations. However, unless enforcement activities were concurrently                                  developments did not occur along the entire northern coast of Alaska and
               increased, the sore..restrictive regulations would be largely ineffective.                             Canada." In fact. stailar,intensive developments have already occurred In
               Currently. law enforcement on the Arctic NWR Is negligible. Can we assume                              these coastal areas. and sore are proposed both on and off shore. Thus it
               that things would be different In the future? What sort of budget,increase
               is proposed for the refuge to ensure effective enforcement?                                            appears likely that polar bears In the Beaufort Sea region will be adversely
                                                                                                                      affected by the cumulative Impacts of industrialization of the area. The
               15. On page 116, the statement "measures designed for prey  species such as                            1002 report's failure to address theme undeniable cumulative effects is one
               caribou, muskox, and moose will also benefit wolverines" is misleading. The                            of Its major flaws.
               word "will" should be replaced by "could" or "might".                                                  (b) The conclusion section goes on to state that annual mortality is
               16. The conclusion of moderate impacts on the wolf population stated on                                approximately equal to annual natality for the Beaufort Sea population of
               page 115 is overly optimistic, again relying on adequate enforcement. Past                             polar bears, Under  the mitigation section, it is proposed that polar bear
               experience with this species has shown that where it comes Into direct                                 den :ress be documented so that "oil-developsent activities avoid then to
               contact with humans, It tends to be diminished. It is a species that                                   the aximum extent possible." That has been shown to be ineffective in the
               requires true wilderness to survive. We believe that most wolves would be                              past, as the den abandoned by the suspected pregnant female polar bear In
               eliminated from the area as has happened in the Central Arctic as a result                             1985 had been well documented (the beer was radio-collared).    The cause of
                                                                                                                      abandonment In this case was strongly suspected to be repeated disturbanc:
               of oil development activities (see 1002 report, p. 108).                                               by motorized exploration support equipment. It was also thought that           ,hi
               17.0) The conclusions concerning brown bear stated on pages 116-117 are                                bear aborted her pregnancy.
               likewise flawed. The same concerns expressed above for the wolf can                                    (c) In the general section on polar bears, the 1002 report tells us that
               generally also be stated for brown bear. In particulars the statement that                             "preserving undisturbed onshore denning habitat each year to very Important
                                                     17                                                                                                      18

              for the 12 to 13 percent of females denning on land rather than offshore                                 preference for staging in the 1002 area. Under the proposed full leasing
              ice. Horeover, if there is an especially significant area for denning on                                 program, the entire area would be subjected to development activities. The
              land in Alaska, it is on and adjacent to the 1002 area." Yet we also learn                               protection of internationally important migratory bird resources to another
              from the report that oil development would require the citing of facilities,                             outstanding reason for the prohibition of development of the 1002 area.
              such as the Pokok port site, In the exact areas where polar bear denning has
              been documented to occur. Furthermore, the report Indicates that the                                     21. The conclusions stated on page 123 about impacts to seabird and
              construction of onshore facilities in polar bear habitat will probably help                              shorebird populations are vague. This section should document the high
              increase development activities offshore in polar bear habitat.                                          potential for moderate to major effects that would result from development
                                                                                I.                                     in riparian zones and coastal wetlind systems. The potential effects of a
              (d) Given the above, please indicate why the Secretary's recommendation is                               catastrophic oil spill on birds need to be predicted and discussed.
              for full oil and gas leasing of the  1002 area. Please also-indicate how
              this recommendation augments the purposes for which the Arctic NWR was                                   22.(a) On pages 125-126 the discussion of impacts on   fish does not consider
              established under ANILCA. Specifically, how will full leasing help "to                                   the effects of water withdrawal from streams. Unless specific     regulations
              fulfill the international treaty obligations of the United States with                                   are formulated to the contrary, these impacts would be inevitable if the
              respect to fish and wildlife and their habitats" (ANILCA Section.     1                                  1002 area was opened to full leasing. "Water withdrawal in critical areas
              303(2)(B)(ii))? According to page 33 of the 1002 report, "Polar bears     are                            and/or during critical time periods, and gravel removal from fish-bearing
              protected under the provisions of the Harlon Ma"al Protection Act of 1972."                              stream systems would not be permitted", claims the 1002 report. Two
              How will full leasing supplement the provisions of   this Act? Also on page                              paragrphs later: "Development in Block A would require both water and
              33, we read that the U.S. and four other countries   ratified an agreement for                           gravel. If these materials were taken from the Tamayarlak River, moderate
              the conservation of polar bears in 1976. "Article    11 requires that                                    adverse effects on grayling would result." No alternative to the Tamayariak
              appropriate actions be taken to protect ecosystems   of which polar bears are                            is mentioned here for.gravel and water sources. This makes it obvious that,
              a part, especially denning and feeding sites." In    our view, protection of                             even before Congressonal consideration of the coastal plain issue, plans are
              the delicately balanced Beaufort Sea population of   polar bears and their                               already being made to withdraw water and gravel from fish-bearing stream.
              habitat is one of the strongest reasons for prohibiting oil and gas,                                     systems. Dewatering of fish overwintering Pools at Prudhoe Bay has been
              development activities in the 1002 area.                                                                 documented to result in fish kills. "Large reservoirs excavated in "dead
                                                                                                                       arms" of rivers, perhaps In conjunction with gravel removal, may be the only
              19.  In the discussion of marine mammals on page jig, the additional impacts                             viable option to provide the large quantities of water needed to develop oll
              of contaminants, including both chronic and catastrophic spill                                           reserves at the more inland areas of the ANWR coastal plain" (USFWS, 1986,
        -4    possibilities, should be considered. Again, this discussion is deficient in                              P. 609).
              light of the Indication, found elsewhere in the report, that port facilities
              built for production In the 1002 area would facilitate development of                                    (b). The cumulative effects on fish populations and habitats of docks and
              offshore oil,and gas leases. These probable cumulative impacts should be                                 causeways from offshore development are not given adequate consideration.
              discussed in detail.                                                                                     "Impacts can include: impedence of normal fish and prey organism movements;
                                                                                                                       alteration of water temperature, salinities, and current patterns; and
              20(a). "The judicious placement of transportation corridors south of                                     changes in disposition of sediments" (USFWS, 1986, p.610). This is
              coastal nesting areas would be particularly Important for tundra swans",                                 important because industry has continually refused to accept causeway and
              according to the mitigation section on page 121  ' How can this be                                       dock designs other than solid-fill with Inadequate breaching.
              accomplished? what areas would not be leased in order to accomodate nesting
              swans? It seems likely that impacts to tundra swans in the 1002 area could                               23. At thetop of page 127 we read that "Rehabilitation of the entire
              be moderate to major consideringthe cumulative impacts that would result                                 coastal plain ... could require as many as 1,500 people for several years."
              from development of RIC lands and state submerged lands offshore. Swans                                  This statement implies that rehabilitation can actually be achieved, and
              nest in areas with the most lakes. The huge demand for water out of those                                therefore is contrary to information contained In the final baseline study
              lakes would likely preempt attempts to keep development away from them.                                  report. The discussion of employment also implies that local residents
                                                                                                                       would derive great benefits, when in.reality most of the oilfield workers
              (b) We agree with the statement on page 121 that "Reserve pit fluid                                      would come in from somewhere else. Any benefits that did accrue to Kaktovik
              discharges and other contaminants should be adequately controlled." in    what                           residents would necessarily be as long- or short-lived as the oilfield
              specific ways will this be accomplished? As stated before, the effects    of                             itself, whereas subsistence from the land has sustained the Inupiat people
              these discharges on arctic tundra and wetland ecosystems are not yet fully                               for 10,000 years.
              understood. Perhaps reserve pits should not be used at all if the 1002 area
              to developed.                                                                                            24. One of the major Impacts on subsistence Is likely to be    the reduced
                                                                                                                       availability of the Porcupine Caribou Herd to the people of Arctic Village
              (c) The discussion of the effects of various.kinds of disturbance    on snow                             and Old Crow if the herd population is reduced. Those villages depend
              geese is inadequate in that it does not consider possible Indirect    effects                            principally on the Porcupine herd for subsistence. Yet the report on page
              such as contaminants from reserve pits, and fuel and.seawater spills. The                                127 only mentions the possible effects on these villages in passing. We
              high mobility of staging snow geese to irrelevant, as data has shown their                               think that these effects should be dealt with more thoroughly.

                                                     19                                                                                                       20

                                                                                                                        nearly as great for limited as for full leasing (pages 135-136).
             25. Proposed land exchanges in the 1002 area, between the federal                                          32. On page 138 the reduction in economic benefits from limited leasing as
             government and other corporate and government entities, could have     major
             environmental and socioeconomic impacts.     One of the most glaring   major                               compared to full leasing would probably not be quite ;a great as described
             Items that the 1002 report fails to address is the so-called "Hegatrade"                                   (one third). The portion of the coastal plain that apparently would be
             negotiations and their possible effects relative to FWS environmental                                      excluded from leasing would only contribute about 25% of the economically
             regulation as well as on state, local, and federal economic systems. These                                 recoverable oil, based on the estimates given.
             exchanges have the potential to seriously impair the ability of FWS to
             regulate oil exploration and development activities in the 1002 area. Page                                 33. on page 139 the effects of limited leasing on wilderness values were
             130 would have been the ideal place for a discussion of possible economic                                  described as not destroying the wilderness qualities-of the southeastern
             impacts of land trades.   It is Imperative that the above items be addressed                               portion of the coastal plain. However, on the flat coastal plain, the
             in detail In the final 1002 report to Congress.                                                            visual and aural effects of an oilfield would extend much farther than the 5
                                                                                                                        miles given in the report as being a mitigating buffer distance.
             26.(a) On page 131 under the section on "Recreation, Wilderness, and                                               On page 141 the description of socioeconomic effects of no action
             Esthetics", the first sentence states, "Most recreationisto . . . might                                    34(a).
             perceive the existence of oil facilities in the area as lessening the                                      deceptively implies that the only chance for economic development in
             quality of that experience." We think that the word "might" should be                                      Kaktovik would be from oil development In the area. This is not necessarily
             replaced with "would."                                                                                     true. It to possible for economic change from sources such as tourism
                                                                                                                        (currently an annual Ifidustry of over $700 million In Alaska) or other
             (b) Concerning Impacts on hunting, the report states that hunting would not                                industry. Furthermore, It to incorrect to state that under Alternative 9
             be allowed and access would be restricted in the ollfield area. Yet the                                    "production of the estimated 3.2 billion barrels of recoverable oil would be
             analysis on page 131 goes on to conclude that the effect on hunting would be                               forgone." Production of the oil, If It is there. could be postponed
             negligible. This conclusion is ridiculous. If hunting Is not t1lowed                                       indefinitely, but the oil itself would remain,
             within an area, that in itself to a major impact on the activity.      it to                               (b) on page 141 It to stated that under the no action alternative the
             also patently ridiculous to Imply that roads built In the 1002 area to                                     entire coastal plain within the refuge, including the RIC land would be
             facilitate oil and gas production will improve public access for recreation.                               closed to oil and gas development. That is not necessarily true. It Is
             Because of tight ollfield security, access would effectively be denied to                                  coAceivable that Congress could allow oil development on the Native land
             the general public. Even If It were not, the restrictions on the discharge                                 without opening up the refuge lands.
             of firearms would effectively preclude any hunting throughout most of the
             1002 area under full leasing. This in turn would cause Increased hunting                                   (c) Also in relation to the above, on page 141 it is stated that if
             Impacts on lands outside the 1002 area.                                                                    Congress took no action then the 1002 area would then come under the CCP
             27. The summary of unavoidable Impacts, Alternative A, should also Include                                 process. Can the Secretary force Congress' hand? When would it be
             the following: direct loss of at least 12,000 acres of shorebird,                                          determined that Congress had taken no action? The day after the report is
             passerine, waterfowl, and other migratory bird nesting and staging habitat.                                submitted? one year? Ten years? Never? What happens to the 1002 area in the
                                                                                                                        meantime? it is still part of the refuge.
             28. On pages 105 and 133, we think that the effects on Sadlerochit Spring                                  35(a). On page 142 In the discussion of Irreversible and Irretrievable
             would be greater than negligible. Effects would likely be at least                                         Commitments of Resources the report fails to consider the possible changes
             moderate. Again, the report Is relying on move effective enforcement than                                  in fish migration patterns and use of lagoon areas that could result from
             we believe to realistic.                                                                                   construction of docks and causeways.
             29. On page 134 the conclusion concerning effects on muskox from limited                                   (b) Also In this section, wilderness deserves a separate category, for once
             leasing Is Inconsistent. The conclusion begins by stating that effects                                     it to destroyed. wilderness Is surely irretrievable. It should be clearly
             would be the same as for full leasing. Those effects were given on page      114                           stated that air access for traditional uses to allowed by fixed-wing
             as major. Yet, the discussion an page 134 goes on to state those effects as                                aircraft only. Helicopter use requires a special use permit on the refuge.
             being moderate. Which is it? Since the concept of limited leasing appears
             to-be totally guided by concerns relative to caribou, It seems likely that
             effects on muskox would still be major.                                                                    36(a). The recommended mitigation measures listed on pp. 145-147 are
                                                                                                                        Inadequate for an area as Important as the Arctic NWR coastal plain. Hany
             30. We think that the effects on Dall sheep from limited leasing (page 135)                                of the proposed measures have been unsuccessful to the past, or have been
             would be nearly as great as for full leasing because the increase in hunting                               totally unacceptable to industry.    For example, efforts by the Alaska
             by ollfield workers would probably be the same. These effects would                                        Department of Fish and Game to restrict oilfteld activities during caribou
             probably be moderate to major.                                                                             calving at the Kuparuk fields were not completely successful. In this case,
                                                                                                                        so many variances were issued that the original restrictions might as well
             31. We believe that the effects on the wolf and brown bear would likely be                                 have never existed. The feeding of Arctic Foxes continues in the Prudhoe
                                                    21                                                                                                          22

               and Kuparuk areas even though proh ibited.
                                                                                                                        NATIONAL ENERGY NEEDS AND THE 1002 AREA-S  POTENTIAL CONTRIBUTION
               (b) Proposed mitigation measures should be made much more specific. For
               example. under number 13, key species should be listed: caribou (PCH and
               CAN), polar bears, brown bears, muskox, Dall sheep, wolves, wolverines, $now                             It to difficult to.imagine what the actual basis Is for justifying the
               geese, peregrine falcons and other migratory birds, arctic char and                                      opening of the 1002 area to full oil and'gas leasing.    it seems obvious that
               grayling. and other species. Number 14 should show closed areas on a map,                                private corporations will benefit the most from a full leasing program. If
               where no activity is permitted. Numbers 30 and 31 are extremely vague and                                economically recoverable oil deposits exist. As private entities benefit,
               rudimentary. Applicable laws and regulations should be cited. Number 32                                  the public will lose as lands set aside in the national interest have their
               should define specifically the process whereby the suggestions will occur.                               surface permanently modified. Considering the arguments below, there seems
                                                                                                                        to be nothing substantive to support claims that oil from the coastal plain
               (c) We also recommend additional stipulations. Number 33:     lease sale                                 is needed for national security. Nor would it seem that such oil, if it
               stipulations shall prohibit any permanent facilities until a field has been                              exists, could make enoughof a contribution to domestic oil production to
               delineated and a complete development plan approved. Number 34: Prohibit                                 significantly reduce our.nation's dependence on foreign oil.,
               gravel extraction or gravel fill in drained lake basins, river deltas and
               riparian areas to protect important shorebird and waterfowl habitats. A map                              We'do not agree with the conclusions reached in Chapter VII. The fact that
               of these areas should be provided. Further measures, such as the                                         no national energy conservation 'policy is either Implemented  or proposed
               implementation of stream setbacks for all facilities, should be considered.                              Indicates to us that there is no serious desire to address energy problems
               As stated previously, most of the proposed measures are likely to be                                     in this country.  Furthermore, it is difficult to support invading a
               ineffective without adequate enforcement.                                                                wildlife refuge for non-renewable energy resources while at the same time
                                                                                                                        providing no support for the development of renewable energy resources.
               37. Throughout the 1002 report, and particularly In the Environmental                                    Workable techniques and technologies currently exist in this country for
               Consequences section. there is a marked failure to include predictions    of                             both.energy conservation and alternative energy, yet,.there to no national
               Impacts associated with service and support industries and facilities.     Oil                           leadership to foster either of these long-term solutions to our energy
               production has never occurred without these industries In the past, nor to                               problems. Instead, as the next paragraph graphically illustrates, the
               it likely to In the future. This oversight lessens the predicted extent and                              public to continually asked to believe that it to in the nation's best
               level of Impacts. and serves to undermine the usefulness of the 1002 report                              Interest to sacrifice environmental values in favor of developing
               as an instrument for determining what, those impaCES might be.                                           non-renewable resources so that they can be.wasted.
               38. Disposal of each solid waste and liquid waste stream should be                                       According to some estimates, the recently vetoed  National Appliance Energy
               individually addressed. The treatment of drilling suds in this report is                                 Efficiency Act, passed by both the House and the  Senate, would have saved
               woefully inadequate.- The state of,Al:asks to working on drilling mud                                    the equivalent of over 1.5 billion barrels of oil over the next 20 years.
               regulations and these efforts should be taken into account.                                              That amount of oil constitutes almost half of the wean.condittonal te  Isource
                                                                                                                        estimate for the coastal plain (3.2 BBO) used In the 1002 report. There are
               39@a). No discussion of hazardous waste management Is included in this                                   also moves afoot to repeal the federal 55 mph speed limit. It to estimated
               report. Of the 99,000'setric tons of waste generated in Alaska In 1984,    the                           that a national speed limit of 70 mph could increase daily U.S. energy
               oil and gas industry Is responsible for-managing 97.300 metric tons.                                     consumption by as much as 12. According to the 1002 report, if mean
               Further growth is expected from exisiting production areas and this wilt                                 resource estimates prove correct for the coastal plain that area will
               increase demand for disposal. The state is In the process taking over                                    contribute only 4.17Z of U.S. oil demand by 2005. Recent recommendations
               hazardous waste management from the EPA and is working on hazardous waste                                from the Regulatory Review Task Force chaired by Vice President George Bush
               siting facility regulations. These efforts will have direct bearing on any                               have supported the repeal of fuel economy standards for American cars.
               development in the 1002 area and must be addressed.                                                      Thus, it would seem that more than 25% of the oil from the coastal plain
                                                                                                                        would be used to enable Americans to go faster intheir gas-guzzlers. This
               (b) Given the Importance of the 1002 area to.refuge wildlife populations,                                ftagrant waste certainly does not constitute a "national need for domestic
               and the possible effects of wastes on populations and habitats, it might be                              sources of oil."
               appropriate to lift the oil and gas Industry exemptions extended under the
               Resource Conservation and Recovery Act. If so, such a recommendation should                              Significant questions remain unanswered relative to the need   to lease the
               be made to Congress. Hazardous waste presents another problem under other                                coastal plain at this time, as is recommended. Right now on    the North
               federal legislation, the Comprehensive Environmental Response Compensation                               Slope, producing oil fields and fields with proven reserves are.shutttng
               Liability Act (CERCLA). If a hazardous waste split were to occur in the                                  down or going undeveloped. Examples of this are at.Mtlne Point and the West
               1002 area, it could significantly increase the federal government's                                      Sak fields. This indicates that economic factors, not the national
               liability under CERCLA. The potential for such a spill, and the resultant                                interest. are the true motivating forces behind 611 exploration and
               economic Impacts to the federal government, should be addressed in the final                             development.
               1002 report.
                                                                                                                        Chapter VII does not go  far enough in evaluating the nation's total energy

                                                      23                                                                                                       24

                                                                                                                           5.  On page 164 the report concludes that full leasing of the 1002 are.
              needs and the development of energy sources other than fossil fuels. We                                      could significantly reduce the country's dependence on foreign oil.
              realize that this would have been beyond what was technically required by                                    However, previous pages indicated that the United States would continue to
              ANILCA Section 1002, bui it to certainly not precluded by that Act.. We                                      rely heavily on foreign oil despite any possible contribution from the 1002
              think that the assessment would have been more meaningful If this had been                                   area. Also, in reference to Table VII-2 on page 162 we see that under full
              done. Our specific problems are as follows.                                                                  teasing the 1002 area would, if mean resource estimates prove correct,
                                                                                                                           contribute at beat less than 5% of U.S. oil demand. In terms of oil imports
              1. Throughout this chapter the analyses presented use the mean conditional,                                  it would be just over 8%. We don't see how these figures can be termed
              economically-recoverable estimate of 3.23 BBO. The probability associated                                    "significant" by anyone-9 definition.
              with this estimate is only 40%. We believe this has resulted In
              unrealistically high predictions of possible benefits as described in this                                   6. Also on page 164 the report states that oil produced from the 1002 area
              chapter. The report should have at least presented alternative figures                                       would enhance national security. Under the proposed development scenario,
              based on the most reliable estimate at the 95% probability level. Otherwise                                  oil from the 1002 area would only be as reliable as the Trans-Alaska
              the data presented are misleading.                                                                           Pipeline System.   America does have highly effective military forces, yet
                                                                                                                           even they might be hard put to defend the 800 mile length of the pipeline.
              2. On page 161 the second to last    paragraph, first column states that                                     one well-placed bomb or cruise missile, or even land-based sabotage, could
              geologic conditions are "extremely   favorable for major discoveries."                                       effectively eliminate this source of energy very early on In any conflict.
              Perhaps the authors of this section have access to information that is                                       If oil is needed for national security, it is difficult to understand why
              missing from Chapter III; we don't believe that chapter supports such a                                      additions to the Strategic Petroleum Reserve have been halted.      It seems
              conclusion as it now reads. one of the most expensive dry*holes ever                                         like now is the time to make such additions in the Interest of national
              drilled was in Arctic Alaska, in an area with a predicted 70Z chance of                                      security, when oil prices are low and foreign oil Is available.
              finding economically recoverable oil. The chance for this in the 1002 area
              is 19%.                                                                                                      7. We note that the report states on page 165 that oil production from the
                                                                                                                           1002 area could reduce the foreign trade deficit by just over $8 billion In
              3(a). On page 163 several statements in the left column support the concept                                  the year 2005.   Presumably this figure to based on the Inflated $33 per
              that the nation's (and by inference, the world's) oil reserves are finite                                    barrel price of  oil used elsewhere In the report. Predictions should also
              and will probably be exhausted In the not too distant future. The figures                                    be made using a  $20 per barrel price or other lower and more realistic oil
              of 9 to 30 years are given for exhaustion of known reserves.      In light of                                prices. The report doesn't project what trade deficits or oil prices will
              this it would be appropriate for the report to acknowledge that If the 1002                                  be in 2005, but it does state the deficit will likely increase from its
              area contains any oil at all. it.would only be a short-11ved supply. and not                                 present level. The report gives the 1984 deficit as $123 billion. If the
              very significant at all in terms of solving our long-range energy problems.                                  trade deficit in 2005 to not any more than this, which is not likely, the
                                                                                                                           reduction from oil production on the 1002 area will only amount to about
              (b) The third paragraph in the right column on page 163 contains a key                                       6.52. Realistically, It might be somewhat less than this.
              statement as to why we believe that the oil industry Is so intent on getting
              into the 1002 area. The fact that all of the known promising onshore areas                                   8. Table VII-4 on page 165 falls to take into account the potential effect
              have already been explored for oil makes the 1002 area that such more                                        of land exchanges inside the 1002 area. These exchanges have been under
              attractive; offshore exploration and-development are expensive. We believe                                   negotiation for years, and draft agreements currently exist. Above the
              that the "forbidden fruit" concept may be at work here and that it is                                        Table It to noted that if non-Federal subsurface areas are leased by others,
              serving to Inflate ideas about the real oil potential of the area. That                                      then portions of bonus, rent and royalty income shown as Federal revenue
              appears to be obvious when one looks at the Secretary's recommendation in                                    will accrue to others. Although this statement referred to the potential
              comparison to the dats@contatned in the report.     if an area's untapped                                    teasing of selemically mapped structures off-refuge, it remains true for
              energy potential were sufficient reason for developing it, then Yellowstone                                  lands traded out of federal ownership inside the 1002 area. Thus. under
              National Park would be a geothermal energy project and Grand Canyon National                                 what now appears to be the most Ilkley scenario If the 1002 area is
              Park would be a hydroelectric project. Commitments to preserve areas like                                    developed, significantly smaller amounts of revenue will accrue to the
              these (including the Arctic NWR) in their natural states have been made by                                   federal government because of land exchanges.
              the American people repeatedly in the past. Continuing to preserve these
              areas is a reaffirmation of that commitment.                                                                 9. We note, to the report writers' credit$ that in the first paragraph on
                                                                                                                           page 166-it to acknowledged that the coastal plain's economically
              4.   The answers to our long-range energy needs will be found only in                                        recoverable estimates are speculative and not very precise. The conclusion
              looking at a broad range of sources and technologies, in addition to the                                     to Chapter VII goes on to state that "Only actual exploration can provide
              implementation of effective energy conservation measures. On page 164 the                                    the information needed to determine the extent and distribution of the
              second paragraph focuses only on fossil fuel energy sources.      In this regard                             resources, and, therefore, the potential benefit to the economy." This
              the-report is extremely short-sighted. Also in this paragraph, what is                                       seems to provide a logical basis for the next chapter, the Secretary's
              meant by "long-term energy supplies"? Thirty years until the oil runs out                                    Recommendations. However, the advice was not heeded, as review of that
              isn't a very long time.                                                                                      chapter shows.

                                                                                                                                                                   26
                                                      25

                                                                                                                                this as part of the justification for recommending full leasing. This
                SECRETARY'S RECOKKENDATION                                                                                      statement ignores information presented in Chapter V of the report which
                                                                                                                                predicts major impacts on the Porcupine Caribou Herd and other species from
                                                                                                                                full leasing of the 1002 area. Information included on page 108 of the 1002
                We do not agree with the Secretary's Recommendations presented in Chapter                                       report itself describes Important differences between the two caribou herds,
                VIII. The recommendation does not appear tu be based on the information                                         and reasons why conclusions based on comparisons of the two herds cannot
                presented in the report, nor does It appear to be compatible with refuge                                        always be relied upon. On page 169, the Secretary oversimplifies the
                purposes as defined in ANILCA.     Bearing in mind the purposes for which the                                   situation. The Central Arctic Herd is much smaller than the Porcupine Herd
                Arctic National Wildlife Range, and later Refuge, was established, we urge                                      and has available to it much more extensive potential calving areas than
                that the Secretary's Recommendation be rewritten to favor protection of the                                     does the Porcupine Herd. We could go on with this discussion of impacts to
                area's wilderness and wildlife resources over environmentally destructive                                       caribou, but it has already been treated elsewhere, and we refer the reader
                development. To fulfill his obligations as guardian of our wild lands, the                                      to that source (Elison et at. t986).
                Secretary of the Interior should recommend wilderness designation for the
                1002 area.                                                                                                      3(a) On page 170 the second paragraph presents an elaborate scenario for
                                                                                                                                developing and offering lease sales in the 1002 area. It sounds like a lot
                Our specific observations regarding the Secretary's Recommendation are as                                       of effort for an area that the DOI Is already making extensive plans to
                follows:,                                                                                                       trade away to private entities.

                1. (a) The first paragraph on page 169 is highly misleading.         It states                                  M The statement "Development must result in no unnecessary adverse
                that the 1002 area has been predicted to contain as much as 29 BBO but fails                                    effects, and unavoidable habitat losses should be fully compensated", to
                to mention that the probability associated with this prediction is only 5%.                                     found on page 170 and in Assistant Secretary Horn's cover letter to the 1002
                The failure to mention probabilities or to take them into consideration in                                      report. This to not only vague and contradictory, but has no bearing on
                the recommendations is highly deceptive, as is the failure to state that 29                                     reality (legislative, administrative, or otherwise).        It seems like
                BBO is the highest figure predicted relative to oil in place. To be                                             unavoidable habitat louses would be unnecessary adverse effects.           Please
                accurate and informative, the Secretary should mention here that even If                                        explain what the words "unnecessary" and "compensated" mean in the quoted
                there are 29 BBO in place, the amount that could be recovered would be a                                        sentence. What standards will be used to define what "necessary adverse
        9       much smaller figure.                                                                                            effects" are?
        Ea
                (b) The second paragraph on this page states that the coastal plain could                                       (c) ANILCA Section 304(b) reads:        "...the Secretary may not permit any use,
                make a significant contribution to the economy.and security of the nation.                                      or grant easements for any purpose      ... unless such use (including but not
                again with no accounting for the probabilities associated with the oil                                          limited to any oil and gas leasing      ... ) or purpose is compatible with the
                estimates. This statement is not based on information gathered through a                                        purposes of the refuge." Does the       1002 report make such a compatibility
                careful reading of the report, nor Is it based on a realistic evaluation of                                     determination?    If so. where in the report can it be found?       If not, then
                the national and international situation. This paragraph also states that                                       how can the Secretary propose.full leasing without first determining
                development of the 1002 area could occur in an environmentally sound manner.                                    compatibility? Given the purposes for which the Arctic National Wildlife
                For reasons stated and documented in our comments relative to the Executive                                     Refuge was established under ANILCA Section 303, and the 1002 report's
                Summary section, we emphatically disagree with this statement.                                                  admission that many adverse Impacts will be unavoidable under a full leasing
                                                                                                                                program, we submit that full leasing cannot possibly be compatible with
                (c) The third paragraph makes several statements that are not        at all                                     refuge purposes.
                supported by the text of the report, in particular the text of       Chapter 111.
                By not basing the recommendations on the report, the Secretary       demonstrates                               5. The report fails to consider       the cumulative impacts on coastal plain
                extreme negligence, which amounts to a gross misuse of the government funds                                     resources from other activities,      such as possible oil development in Canada,
                spent in conducting years of baseline studies and doing the geological                                          on adjacent state lands and offshore.       Development of the Arctic Refuge
                analyses.                                                                                                       coastal plain will most Likely lead to development of these other areas,
                                                                                                                                thereby ensuring that cumulative impacts occur. The federal government has
                (d) This page goes on to paint an incredibly gloomy picture of the nation's                                     already sold offshore oil and gas leases in the Beaufort Sea, and the State
                energy future. And then it proposes to destroy the last area of the Alaskan                                     currently plans to conduct two lease sales in waters offshore of the refuge
                North Slope that could be preserved as wilderness, in exchange for a meager                                     in 1987 and 1988.     It is highly likely that additional infrastructure within
                supply of oil that would be a stop-gap measure at best in providing for that                                    the 1002 area would be required to support future exploration and
                energy future. This indicates irresponsibility on the part of the person                                        development activities in these other areas.         Failure to consider these
                who Is supposed to be the chief steward of this country's natural resources.                                    cumulative impacts makes the environmental impact evaluations in the report
                                                                                                                                less realistic.
                2. In the last paragraph on page 169 the recommendations make reference to
                the fact that the Central Arctic Caribou Herd population has Increased                                          6. The report fails to consider some of the other more widespread,
                substantially since oil development began in the Prudhoe Bay ollfield, using                                    insidious impacts that would result from burning of the fossil fuels that

                                                          27                                                                                                               28

              might be produced from the refuge.    Jhese include decreased air quality,                                    h) Wilderness review, mandated under ANILCA Section 1004, has not been
              with attendant disease and, In some cases, death.      It is estimated that as                                conducted
              many as 50,000 deaths occur each year in the U.S. as a result of fossil       fuel                            In conclusion, the NAEC finds the 1002 report to Congress extremely
              pollutants (USOTA 1984 as cited.in Postal 1986). Combustion products of
              fossil fuel are known also to be a majoi contributor to the global                                            disappointing. We fail to see how the Secretary's recommendations are
              atmospheric increase in carbon dioxide and other compounds, which are                                         supported by information contained in the draft 1002 report If one considers
              predicted to begin producing some major climatic changes and other adverse                                    the important wildlife and wilderness values of the Arctic NWR coastal
              effects on human health, food production, and forests during the early part                                   plain. the predicted impacts of oil and gas development there, and the very
              of the next century (Mercer 1978 as cited in Hayes t978, Postel 1986).                                        limited contribution that the coastal plain could ever be expected to make
                                                                                                                            to the country's energy resources. Under these conditions, we do not see
              7. We are particularly disappointed that the report does not bring into its                                   how it could ever be In the best interest of this country to destroy the
              consideration of the nation's energy future alternatives to this country's                                    coastal plain's surface in what might be a vain quest for non-renewable
              futile reliance on fossil fuels which will someday be expended. Such                                          resources. Therefore, we believe Alternative E. Wilderness Designation, Is
              consideration would have been widely regarded as a progressive step into the                                  the most prudent and meaningful course in this matter, and we urge the
              future. In Menzies (1978)(as cited in Hayes 1978), Robert Donahue. then                                       Secretary to alter his recommendations accordingly.
              Vice Chairman of Sun Oil Company, was quoted as saying, "We are in a
              business that is dying." Some new source or sources of energy will be                                         We feel that a near total rewrite of the draft 1002 report to necessary, due
              required to fill the gap; that is inevitable. It has been predicted that by                                   to the broad extent and serious nature of the problems we have outlined.
              2025 as much.so 75Z of the world's energy could be obtained from solar                                        The language in AMILCA mandates that this report contain the information it
              sources (Hayes 1977). Hayes (1977) states that "Every essential feature of                                    now lacks before it can be presented to Congress. Our comments in this
              the proposed solar transition has already proven technically viable; if the                                   letter indicate in detail what that Infornaton in. We took forward to
              50-year timetable to not met, the roadblocks will have been political -- not                                  seeing your responses to our concerns.
              technical." By disallowing oil development on the 1002 area, the federal                                      Sincerely,
              government would be helping in a small way toward speeding this transition,
              while at the same time preserving one of the world's soot significant
              wildli fe and wilderness areas.

                                                                                                                            Kate Pendleton
              SUMMARY AND CONCLUSION                                                                                        Associate Director

              Our major problems with and objections to the 1002 report in its present                                      cc: Non. Ted Stevens
              form are:                                                                                                         Ron. Frank Murkowski
                                                                                                                                Ron. Don Young
              a) The report fails to consider cumulative impacts to Coastal plain                                               Governor Steve Cowper
              resources                                                                                                         Secretary Donald Model
                                                                                                                                Assistant Secretary Bill Horn
              b) Proposed sitigation'sessures are likely to be largely Ineffective                                              Regional Director Bob Gilmore
                                                                                                                                Refuge Manager Glenn Elison
              c) Possible effects of contaminants and hazardous wastes on coastal plain                                         other environmental groups
              populations and habitats are not adequately addressed

              d) The magnitude of activities and facilities thatwill be necessary for a
              full leasing and production program are not adequately portrayed

              a) Possible sources and Impacts of air, water and noise pollution are not
              addressed

              f) The report fails to consider the potential effects of land exchanges
              that are currently being negotiated for the 1002 ore*

              g) The Secretary's recommendation for full oil and gas leasing not only
              violate@ FWS mitigation policy but to contrary to all of the purposes for
              which the refuge was established under ANILCA Section 303

                                                      29                                                                                                         30

    		REFERENCES

    Abbey, E. 1984. The last pork chop. outside 9(2):51-86.

    Bliss, L.C. and K.M. gustafson. 1981. Proposed ecological natural
    landmarks in the brooks range, Alaska. U.S. Dept. Inst., Heritage Cons. Rec,
    serv. 175pp

    Brower, K. 1971. Earth and the great weather--the Brooks Ragne. Mccall
    publ. CO., new york, 188pp.

    Chadwick, D. 1979. Alaska's Arctic National Wildlife Range--out wildest
    wilderness, Nat. Geogr. Mag. 156(6):737-769.

    Collins, G. and L. Sumner. 1953. Northeast arctic--the last great
    wilderness. Sierra CLub Bull., 38(8):13-26.

    Dahlgren, G., Jr. (ed.) 1962. Arctic National Wildlife Range Symposium.
    proc. 12th Ak. Sei. conf. 12:31-72

    Elison, G.W., A.G. Rappoport, and G.M. Reid. 1986. Report of the caribou
    impact analysis workshop, Arctic Natinal Wildlife REfuge, November 19-20
    1985, U.S. Dept int. Fish Wildl. Serv., Faribanks. 39pp.

    Hayes, D. 1977 Energy: the solar prospect. Worldwatch paper 11,
    worldwatch institute, Washington, D.C. 79 pp.

    Hayes, D. 1978. The solar energy Timetable. Worldwatch paper 19,
    worldwatch institute, Washington, D.C. 40pp.

    Kerasote, T. 1984. Across arctic muntains, parts I and II sports
    afield 193(2): 76-114 and 193(3):58-144.

    Laycock, G. 1976. Our last arctic wilderness--a gift denied audubon
    78(4):80-102.

    Menzies, H. D. 1978. why sun is educating itself out of oil. Fortune
    February 27, 1978.

    Mercer, J.H. 1978 . West Antarctic lee sheet and CO2 greenhouse effect: a
    threat of disaster. Nature, January 26, 1978.

    Milton, J.P. 1969. nameless valleys, shining mountains, walker and co.,
    New york. 195pp.

    Murie, M.E. 1978. Two in the far north. Ak. Northwest Publ. co. 385 pp.

    Postel, S. 1986. alturing the earth's chemistry: assessing the risks.
    worldwatch paper 71. Worldwatch Institute, Washington, DC. 66 pp.

    Spencer, D.L. C. Naske, and J. Carnaham. 1979. National Wildlife refuges
    of Alaska--a historical perspective, Part I. U.S. Dept int., Fish wildl.

    31

    Serv., Anchorage. 183 pp.

    Stenamrk, R.J. and T. H. Schoeder. 1974. Recreation and preservation
    opportunities--arctic region resources inventory. Joint Fed. st. Land
    use plan. comm, Res. paln. to. 83 pp.

    Sumner, L. 1956. your stake in Alaska's wildlife and wilderness. Sierra
    club bull. 41(10):34-71.

    Tall, B. 1959. Our last wilderness. Science Newsletter. 76(9):154-155.

    Thayer, A. 1982. Wilderness evaluation of 1002(c) area. Memorandum to
    Refuge Manager, Arctic nwr. U.S. Dept. Int., Fish Wildl, Serv., Fairbanks.
    3 pp.

    U.S. Fish and Wildlife Service (USFWS). 1973. Arctic Wilderness study
    report. unpubl. manu., U.S. dept. Int., Fish wildl. Serv., Fairbanks. 94
    pp.

    USFWS. 1078. Draft environmental impact statement, proposed arctic
    Wilderness, Alaska. Unpubl. Mnau., U.S. Dept. Int., Fis Wildl. Serv.,
    Washington, DC. 69 pp.

    USFWS 1986. Final report baseline study of the fish, wildlife, and their
    habitats. U.S. Dept. Int., Fish Wildl. Serv., Anchorage. 695 pp.

    U.S. office of Technology Assessment (USOTA). 1984. Acid rain and
    transported air pollutants: implications for public policy. U.S. off. tech
    Asset., Washington, DC.

    32

    		NORTHERN ALASKA ENVIRONMENTAL CENTER
    			218 DRIVEWAY
    		FAIRBANKS, ALASKA 99701
    			(903) 452-5021

    	January 5, 1987

    Statement of Randall R.Rogers, executive director, northern Alaska
    environmental Center, before the U.S. Fish and WIldlife Service on the
    Arctic Natiional wildlife REfuge, Alaska, Coastal Plain Resource Assesment

    	Originally founded in 1971, the Northern Alaska Environmental Center
    is the northernmost conservation proganization in the united States. We have
    a memberhsip of over 700 persons living both within and outside the state of
    Alaska. The Northern center is dedicated to the protection of public lands
    and waters of arctic and interior Alaska.

    	The flaws in the reasoning and conlusions of the draft 1002 report
    are much to numerous to be adequately dralt with three minutes of verbal
    testimony. which was the occured time throught we had. The Northern center
    will provide detailed written comments on
    the draft report prior to the closing of the public comment period.

    	We are extremely perturbed at the Department of interior's attempts
    to keep the voices of the Alaskan public out of the decision on the coastal
    plain of the Arctic Refuge. It is dispicable that a public agency would go
    to such great lengths to avoid the involvement of the american people.

    	We would not be here today if it were not for a court order forcing
    the Department to provide for public involvement. Even with this court
    order, interior has refused to conduct hearings in Fairbanks and Arctic
    Village, two of the communities who wil be most affedcted by the final
    decision, we can only speculate that the decision to avoid a hearing in
    Fairbanks was based on the U.S. Fish and wildlife service's Knowledge that
    residents of Fairbanks are deeply concerned with the ecological integrity of
    the Arctic Refuge. We do not believe it was simply a burrocratic oversight
    that the people of Fairbanks have been demind the opportunity to voice their
    concerns on the draft 1002 report.

    	The northern Alaska Environmental center supports Alternative E,
    which recommends wilderness designation of the entire 1002 area.
    Information provided in the draft 1002 report does not justify the proposal
    for full leasing of the coastal plain. In fact, it appears that this
    recommendation is based largely on political motivations to promote the oil
    industry, rather than the data derived during the coastal plain resource
    assessment.

    page 1

                                                                                                                                        The report bases its arguments on the national need for oil on
                                                                                                                               unrealistically high oil prices of $33 par barrel Andostimatiis of
                        The environmental effects of oil development in the coastal can be                                     in-place oil with low percentages for probability of occurance.          If the
                                                                                                                               report used realistic oil price assumptions and relitil on estimates of
                summarized by one quote from the report.                                                                       in-place oil with high probabilities Jor"Foccurance, strong arguments for
                          'Long-term losses in fish and wildlife resourceso                                                    the national need for oil could not be madio.
                          subsistence uses and wilderness values would be the                                                           in facto if one looks solely at the e     .conemic factors in
                          inevitable consequences of a long-term comottment to oil                                             considering the fate of the Arctic Refuge coastal plain, it does not
                          and gas developmentl production.and transportation.'                                                 Make Sense to MoVer'orward with full scale lt&sing. At a time when
                        A major flaw of the report is its failure to consider the                                              existing oil fields in Alaska and other parts of the nation are shutting
                                                                                                                               dcwn production we should not initiate leasing of a field which, in all
                cumulative impacts from other activities on coastal plain resources.                                           liklihood, is no larger and
                The 4ederarl government has already sold offshore oil and gas leases        in                                                                      in one (if the most environmentally
                the Beaufort Sea, and the State is proposing to conduct two least sales                                        sensitive areas of North America.
                in the water% offshore of the rtfucie in the near future.       This failure                                            14 le'ases are sold In the 1002 area during this time o4 low oil
                to coniodor these cumulative impacts makes the environmental impact                                            prices the only beneficiaries will be the multi-national oil companies
                evaluations in the report less realistic.       In addition, mitigation                                        Alaskans and all americans who might benefit from oil least revenues
                measures proposed in the report represent wishful thinking at best and                                         will see only a minimal return while jobs associated with actual
                do not realistically assure protection of biological resources. r                                              production will not be rtalized until oil prices rise adequately for @kf_
          9.            The hiah oil and Gas DDt@ntiAl for the area that is described In                                       oil companies to reap huge profits with little cost.
          -A    the executive summary art not supported by the taxi of the report.                                                      In summary, we urge the Department to consider the values for
          01    Reasons for this observation includet                                                                          wl@ich the Arctic Refuge was established and recommend Me best mechanism
                                                                                                                               available to protect those values, namely, wilderness designation of the
                a.  The report states that there is only a l5r/ chance      of there being                                     'coastal plain.
                economically recoverable,oil in the 1002 area.       We do  not see this I     in
                5 chance of discovering oil as very good odds for risking damage to the
                internationally significant wildlife and wilderness resources of the
                refuge.

                b. In several places in the report, the proximity of the area to
                Prudhoe Bay is cited as an encouraging factor. The report states          that
                most of the Prudhoe Say production is from Ledge Sandstone rocks of the
                Ellesmerian sequence.    It is also stated that these rocks are,likely
              -aaa-existant in the 1002 area.

                C. Page 66 of th  V report  states that the two largest prospects account
                for the majority of the estimated in-place oil. Yet it is &I" stated
                that these prospects are dependent on the priosence of Ellesmerian rocks
                as reservoirs. Once again, the report states that those types of rocks
                are not likely present in the 1002 area.

                d.   On page 54 the report states that if Ledge Sandstone rocks are not
                prosentg then the chances of oil being present in the area are much
                reduced. These rocks are cited as being the major possible source rocks
                for oil production in the area, but their existence in the area is
                uncertain. The report states that 'Drilling one or two wells in
                critical areas would resolve this question.* Yet, the report recommends
                full leasing!   This recommendation is not logical and prudent
                considering the predicted environmental constquencos of full leasing.

                                                      (page 2)
                                                                                                                                                                      (page 3)

                     PACIFIC Iff@/Nl-
                     FOUNDATION                                                                                                INTRODUCTION
                                                                                                              Pacific Legal Foundation is a nonprofit public interest

                                                                                                    law firm based in Sacramento, California, with a branch office in

                                                                                                    Anchorage, Alaska. PLF has over 19,000 supporters throughout the

                                                                                                    United States and has the primary purpose of litigating in the

                                                                                                    public interest in defense of individual freedoms, private

                                                                                                    property rights, and the free enterprise system. PLF has

                                                                                                    extensive experience in the field of natural resource ani

                                                                                                    environmental law and the issues surrounding natural resource
                           COMMENTS OF PACIFIC LFGAL FOUNDATION
                          ON THE DRAFT ARCTIC NATIONAL WILDLIFE                                     development. Because the disposition of the Arctic National
                    REFUGE, ALASKA, COASTAL PLAIN RESOURCE ASSESSMENT
                                                                                                    Wildlife Refuge (ANWR) coastal plain is of great national

                                                                                                    significance, PLF is submitting these comments for the purpose of

                                     February 3, 1987                                               discussing the draft report. PLF believes that the report fully
       9
       CA)                                                                                          complies with all legal requirements and addresses all issues

                                                                                                    necessary under law. PLF also concludes that the report's

                                                                                                    recommendation for congressional action that would allow the

                                                                                                    leasing of the coastal plain is supported by the facts and is in

                                                                                                    the national interest.

                                            RONALD A. ZUMBMJN                                                                        I
                                            ROBIN L. RIVETT
                                              Pacific Legal Foundation                                                    THE FISH  AND WILDLIFE
                                              555 Capitol Hall, Suite 350                                                  SERVICE  HAS DONE AN
                                              Sacramento, California 95814                                             ADMIRABLE JOB IN ENCOURAGING
                                              Telephone: (916) 444-0154                                          PUBLIC COMMENT ON THE ANWR COASTAL PLAIN

                                            JAMES S.-BURLING                                                  Although some controversy existed over whether or not
                                              Pacific Legal Foundation
                                              807 G Street, Suite 200                               public comment had to be solicited during the preparation of the
                                              Anchorage, Alaska 99501
                                              Telephone: (907) 278-1731                             ANWR coastal plain report, PLF believes that the level of public

                                            Attorneys for Pacific                                   participation in the review of the draft report fully satisfies
                                            Legal Foundation
                                                                                                    all legal requirements. The hearings in Anchorage, Katovik, and

              Washington, D.C., were all very well attended, and it was obvious                          studied a11 potential significant environmental consequences that
              that the interested public had ample notice and was fully aware                            might result from exploration activity.
              of the hearing process. It is especially noteworthy that the                               A. Cumulative Effects"
              hearings in Katovik, Alaska, were well attended by Inca    .I native                                 It is.especially important that the scope of the
              individuals and associations who were able to express their                                proposed report and its recommendation for congressional action
              concerns, support, or opposition to the recommendation of                                  be put into perspective when determining exactly what should be
              congressional action for leasing   Ithe ANWR coastal plain. Since                          included in the final report. For    example, it was,suggested at
              Katovik will be thecommunity most affected by any oil and gas                              the Anchorage hearings that the draft plan failed to address     the
              exploration or leasing activity, the participation of Katovik                              cumulative impacts* of a whole menu of activities in the'
              residents was crucial to the fulfillment of the public                                     arctic. in other words, the commentator believed that the
              participation requirement. In addition to this evidence of                                 coastal plain report should have assessed every development
              compliance, it is to be expected that many other individuals and                           activity, actual and proposed, anywhere in the same general
              organizations are participating with written comments. In                                  arctic geographic region. The draft plan, however. was
        R     conclusion, allegations made by some groups of inadequate public                           completely correct  in limiting Its study to those activities.
        -4    hearings are totally unfounded.                                                            having some rational bearing to the   range of proposals  found   In
                                                                                                         the plan. otherwise, there would literally be no end to the
                                THE DRAFT REPORT  HAS CONSIDERED                                         scope, detail, complexity, and expense to the study; and there
                             FULLY, TO THE EXTENT REQUIRED BY LAW,
                             THE POTENTIAL ENVIRONMENTAL EFFECTS OF                                      certainly would be no way it could be completed in an efficient
                              EXPLORATION ON THE ANWR COASTAL PLAIN
                                                                                                         and timely manner.. When Congress directed Fish and Wildlife to
                         After reviewing some of the oral testimony   given at the
                                                                                                         prepare the report It ordered that the coastal plain be studied,
              .Anchorage hearings on the ANWR coastal plain report,    PLF is award                      not the .entire arctic geographical region. More importantly,
              that certain criticisms have been leveled against the draft
                                                                                                         there is no legal justification for extending the scope of the
              report involving an alleged failure to adequately study certain                            report beyond that which is the subject of the report--the
              Potential environmental consequences of exploration on the                                 coastal plain and the study's action alternatives including
              coastal plain. PLF believes that these allegations are baseless                            congressional act.ion to permit leasing.
              and that the Fish and Wildlife Service has more than adequately                                      Statutory and case law requires a discussion of
                                                                                                         .cumulative impacts" in only two situations. The first is where

                                                 2                                                                                         3

             an agency is proceeding according to a programmatic or regional                         extent will be.   When there are actual leiasing proposals on the

             plan, as when a proposed activity is merely a segmented part of    a                    table, then and only then will it be appropriate to study the

             larger action.  For example, the construction of a forest road                          "cumulative effects." For these reasons, the report properly

             cannot be considered in isolation from a timber harvesting plan                         confined its discussion to potential environmental consequences

             when that road is designed solely to facilitate the timber                              germane to the proposal for congressional action, namely the

             harvesting plan. Therefore, a discussion of the environmental                           actual leasing of the coastal plain.

             impacts from the road construction must also consider the related                       0.   More Study"

             timber plan.  The second instance in which cumulative impacts                                      Some commentators have suggested   that "more study" is

             must be discussed is where a specific proposal for an activity                          required before the Congress can make a reasoned decision on the

             simply cannot be considered in isolation from other similar or                          leasing of the coastal plain.    This is untrue. The draft    report

             related activities in the same specific area.                                           is fully complete and contains all the data necessary for

                       Neither circumstance is present here and there is no                          Congress to make an informed decision.    It appears that the call

             need to study additional "cumulative impacts." The secretary's                           more study" is nothing more than a thinly disguised attempt to
        9
        (A)  proposal for Congress to facilitate leasing Is in no way related                        delay the project into oblivion. The nation needs to begin today
         L
        OD   to any other actual or proposed activity in the arctic. There is                        the exploration for more oil reserves because production will

             absolutely no connection between the recommendation for                                 take -years to implement after a discovery is made.    As domestic

             congressional legislation and oil activities to the west on the                         reserves decline, the need for future reserves will become

             North Slope, or anywhere else. There to most certainly no                               imperative.   If the needless call for more study is heeded, we

             relationship to any activities in Canada.                                               will probably study ourselves right into another and more serious

                       Furthermore, the recommendation for congressional                             oil shortage.   More to the point, the critics of oil exploration

             legislation will not result in any immediate leasing activity or                        have submitted no compelling arguments for more study. The

             environmental effects.  Before any leasing commences after                              coastal plain region is one of the most studied environments in

             appropriate legislation there still must be a comprehensive                             the world.

             environmental review.   It is at this review stage where                                           Indeed this is not the first time calls for more study

             cumulative effects, if any, should be considered. Otherwise, the                        have clouded the picture in the ANWR. When the Alaskan Arctic

             report will simply be far too speculative to be of any value.     It                    Gas Pipeline Company began the process for building a gas

             is too soon to tell where leasing will be proposed and what its                         pipeline, an exhaustive series of environmental studies were

                                            - 4 -                                                                                    - 5 -

              initiated. Despite objections that the sturlies were Inade(late,                       plain. This could very well be a substantial boost to the
              .the Federal Energy Regulatory Commission conclusively determined                      support industries.   For example. between 1980 and 1986 a total
              that pipeline construction could be compatible with environmental                      of $10,536,000,000 North Slope oil development dollars were spent

              values in the Arctic National Wildlife Refuge.                                         In the United States, of which $9.18 billion were expended in the

                        However there is one area of uncertainty that still                          lower 48.  In the State of California alone, over $1.8 billion

              must be resolved.  Despite a plethora of geophysical and                               was spent through the oil support industries on North Slope

              geological surveys, it is still not known how much recoverable                         production. It the exploration of the coastal plain commences
              oil may lie under the coastal plain. The only way this                                 there will be great direct economic benefits to all other states,

              information can conclusively be discovered is for exploratory                          and, if the exploration is successful, there could be a boost to
              drilling to commence. Therefore. the secretary's proposed                              the lower 48 economies to match that provided by Worth Slope

              recommendation for congressional action to facilitate leasing is                       production.  This sort of private sector economic development

              highly appropriate.                                                                    should be strongly supported. Adhering to,the secretary's

                                              III                                                    recommendation will help achieve this goal.

                                 THE ECONOMIC BENEFITS OF OIL
        -4                 LEASING WILL INURE TO THE ENTIRE NATION
        (0
                        The draft ANWR report accurately reports that the

              economic benefits from the development of the coastal plain will

              benefit the nation by helping to avoid future shortages, reducing

              our dependency on foreign oil and foreign pricing structures, and

              improving our balance of trade. A further economic advantage

              that should be considered is the tremendous economic benefit to

              the lower 48 states that will result from a major exploration

              effort on the ANWR coastal plain. The infrastructure and

              expertise required to take advantage of leasing opportunities on

              the coastal plain will not all be supplied by Alaska. instead,

              the now severely depressed oil exploration industry of t1he lower

              48 will be called on to help explore and develop the coastal

                                               6                                                                                      7

                                        CONCLUSION

                      The draft ANWR coastal plain report is an important and

            well designed document. It accurately portrays the potential

            economic benefits that will arise if the recommendation for

            congressional action Is adhered tn. All relevant potential

            environmental consequences are addressed as well. The report

            fully complies with legal requirements, and its recommendations

            should be supported.

                      DATED: February 3, 1987.

                                           Respectfully submitted,

                                           RONALD A. ZUMBRUN
                                           ROSIN L. RIVETT
                                           JAMES S. BURLING

                                           BY       3AMES S. BURLING

                                           Attorneys for Pacific,/
                                           Legal Foundation

                                            8

    		Renewable Resoruces Inc.

    Director
    U.s. Fish & Wildlife Service
    Division of Refuges
    U.S. Department of Interior
    room 2343 Main Interior Building
    18th & C streets
    Washington, D.C. 20240
    U.S.A.

    Dear Sir:
    Re: ANWR Coastal Plain Resource Assessment
    Enclosed are review comments on teh subject Draft EIS. I have also
    enclosed an unpublished paper which is cited in teh review.

    Sincerely Yours,

    Renewable Resources Inc.

    R.D. Jakimchuck
    President
    RdJ/ir
    enc.

    A EVIEW OF THE REPORT ON THE ARCTIC NATIONAL
    WILDLIFE REFUGE COASTAL PLAIN RESOURCES ASSESSMENT

    PREPARED BY

    R.D. Jakimchuk and L.G. Sopuck

    of

    Renewable Resources, Inc.

    for the
    Alaska oil and gas Association

    January 1987

                                                                                                           1.0 INTRODUCTION

                                        TABLE OF.CONTENTS
                                                                                                                    The purpose of this report is to review the
                                                                            Page                           terrestrial wildlife port  ions of the U.S. Secretary o  If the

                                                                                                           Interior's 1002(h) report concerning oil'development in the
               1.0 INTRODUCTION    .......................................    I
                                                                                                           Arctic National wildlife Refuge (ANWR) in northeastern Alaska.
               2.0 ADEQUACY OF THE DATA BASE     ..........................   1
                                                                                                           Our approach was to assess the.adequacy of the data base used
               3.0 MAJOR ISSUES FOR THE PORCUPINE AND CENTRAL ARCTIC
                                                                                                           to describe resource values and te predict impacts. We then
                    IIERDS  ..............................................    5
                                                                                                           determined whether the data Uase was used in an objective and
                 3.1 The Displacement Issue     ...........................   6
                                                                                                           scientifically-sound manner to predict impacts and recommend
                 3.2 The Insect Relief Habitat Issue     ..................  11
                                                                                                           appropriate mitigative measures.. Following sections provide
                 3.3 Mitigation    .......................................   12                            periodic reterence to Appendix I which is a list of specific
               4.0 OTHER SPECIES    ......................................   15
                                                                                                           comments keyed to Chapters It and VI of the 1002 report.
               APPENDICES,*,*********  ...                                   19                            Appendi.x I should be consulted for additional and more specific
               LITERATURE CITED  ........................................    32                            comments.

                                                                                                           2.0 ADEQUACY OF THE DATA BASE

                                                                                                                    The wildlife resource and impact assessment     sections

                                                                                                           of the 1002 report often contain unreliable statistics and
                                                                                                           poorly referenced and unqualified statements. Conclusions are

                                                                                                           often based on uncritical acceptance of one or two studies or

                                                                                                           on unreliable data bases. In some cases, speculative

                                                                                                           statements are not distinguished from those which are well-

                                                                                                           documented and hence are misleading.

                                                   2                                                                                               3

                          There are several examples in the report of where tire                                site-specific movementand distribution data for the PCH.           The
                 reliability of population data are not addressed.       For example,                           report states that.caribou use riparian areas during spring and
                 the estimate of 180,000 animals for the Porcupine caribou herd                                 summer but does not cite a recent study by Carruthers et al.
                 (PCH) in 1986 is crude because the herd has not been properly                                  (1984a) that shows that females with calves usually avoid
                 censused since 1983 when an estimate of 135,000 animals was                                    riparian habitats.    In addition, the movements and distribution
                 obtained JWhitten, 1986).     However, the uncertainty of the 1986                             of CAH caribou within the 1002 area are described in detail in
                 estimate was not addressed in the report.      The report also_                                the report, yet the movements have been very poorly documented-
                 states that there is a major concentration of Central Arctic                                   to date.   If recent unpublished data were used they-should have
                 herd (CAH) caribou calving on tire Canning River Delta.        This                            been referenced in the report.

                 was based on very limited survey information.       In contrast,
                 more extensive calving ground surveys conducted by Renewable                                             The definition of the    "core calving area" for tire PCh
                 Resources Consulting Serv  .ices Ltd. (RkCS) from 1981@86 show                                 was derived using information obtained from L972-8@. This
                 that the Canning River Delta is not a major calving area, but                                  report refers to this period as the "14-year study".         In fact.
                 that there tends to be a continuum of calving along the coast                                  the data  were obtained from several individual studies and
                 with concentrations between major river valleys (Carruthers et                                 surveys.   During some years (e.g., L973, 1974, 1980),very
                 al.. 1984;   Carruthers and Jakimchuk, 1985;      Sopuck and                                   limited information was obtained on the calving distribution of
                 Jakimchuk, 1986).    These stucies were riot referenced in the                                 the PCH, and even more limited estimates of density.         Yet it

                 text.                                                                                          appears in tire report that the "core calving area" was defined

                                                                                                                based on a solid, 14-year data base.

                          The available data base an the distribution and
                 movements of the PCH and CAH is vastly under-utilized in the                                             In the impact section of the     report. the indirect loss
                 report. The calving distribution of the PCH was studied by RRCS                                of habitat as a result of behavioral avoidance is quantified
                 from 1972 to 1977 but these studies are not cited directly in                                  using a worst-case scenario.      However, based on the studies
                 the report (Jakimchuk   et al., 1974:    Roseneau et al.. 1974:                                conducted to date, it is extremely speculative to predict a
                 Roseneau and Curatolo, 1975, 1976;      Curatolo and Roseneau.                                 "zone of total displacement" around a particular development.
                 1977;  Bente 1977).    However. these   reports contain important                              These speculations are based primarily on one quantitative

                                                   4
                                                                                                                                                   5
                  study, Dau and Cameron (1986).     This.study shows short-4erm                               herd is exposed to TAPS only twice each year, but crosses it
                  partial displacement by maternal groups around an active road                                successfully.    In the dssessment of the impacts of aircraft
                  system, but also shows that caribou responses can be highly                                  overflights on caribou, the report ignores the work by Davis
                 variable. In addition, no quantitative information on how
                                                                                                               et al. (1985). The IOU2 report appears to cite references
                 caribou may habituate to these disturbances is available.                                     selectively rather than presenting a more balanced viewpoint.
                 Habituation over the long term may significantly reduce this                                  Davis et al. show that caribou populations can continue to grow
                  zone of displacement".                                                                       despite sometimes severe harassment from aircraft.and other

                                                                                                               military activities including bombing and strafing within
                           The report presents several statements as fact rather                               traditional calving ranges.
                 than speculation. For example, it is assumed that increased
                .energy demands on individual caribou during the insect relief                                            In summary, the lU02 report does not adequately
                 period will lead to reduced survival and productivity of the
                                                                                                               qualify or reference its conclusions and hence presents an
                 herd.  However, there are no studies on North American                                        unbalanced assessment of impacts.       In many cases, the worst
                 populations of .caribou that have established this link.        Also,                         case scenario for impacts is unjustified.
                 the report  makes the implicit assumption that caribou are a

                 "food-limited" species. Howeveri there are no s.tudies that
                 show that mainland po  .pulations of caribou i n North America    are                         3.0 MAJOR ISSUES FOR THE PORCUPINE AND CENTRAL        .ARCTIC HERDS
                 food-limited. European references are not appropriate because
                 reindeer herds are maintained at artificially high stocking                                             Al though a worst case scenario     is a valid approach to
                 levels in largely predator free systems.                                                      environmental analysis, for significant resources such as the

                                                                                                               PCH it should incorporate the following:
                          The report states that the PCH may have difficulty,
                 accommodating to developments such as pipe    lines because they                              1. - Assumptions should be realistic and properly qualified.
                 will interact with them for short periods during the year.
                                                                                                               2.   The factual basis for analysis should be supported and well
                 However, the report fails to discuss RRCS studies of the                                           documented.
                 Nelchina herd (Carruthers et al., 1984b) which shows that this
                                                                                                               3.   Impact criteria should be well defined and supported6

                                                6
                                                                                                                                          71
               4. Use of the scientific literature should     be objective rather
                                                                                                          critical appraisal of those data and the conclusions of    Whitten
                    than selective.
                                                                                                          and Cameron.  The evidence supports the notion that the    Prudhoe

                                                                                                          area is similar to other deltas in having a low calving    density

                                                                                                          which existed pre-development and that conclusions that    calving
               3.1 The Displacement Issue
                                                                                                          has been displaced from the PBC are unsupportable.

                         The.impact assessment on the PCH is largely based on
                                                                                                                  Because of the contentious and inconclusive nature of
               two studies: Whitten and Cameron (1985) who concluded that
                                                                                                          the Prudhoe Say scenario, the report of Whitten and Cameron
               calving of the CAH has been displaced from the Prudhoe Say area
                                                                                                          .(1985) is not a sufficientl@ strong basis to rely on for the
               since the onset of petroleum development, and Dau and Cameron
                                                                                                          PCH scenario analysis.
               (1986) who reported local displacement of maternal caribou

               along the Milne Point Road. Whitten and Cameron (1985) present
                                                                                                                  Dau and Cameron (198b) present a,far better study
               conclusions based  on anecdotal data.which are largely
                                                                                                          design and basis-for assessing the implications of sensory
               correlations after the fact. Jakimchuk (1986) presents a
                                                                                                          disturbance to the distribution of calving caribou.    Because of
               detailed rebuttal  to.the principal conclusion that calving of
                                                                                                          its importance as the basis for the impact analysis   we have
               the CAH has been displaced from Prudhoe Say. Their own paper
                                                                                                          reviewed that study (Appendix 11) for its relevance    and
               recognizes the possibility of other factors such as floocing
                                                                                                          validity. Several points have emerged from that review which
               which may account  for the lower calving density in the Prudhoe                            a.re important to the analysis for the PCH.
               Bay Complex (POC). Jakimchuk (1986) reviews evidence that
               indicates that the, PBC was not an important calving  .area even                           1. The Dau and Cameron study, although a better design than
               before development  and that the correlations made by Whitten
                                                                                                             previous studies, is not definitive. It documents a
               and Cameron reflect  a calving distribution in response to
                                                                                                             partial avoidance by maternal cows over a period of high
               ,natural influences. However. neither viewpoint can be termed
                                                                                                             disturbance. However its limitations include lack of a
               conclusive because of the post facto correlations which are
                                                                                                             control, and no discussion of conflicting results with Went
               made and the limitations of pre-development data and possible
                                                                                                             Sak Road studies which show no avoidance by calving groups
               comparisons. Jakimchuk (1986) does. however, present a
                                                                                                             along the West  Sak Road.  Their comments on-lack of

                                                                                                             habituation by  caribou to disturbance ate unsupportable.

                        Although Dau and Cameron document   reduced habitat use
                                                                                                         reference is not even cited in the LIS. The analysis of air-
              (i.e., lower densities) by maternal groups    near the road, they
                                                                                                         craft disturbance ignores at least a dozen aircraft disturbance
              did not in fact document displacement which may be defined as
                                                                                                         studies, many of which are more quantitative or relevant than
              an active process of dislocation of caribou from a previously
                                                                                                         those cited.   The gratuitous editorial comment on\   Bergerud et
              used area in response to a stimulus. Further, they do not
                                                                                                         at. (1984) (ref. 41, p. 110, App. 1) as a paper that -is "widely
              comment on the significance of the fact that numbers of calving
              caribou in their stu .dy area almost.doubled between the pre- and                          disputed" indicates a biased   approach to disseit-ing   viewpoints.
                                                                                                         We consider that such an arbitrary dismissal of a major,
              post-development study periods.
                                                                                                         refereed, published paper is unethical.

                        The most significant error of   the scenario analysis
                                                                                                                   Previous sections of this review and Appendix I
              for the PCH is the assumption that what is termed "behavi6ural
                                                                                                         identify  omissions of specific papers relevant to an objective
              displacement" would be total for a 2-mile zone adjacent to
                                                                                                         analysis  of impacts. Another example is omission of Carruthers
              roads using Dau and Cameron (1986) as a    basis for that
              analysis.   A total dis .placement was not found by Dau and                                et at. (1984b) on crossing success of TAPS by the Nelchina
                                                                                                         herd, which has a direct relevance to the question of effects
              Cameron and there is no basis for the assumption of a zone of
                                                                                                         on caribou which only periodically contact a pipeline (ref. 36,
              habitat loss of that magnitude. Moreover, the analysis
                                                                                                         p. 109, App. I). This report is not listed in the bibliography
              unjustifiably fails to discuss the potential for habituation
                                                                                                         of the EIS.
              and is highly selective in use of relevant references. it
              specifically ignores those references which may temper                                               The assumption that displacement from the PCH core
              conclusions pertaining to the adverse eftects of disturbance                               calving area would be co .mplete is not justified on the basis o   If
              and displacement on caribou demography.
                                                                                                         known examples. The further Iiiik to population decline is even

                                                                                                         more speculative. There is inadequate treatment of alternative
                        For example, Davis et at. (1985) report no short term
                                                                                                         habitat use and the potential mitigating effects of
              demographic effects on the Delta herd from displacement from
                                                                                                         habituation. The net result of the foregoing omissions is to
              their core calving area and no adverse demographic effects on
              tlie herd from severe disturbances on the calving grounds.     This                        greatly exaygerate the worst case beyond what can be supported
                                                                                                         on scientific evidence.

                       Although the qualifiers "could be", and "maybe" are,                                    We have given*little attention to the impact
               frequently used in the impact predictions they are not defined.                        assessment of the CAH in this summary and refer the reader to
               The assessment would be enhanced cotisiderably by an objective                         specific notes and comments in Appendix I.   In general,
               risk or probability analysis in order to place predictions in                          projected impacts on tne CAH are highly overstated since 1002
               context with their likelihood of occurrence.                                           developments would impinge on a smaller portion of the herd

                                                                                                      than do existing petroleum developments in the Central   Arctic
                       The analysis of comparative calving densities for                              region.
               various herds has been linked to the vulnerability of the PCH

               to population decline if displacement occurs because of its
               higher calving densities.  That analysis, however. depends                             3.2 The Insect Relief Habitat issue
               entirely on undocumented assumptions that:
               a) There is a relationship between calving density and herd                                     Although there is considerable theoretical concern
                  productivity.                                                                       for, and discussion of, the importance of insect relief habitat
               b) That alternative calving areas.are incapable of sustaining                          to the PCH and CAH, there is very little documentation of its
                  the PCH at current levels.                                                          role or significance to the herds. The overall requirements
               c) That displacement would be complete.                                                for insect relief and its relationship to herd health and
               d) That the growth of the CAH is partially a result of its low                         energetics requires additional study and assessme  .nt. As a
                  calving density.                                                                    migratory herd the PCH has insect relief habitat options both
                                                                                                      north and south of the study area and has utilized both coastal
               The arguments presented in the EIS regarding assumed relation-                         and montane ha bitats for that purpose.   01verall, insect relief
               ships between calving density and herd productivity are both
                                                                                                      habitats are neither scarce nor inaccessible. maintenance of
               speculative and hypothetical.  There is no supporting data to                          movement patterns as specified in the mitigation measures and
               warrant the conclusions made.  Therefore. the severity of the                          as experienced by the CAH would ensure access to insect relief
               impacts predicted are overstated and sub]ect to question.                              habitats both along the coast and inland.    In addition,
                                                                                                      elevated areas of gravel pads will increase availability of
                                                                                                      insect relief sites inland albeit to a minor extent compared to

                                                                                                      natural areas.

                                              12
                                                                                                                                       13
                        At present, there is no  basis toconclude that access
                                                                                                        15 July the majority of caribou have left the   1002 area on
               to insect relief,habitat will be  impaired by the development
                                                                                                        tneir mid-summer migration into Canada.
               scenario provided that mitigation  measures proposed are

               implemented.
                                                                                                                 There is also  scope to add to and improve the

                                                                                                        mitigation measures to  further reduce impacts on the PCH.

                                                                                                        These include site-specific scheduling to minimize activity
               3.3 Mitigation
                                                                                                        during sensitive periods.

                        In general# we.agree with the mitigation analysis.
                                                                                                                 A major unknown is how large concentrations   of caribou
               The major exception is the recommendations for ramps to'
                                                                                                        (100,000 or more in post-calving aggregations) would   respond to
               facilitate caribou passage. Recent studies show that ramps are
                                                                                                        and negotiate oil development infrastructure. There    is.reason
               not necessary to ensure caribou passage across pipeline
                                                                                                        to believe that large groups are more,susceptible to   influences
               corridors provided adequate pipe clearance is available.                                 such as deflection Ibecause of the impetus of their numbers and
               Further. the construction of ramps has biological costs
               associated with gravel removal and transport and habitat                                 the dynamics of group leadership.    Becau.as of these unknowns it
               alteration at source locations and ramp locations.                                       would be pru.dent to establish facilities such  as roads,and
                                                                                                        pipelines in areas of minimal potential conflict.with large

                                                                                                        aggregations of caribou.
                        Although we are in agreement  that air traffic should

               be controlled to minimize disturbance  the mitigation analysis
                                                                                                                 Despite evidence that caribou cross under pipelines
               presents a one-sided scenario by omitting references to caribou
                                                                                                        with clearances as low as 5 ft, we have previously recommended
               populations exposed to aircraft disturbance which have not
               suffered demographic effects (Hergerud et al., 1984;    Davis et                         a higher clearance where interaction with large aggregations
                                                                                                        are anticipated. We feel that a minimum of 7 ft ground/pipe
               al., 1985).  The restrictions proposed for aircraft appear to
                                                                                                        clearance within the range of the Porcupine caribou   herd would
               be overly conservative. For example 2.000 ft-ceilings on
                                                                                                        be a highly significant improvement as a mitigation   measure.
               overflights are proposed trom 20 May to 15 August.    However, by
                                                                                                        The major rationale.for increasitig the clearance is  to provide

                                                                                                        a larger margin for tacilitating passage of large
       OD

                                             14                                                                                       15
              concentrations of caribou and  because of the aforementioned                             4.0 OTHER SPECIES
              impetus of large groups which  can govern directional movements

              during post-calving and mid-summer migration. A higher
                                                                                                                Appendix I provides specific annotations for other
              clearance would facilitate passage of mature antlered bulls and                          species.  A major deficiency in the analysis is incomplete use
              would maintain a physical opening between . passing animals and                          of available literature and data sources.    As a result,
              the overhead pipe which would be visible to those animals in                             potential negative impacts tend to be over-emphasized, e.g.,
              the rearguard of large herds.                                                            the status of Polar Bear d enning is accorded considerable

                                                                                                       attention. However, denning in the 1002 area is an extremely
                       The existing scenario shows a proposed pipeline
                                                                                                       minor component of denning adjacent to ANWR which in turn is a
              location traversing the known post-calving aggregation area for                          minor component of denning overall for the Beaufort Sea polar
              the PCH south of Camden bay.   Additional study is recommended                           bear population.
              to improve that.location, possibly by moving it further north
              tn awnid tho .- Of Massive aggregation w-lithout preclu*...v                                      We are in agreement with the projected impacts and
              access to insect relief habitat.
                                                                                                       description on grizzly bears. The exponential growth rate of

                                                                                                       muskoxen may be limited by habitat availability in future.
                       The foregoing and other measures such so scheduling or                          Effects of disturbance on this growth rate are sL4eculative at
              convoying traffic during periods of major caribou move   .ments                          the present time.  The history of the transplant and growth
              would serve to greatly minimize adverse impacts on the herd and                          have established the capability of muskoxen to pioneer a new
              reduce the magnitude of predicted impacts considerably.
                                                                                                       environment and is evidence that they are responsive to

                                                                                                       opportunities provided by mitigation. In the absence of
                       In view of  the foregoing we disagree with the                                  controls or management, muskoxen would be forage regulated at
              statement (ref. 43. p. 111, App. 1) that mitigation is   not
                                                                                                       some future point and might compete with caribou in a
              possible in Resource Category I lands and feel that there are                            conflicting way.
              significant mitigative opportunities and measures to reduce the

              adverse effects of development activities on those lands.

                                                  16
                                              APPENDIX  I -                                                                                    17
                                                                                                                    Reference
                                                                                                               Page     No.                            Comments
                            Detailed review   comments on  the ANWR impact                                     28         6        it is important  to distinguish between post-
                                   assessment report, pp.   27-170.                                                                calving movement and aggregation and the mid-
                                                                                                                                   summer migration (see Jakimchuk and McCourt,.
                                                                                                                                   1975). Summer movements (midsummer
                 A)   Chapter 11, Existing Environment,    pp. 27-45.                                                              migration) are the most consistent mov   Iements
                                                                                                                                   of. the year. Post-Ta-1ving movements are also
                        Reference
                                                                                                                                   quite predictable.
                 Page      No.                            Comments
                                                                                                               28         7        There is no attempt to define the phrase
                  28       1-2       The "core calving area", as defined, has                                                      ..critical life stages".
                                     caribou densities of 50 animals/mi2 or more
                                     during five of 14 years.     Caribou use of                               29         a        Is productivity the basis for determining
                                     their calving grounds is very dynamic with                                                    'impact' or is habitat? Unless the direct
                                     site-specific densities varying greatly                                                       link implied is documented for caribou both
                                     within the calving period.                                                                    definitions should not be used*
                                                                                                                                   simultaneously.
                                     Core calving area is not necessarily
                                     "traditionally" favored and the words "strong                             29         9        More documentation of August numbers is
                                     fidelity" are misleading.     It is in fact an                                                needed to determine the frequency of hugust
                                     area where high density of calving has                                                        occupation of the 1002 area (eg., are
                                     occurred frequently. i.e.,    yearly overlap                                                  numbers closer to 15,000 or to lower end of
                                     within the overall calving    range.                                                          range?).
                  28        3        This paragraph lacks references and is mis-                               29        11        This paragraph requires references.      The
                                     leading. The generalization that caribou use                                                  movements of Central Arctic herd in the 1002.
                                     riparian areas as travel routes and important                                                 area have not been adequately documented to
                                     feeding areas is not fully supported by the                                                   date.
                                     available literature (see Jakimchuk and
                                     McCourt. 1975;    LeResche and Linderman,                                 29        12        Again no references are provided.     The most
                                     1975).                                                                                        detailed information on calvingdistribution
                                                                                                                                   of the Central Arctic herd is available from'
                  28        4        References or qualifications are required on                                                  Sopuck and Jakimchuk (1986). Carruthers and
                                     types of disturbances which may affect                                                        Jakimchuk (1985) and Carruthers et al.
                                     bonding and increase in mortality. We need a                                                  (1984a).  The presence of 1,000 females and
                                     more realistic impact prediction on the                                                       calves on Canning Delta in most years
                                     effects of disturbance on calf mortality.                                                     contradicts data which show more of a calving
                                                                                                                                   continuum along the coast with concentrations
                  28        5        Uplands are in southern part of calving                                                       between major river valleys. Also, the
                                     grounds. not the northirn part.     Also, use of                                              calving situation at Prudhoe Bay oilfield is
                                     uplands by most calving cows contradicts                                                      misleading.   The results of Whitten and
                                     previous statement (see #3) that calving                                                      Cameron (1985) were rebutted by Jakimclkuk
                                     "caribou" use vegetated riparian habitats                                                     (1986) who reviewed evidence that the Prudhoe
                                     (see Jakimchuk et al., in press).      There are                                              Bay area was never an important calving area
                                     no citations of work done by Renewable                                                        for the Central Arctic herd.
                                     Resources Consulting Services Ltd. on calving
                                     distribution of the Porcupine caribou herd                                29         13       Use of riparian areas as travel corridors
                                     during the 197us.                                                                             and feeding areas by the Central Arctic herd
                                                                                                                                   by cows and calves is not supported by the
                                                                                                                                   literature (see Carruthers et al., 1984a;
                                                                                                                                   Jakimchuk et al., in press).

                    Reference                 18                                                              Reference                 19
             Page     No.                           Comments                                           Page      No.                           Comments
                                This paragraph ignores the Central Arctic                                33      25       This paragraph contains very vague and mi   s-
                                herd as a whole anti only discusses the 1002                                              leading statements.    It leaves the impression
                                area and is therefore, incomplete.     Since                                              that 4 high percentage of the 2,000 bears in
                                most of the herd occurs outside the 1002
                                area, this paragraph gives a misleading view                                              the Beaufort population use ANWR.     This is
                                of importance of the area to the Central                                                  not the case.   One to two dens in each of
                                Arctic herd.                                                                              four out of five years does not indicate high
                                                                                                                          use of the area by denning bears@.    See hoore
             29       is        In the presentati .on of Central Arctic herd                                              and Quimby (1974) for earlier studies on
                                distribution and abundance there are no                                                   polar bear denning locations (Biolocjical
                                comments on productivity.   This omission                                                 Report Series, Vol. 32, Ch. 2) which also
                                downplays the tripling of herd size which has                                             found a low frequency of denning    in ANWR.
                                occur'red since the Prudhoe Day development                                               The 15 dens found between 1951-1985 is
                                started.                                                                                  cumulative and does not represent actual
             30       16        Additional data on moose obtained in the                                                  numbers in .any one year.
                                1970s are available from the Arctic Ga  13                               34      30       Addition Iat information on ringed seal is
                                Biological Report Series, Vol. 6, Ch. 1.                                                  adjacent to ANWR can befound in Moore
             20       17        Data on the Sadlerochit Mountains sheep herd                                              (1976)Biol. kept. Series, Vol. 36,.Ch. 2.
                                are available in an earlier reference (see                                                This reference.was not cited.
                                Arctic.Gas biological Report Series, Vol. b,
                                Ch. 1).                                                                  37      31       Studies conducted by McCart et.al. (Hiol.
                                                                                                                          Ftept. Series) on fisheries resources in the
                                                                                                                          ANWR area are not cited.
      A       31                More detailed information than  available in
                                Chesemore (1967) on Arctic fox   distribution
                                in the.1002 area is available from Quimby                              45        32       The impacts of oil development on the Wilder-
                                                                  o                                                       ness resources of the 1002 area will be a key
                                and Snarski (1974). Arctic Gas biological                                                 issue.
                                Report Series, Vol. 6. Ch. 2.-

             32       20        Additional ihformation,on wolverines in the
                                1002 area is available from Quimby and
                                Snarski (1974), Arctic Gas Biological Report
                                Series. Vol. 6. Ch. 2).                                                B) Chapter Vt. Environmental Consequences, pp. 95-119.
             32       21        Again, earlier work on bears in the IU02 area
                                by Quimby and Snarski (1974) is ignored.                               96          1      These definitions of impacts do not attempt
             33       2 14      Thts paragraph lacks references which   are                                               to 4uantify the changes in abundance in wild-
                                especially required since conculsions                                                     life populations from the natural state t   Ihat
                                presented are controversial.                                                              corresponds to each level of impact.
                                                                                                                          Also there is no allowance for accommodation
                                                                                                                          or habituation by species to modifying
             33       24        Numbers of polar bears in the ANWR part of                                                influences.
                                the Beaufort should be indicated;    the Beau-
                                for't sea estimate.of 2.OQU includes Canadian                            96        2      We agree that the PCH concentrated calving
                                waters. "Influx of.females" implies large
                                numbers moving into the  1002 area.   TE13 a 19                                           area is considered unique and irreplaceable.
                                not so.  References for  the population.                                 98        3      The remainder of the 1002 area canno    .t be
                                estimate are-not given.                                                                   considered scarce habitats, nationally vs.
                                                                                                                          regionally,and should be category 3-4 for
                                                                                                                          most  species,.

                                               20
                    Reference
              Page      No.                           Comments                                                                              21
                                                                                                                 Reference
              105        5        Although up to 82 percent of calving for the                             Page      No.                            Comments
                                  Porcupine caribou herd has occurred in the
                                  1002 area, in some years almost no calving                                                     important calving area.
                                  has occurred there.    However, use of the area                                                Whitten and Cameron (1985) do not show an
                                  is more consistent during the late June/early                                                  absence of calving for the entire perioT_
                                  July insect relief period.                                                                     but co-Incidentally with delayed snowmelt.
                                  The statement that the insect relief period                                                    Whitten and Cameron also discuss other
                                  is highly stressful is based largely on                                                        possibilities for low pre- and post-calving
                                  theoretical considerations - insect relief                                                     densities.
                                  habitats are widespread north and south of                                                     Other Central Arctic caribou herd calving
                                  the 1002 area. An inland pipeline may inter-                                                   areas show similar pre- and post-develop-
                                  tere with movements to the coast and post-                                                     ment low calving distributions.
                                  calving aggregations;    however, a coastal                                                  This section superficially covers a very
                                  pipeline would not.                                                                          important topic and uncritically accepts
                                                                                                                               selected findings of one study (i.e., Whitten
              105        6        This statement should be qualified as to                                                     and Cameron, 1985).
                                  extent of displacement and should indicate
                                  that only a minor component of the Central                               106         9       Inappropriate secondary reference to a
                                  Arctic caribou herd is involved.                                                             review paper when other references, e.g.,
                                                                                                                               Carruthers et al. (1984a), are original
              106        7        These statements are hypothetical and too                                                    sources of systematic data with wider
                                  generalized because:                                                                         coverage titan any other.
                                  1) Density is only an important consideration
                                     if proposed activities have effects on                                106       LO        Long term data collected from 1981-86 by
                                     populations.                                                                              Renewable Resources Inc. indicates that the
                                  2) It is debatable if the interaction would                                                  Canning River Delta is not a major calving
                                     be greater than at Prudhoe Day.      The                                                  area for the Central Arctic herd.       However,
                                     Porcupine caribou herd does.not always                                                    it receives greater use during the      post-
                                     calve in core area and not-all of the core                                                calving period.
                                     area will be affected.
                                  3) Nonetheless, calving and post-calving                                 106       11        Table VI-4 shows progressive increase in
                                     densities and numbers do differ signifi-                                                  calving numbers,in the oilfield from 1972-
                                     cantly from the Central Arctic caribou                                                    1974.  A detailed critique of these data is
                                     herd and differing Implications may occur.                                                available in Jakimchuk (1986).
                                     if an adverse effect occurs it would
                                     certainly affect a greater proportion of                                                  Also, population estimates for the Central
                                     the population especially during post-                                                    Arctic herd for L981-1986 are available from
                                     calving aggregation.                                                                      various RRCS studies.
                                  We agree also that the Porcupine caribou                                 106       12        The amount Of the "core calving areas"
                                  herd will form larger groups than the Central                                                within the 1002 area depends on the
                                  Arctic caribou herd during post-calving and                                                  definition of core calving ground used.       The
                                  that predator populations also differ                                                        criteria of >50 caribou/km2 in at least 5
                                  between the two areas.                                                                       of 14 years resulting in 80 percent within
              106        8        This paragraph is of major importance     and is                                             the 1002 area may be too conservative (i.e*,
                                  highly misleading (see Jakimchuk, 1986;                                                      the major calving grounds are actually much
                                  Caribou workshop paper) because:                                                             larger).
                                    the Prudhoe bay oil field was never an                                 106       12        There are no receiitly published population
                                                                                                                               estimates for the Porcupine caribou herd
                                                                                                                               since 1983. The 1,983 photocensus estimate

                                              22                                                                                          23
                    Reference                                                                                   Reference
              Page     No.                            Comments                                            Lage      No.                           Comments

                                 since 1983.   The 1983 photocensus    estimate                                              Bergerud et al. (1984).    Citation is   used
                                 was 135,000. Therefore recent estimates, of                                                 inappropriately here.
                                 165,060 in 1985 and 181,000 in 1966 are
                                 guesses rather than actual censuses as                                   107       19@      Thi    tatement is grossly misleading    since
                                 implied.                                                                                    the:esis no evidence available to support
               106     13        Y.ear-round .use of the11002 area by 4,000                                                  it.' The following sentence can also     apply to
                                                                                                                             many other.areas within the range of     the CAH.
                                 Central Arctic car.ibou is undocumented.                                                    Both the statement and cited study are
                                                                                                                             misleading (Whitten and Cameron, 1985) and
              106      14        Core-calving and concentrated calving areas                                                 have been separately criticized by Jakimchuk
                                 are defined using the density.of !50 caribou/                                               (1986) and  Carruthers et ai. (1984a).
                                 mi2 yet there is no indication of how these
                                 estimates of density were made.     Also, a                                                 The extent  of displacement in the Prudhoe
                                 better indication of the use of the 1002 area                                               Say area caused by development is difficult
                                 for calving would be data on the percentage                                                 to quantify since the area.was never an
                                 of the herd that calved there each year.                                                    important calving area and because
                                                                                                                             pre-development data ars not sufficiently
              L07      16        indirect habitat losses as a result of                                                      quantitative.
                                 behavioral avoidance are difficult to
                                 quantify.   Studies to date show that the                                107       20       The study by Dau and   Cameron (1986) shows
                                 degree of a'voidance by caribou is variable                                                 reduced habitat use by caribou.     However, the
                                 and that,caribou may habituate to these                                                     extent of reduced habitat use shows
                                 disturbances over the long term.      Indirect                                              considerable variation. Habituation of
                                 habitatlosses. due to physical barriers may                                                 caribou may reduce this.effect in the long
                                 be more signficant depending on the success                                                 term.
                                 of mitigation measures employed.
                                 Insufficient pipe heights or over-reliance on                            108       21       If displacement does occur, adjacent areas
                                 ramps in combination with disturbance may                                                   may not be undesirab  'Le since they are
                                 impede free movements of caribou. This                                                      frequently used with no short    *term adverse
                                 problem may be significant for very large                                                   effects.on productivity.    Long term studies
                                 aggregations.of Porcupine herd caribou during                                               on effects on productivity of displacement
                                 the.post-calving (insect relief) period.                                                    would be required to determine the signifi-
                                 Date on the responses of very large groups of                                               cance of displacement from a high density
                                 caribou.to physical barriers are presently                                                  calving area.
                                 unavailable.
                                                                                                                             Although displacement of the Porcupine
              107      17        Present studies of behavioral avoidance    by                                               caribou herd from a "core calving area' may
                                 caribou of roads do not prove that                                                          be deleterious, studies of the Central Arctic
                                 disturbance is a-major source of habitat                                                    herd show that caribou numbers can increase
                                 lose. We need to know how many caribou show                                                 despitedevelopment within their calving
                                 the displacement response and whether                                                       areas.   We agree, however, that caution
                                 habituation will occur in the long term.                                                    should be'used in extrapolating Central
                                                                                                                             Arctic caribou herd results to the Porcupine
              107      is        The statement is not trUe,.and   not                                                        caribou herd since the Porcupine caribou herd
                                 definitivei   Dau and Cameron (1986) show                                                   occurs at much higher densities on their
                                 local response to roads consisting of reduced                                               calving grounds and because predators are
                                 densities of maternal caribou not dis-,                                                     more abundant adjacent to the Porcupine
                                         t  from calving grounds.                                                            caribou herd calving Areas.     In addition,
                                 P"COMN ns                                                                                   caution should be used in the assumption that
                                 Conclu io    and statements by Cameron and
                                 Whitten (1979) have  been,challen4ed    by                                                  displacement of the Porcupine caribou herd

                                               24
                     Reference                                                                                                              25
              Page      No.                           Comments                                                   Reference
                                                                                                           Paqe      No.                           Comments
                                  from a "core calving area" would occur in
                                  total as implied. The probability of this is                                                 establish the likelihood of conditions which
                                  low based on evidence from the CAH.                                                          constitute interference or provide better
                                                                                                                               qualifications of statements made.
              108       22        This statement presupposes a food limiting
                                  habitat and a complete loss - the references                             109       31        Agree - valid concern.    I have previously
                                  used deal with non-caribou apparently since                                                  recommended 7' ground to pipe clearance
                                  caribou are not a food limited species and                                                   rather than the 5' level cited in this and
                                  comparable references are not available for                                                  the workshop report.
                                  mainland herds of barrers-ground caribou in
                                  North America.                                                           109       31        We agree that the effect of potential
                        25                                                                                                     barriers are greater during post-calving than
                                  There is no basis for "unlikely" conclusion.                                                 during calving because of the very large size
                                  This is speculation only based on inference     of                                           of postm-calving aggregations and the sudden,
                                  higher density. Also presupposes a "massive"                                                 erratic movements between Inland areas and
                                  displacement rather than a local displacement.                                               coastal insect-relief habitats. There is
                                  This is an example where the CAH experience                                                  insufficient evidence, however, to indicate
                                  is downplayed despite the existence of data                                                  that survival or productivity of caribou may
                                  on compatibility with development. "...no                                                    be reduced as a result of a disruption in
                                  recognizable... long term effect ... has been                                                movements during this Period. We recommend
                                  demonstrated to date (emphasis ours).                                                        that the location of a main east-west pipe-
                                                                                                                               line be studied further and that pipe heights
                        26        However, all participants of the FWS workshop                                                should be raised from the minimum of 5' cited
                                  did not agree to the extent or significance                                                  in the EIS to 7' within the range of the PCH.
                                  of that displacement.
                                                                                                           109       32        The European references used are not
              Los     27-28       Dau and Cameron (1986) indicate that reduced                                                 appropriate - carrying capacity and
                                  density of maternal caribou which they term                                                  nutritional limitations are greater for
                                  displacement may occur within 2 miles from                                                   European Populations.
                                  active roads. However, the percentage of
                                  caribou affected is uncertain. A                                         109       34        This statement is based on one example and
                                  significant number of caribou within 2 miles                                                 hence is not objective.
                                  may be unaffected by disturbance. Therefore,
                                  development would not result in the complete                             109       35        There is no evidence that ramps will
                                  loss of 32 percent of the Porcupine caribou                                                  significantly increase crossing success -
                                  herd core calving area as calculated.                                                        rather pipe heights and the presence of
              108       28        It is erroneous and misleading to imply a                                                    vehicular traffic are more important.
                                  "total displacement" two miles wide.     The                             109       36        it is appropriate to discuss RRCS studies of
                                  term,p roba        lation decline is                                                         the Nelchina herd (Carruthers et al., 1984b)
                                  unsubst.nt@.Iaetepdolue.. displacement is linked                                             here and reference it.    This herd is exposed
                                  to decline, but such an effect has never been                                                to TAPS only twice a year, but crosses it
                                  demonstrated or documented. The assumption                                                   successfully.
                                  of massive displacement is unwarranted based
                                  on the Central Arctic caribou herd                                       109       37        This worst case is unjustified on the basis
                                  experience.                                                                                  of known responses of caribou. it is
                                                                                                                               unrealistic and ignores experience to date.
             108        29        Several studies show that pipelines such as
                                  TAPS and Kuparuk do not create a barrier.                                                    Also should not assume 2-mile sphere of
                                  Note one-sided refs. Need to clearly                                                         influence even without mitigation.

                                                26                                                                                           27
                     Reference                                                                                     Reference
                Page      No.                          Comments                                             Page      No.                            Comments
                110       38       Disturbance and harassment are significantly
                                   different.   There is no evidence that                                                       measures could also be listed, to further
                                   disturbance will result in direct or indirect                                                ameliorate impacts.
                                   mortality as a result of trampling or                                    112       48        Environmental description map in Chapter 11
                                   increased eFiergy loss.                                                                      shows extent of alternative habitats.
                110       39       This paragraph ignores several other studies                                                 Whether these could sustain a growing
                                   some of which are more quantitative.                                                         population assuming loss of all core calving
                                                                                                                                area (although unlikely) is unknown.
                110                Davis et al. (1985) report no demographic
                                   effects or calving ground displacement on                                112       49        Insect relief habitats need to be more
                                   the Delta caribou herd from severe aircraft                                                  accurately described.    We need to know how
                                   disturbance and other disturbance associated                                                 much space is necessary to give relief to the
                                   with military activity. This is an example                                                   Porcupine caribou herd.
                                   where significant conclusions of a recent                                112       50
                                   peer review paper (Davis et al., 1985) are                                                   There is a major step between potential
                                   ignored in favour of an outdated non-peer                                                    undocumented effects and a population
                                   review reference.                                                                            decline.   However this paragraph seems to be
                                                                                                                                properly qualified.
                110       41       The editorial comment "widely disputed view"                             112       51        Is it a decline or distribution change or
                                   is an inappropriate and unsubstantiated
                                   comment on a peer-review published paper.                                                    both? Tfiere is no basis for predicting
                                                                                                                                either a 5-10 percent decline or distribution
                111       43       We disagree with this conclusion since                                                       change. The opposite, a three-fold
                                   Category I habitats would not suffer an                                                      population increase in the CAH accompanied
                                   inevitable   "loss". mitigation of Category I                                                the Prudhoe Bay development which interacted
                                   habi.tat is possible because:                                                                with a much larger proportion of the CAH thn     .n
                                   1)  A 2-ml-le avoidance zone is not a valid                                                  would be the case for the 1002 area.       The
                                       assumption (see previous c6-mments).                                                     Prediction of a decline and distribution
                                   2)  many mitigation options are available                                                    change for the CAH throughout its range based
                                       includingi                                                                               on the 1002 interaction totally,ignores the
                                       - Traffic control                                                                        well-documented facts of the actual effects
                                       - Reduced human activity during calving                                                  of development.   This paragraph is unfounded.
                                       - Reduced aircraft overflights                                       113       52        There is no basis given for extrapolating
                                       - Speed limits on traffic, etc.                                                          effects  on individuals to population
                                                                                                                                effects.
                Ill.      44       Ramps are over-emphasized and not justified.
                                   Llevation of pipelines to 7' above ground                                113       54        A major unjustified assumption here to that
                                   (because of large groups) should be a                                                        disturbance will result in absolute loss of
                                   priority over camps.                                                                         habitat value.
                Ili       -46      Davis et al. (19b5) do not indicate a
                                              Restrictions could be lifted after                                                Also an exponentially expanding population
                                   problem.                                                                                     suygests.that in the.near term it is below
                                   15 July because most PCH animals are gone on                                                 carrying capacity.
                                   summer.movements by that date..    We agree
                                   With a minimum altitude of 2,000' May 20
                                   through July 15th.                                                       114       55        Evidence is opposite, these sub-groups all
                                                                                                                                originated from two transplants, one maTe-on
                Ill       41       We basically agree with all mitigation                                                       Barter Island (19b9) and the other at Kavik
                                   measures except for ramps.     Howev er. more                                                Camp (13 muskox transplanted in 1970).

                                              28
                     Reference                                                                                                          29
               Page     No.                          Comments                                                                      APPENDIX 11
               116      56        These conclusions are entirely speculative
                                  and there is no possibility of subsequent
                                  determination it they are correct or
                                  incorrect.
               117      57        Agree with this section in general.                                        Review of Dau and Cameron (198b) Report entitled "Lffects
                                                                                                             of a road system on caribou distribution during calving".
               lie      59        This paragraph is misleading because 12-13                                 "Rangifer", Special issue No. i195-101--
                                  percent of the Beaufort Sea Population do NOT
                                  den on land.

               119      60        This paragraph should be qualified with a                                      Dau and Cameron have demonstrated a local, short-term
                                  more objective review of likelihood of
                                  effects on productivity of bears..                                    reduced density of maternal caribou groups adjacent to an

                                                                                                        active road system which they refer to as partial displacement.

                                                                                                        However, several qualifications to their results need to be

                                                                                                        made that were absent in the report. The authors admit that it

                                                                                                        is speculative to extrapolate the local effects on maternal

                                                                                                        caribou to the population as a whole. Yet they imply that

                                                                                                        displacement will result in widespread, long-term loss of

                                                                                                        tr&ditionally-used habitat. We argue that such conclusions are

                                                                                                        unwarranted at this time.

                                                                                                                 The experimental design of Dau and Cameron, although

                                                                                                        more rigorous than previous work, did not include adequate

                                                                                                        controls. The design requires a control area    containing a

                                                                                                        hypothetical road alignment and located in an area of similar

                                                                                                        habitat and calving density, well away from human activity.

                                                                                                        monitoring of a control area during an equivalent study period

                                                                                                        (1978-85) would indicate whether changes in caribou

                                                                                                        distribution similar to the experi  mental area can occur in the

                                                                                                        absence of development.

                                               30                                                                                         31
                        In addition, Dau and Cameron fail to note that:                                             It is noteworthy that Dau and   Cameron  showed that non-

                                                                                                          maternal caribou were not displaced by    theroad development.
              1) despite partial.displacement and increasing development
                                                                                                          Also, the response by   maternal groups was partial displacement
                  activity, caribou .  densiti.es increased in their study area                           within a zone of  0-3 km (0-1.9 mi).    In the ANWR report it is
                  from 1978-85;
                                                                                                          implied that all caribou show a total displacement within 2

                                                                                                          miles. This scenario is not supported by the Dau and Cameron
              2)  most.of the  displacement was observed   in the middle                                  report.
                  sections of  the road, the north and   south ends of the.road

                  alignment supported lower densities    of caribou before and

                  after the development,

              3)  non-maternal groups,   whi'ch included up to 25 percent

                  calves, occurred at higher densities (although not
                  signi.ficantly higher) near the roa  d alignment than away,

                  from the alignment during the post-development period;

              4)  habituation was not evident up to 1985 because the

                  intensity  of human activity was also increasing

                  dramatically at this time.

                       The Dau and Cameron study showed statistically

              significant differences in caribou density vs. distance     but

              also indic ate that annual variability was high.     In fact. the

              annual variability within each 4-year period was almost

              significant (p = 0.053) for cal*ves.   This suggests that   the

              displacement response varied considetably from year to year.

                                                32
                                                                                                                                                   33
                                       LITERATURE CITED
                                                                                                                Jakimchuk, R-D. 1986. The relationship of caribou-summer
             Bente, P.J.    1977. Summary report of investigations of the                                             distributions and the Trans-Alaska pipeline:         Does absence
                   Porcupine caribou herd in northeastern Alaska and the                                              mean displacement? Prep. by Renewable Resources
                   Yukon Territory, 1977.     Renewable Resources Consulting                                          Consulting Services Ltd. for Joint Indu      .stry - Alaska Dep.
                   Services Ltd. Unpubl. Rep. 19 pp.                                                                  Fish and Game Caribou Workshop, 28-30 October 1986.
                                                                                                                      Anchorage. 23 pp.
             Bergerud, A.T.. R.D.    Jakimchuk and D.R. Carruthers. 19b4.         The
                   buffalo of the North - Caribou (Rangifer tarandus) and                                       Jakimchuk, R.D., S.H. Ferguson and L.G. Sopuck.          In press.
                   human development. Arctic 37:7-22.                                                                 Differential habitat use and sexual segregation in the
                                                                                                                      Central Arctic caribou herd. Accepted by Can. J. Zool.,
             Cameron, R.D. and K.R. Whitten.       1979.   Seasonal movements     and                                 Sept. 1986.
                   sexual segregation of caribou determined by aerial
                   surveys. J. Wildl. Mgmt. 43:626-633.                                                         Jakimchuk, R.D., L.A. De bock. H.J. kussell and G.P. Semenchuk.
                                                                                                                      1974. & study of the Porcupine caribou herd, 1971.
             Carruthers. D.R., R.U. Jakimchuk and S. Ferguson.         1984a.     The                                 Arctic Gas biol. Rep. Ser., Ch. 1. Vol. 4. Ill pp.
                   relationship between the Central Arcti-: caribou herd and                                    Jak
                   @the Trans-Alaska Pipeline.     Prep. by Renewable Resources                                    imchuk. R.D. and K.H. McCourt.       1975.   Distribution and
                   Consulting Services Ltd. for Alyeska Pipeline Service                                              movements of the Porcupine caribou herd in the northern
                   company, Anchorage. 2U7 pp.                                                                        Yukon. In: Proc. First Int. Reindeer and Caribou Symp.,
                                                                                                                      Biol. PaF-ers Univ. Alaska, Special Rep. No. IsI40-154.
             carruther, D.R.. R.D. Jakimchuk and C. Linkswiler. 19H4b.
                   Spring and fall movements. of belchina caribou in relation                                   LeResche, R.E. and S.A. Linderman. 1975. Caribou trail
                   to the Trans-Alaska pipeline. Prep. by Renewable                                                   systems in Northern Alaska. Arctic 23(1):54-61.
                   Resources Consulting Services Ltd. for Alyeska Pipeline
                   service Company. Anchorage. 101 pp.                                                         'Moore, G.D. 1976. A survey of ringed seal (Phoca hispida)
                                                                                                                      along the northeast Alaska and Yukon Ter-ritory coasts#
             Carruthers, D.R. and R.D. Jakimchuk. 1985. The distribution                                              1975. Arctic Gas Siol. Rep. Ser., Vol. 36, Ch. 11.
                   and numbers of caribou in the Central Arctic region of                                             27 pp.
                   Alaska, 1984-85. Prep. by Renewable Resources Consulting
                   Services Ltd. for Alyska Pipeline Service Company, ARCO                                      Moore, G.D. and ft. Quimby. 1974. Environmental considerations
                   Alaska. Inc., Chevron U.S.A. Inc., Conoco Inc., Exxon                                              for the Polar bear (Ursus marj!img, Phippel of the
                   Company U.S.A.., and Sohio Alaska Petroleum Company.                                               Beaufort Sea. Arctic Gas Blo        R . Ser. Vol. 32, Ch. 11.
                   47 pp.                                                                                             57 pp.
             Curatolo. J.A. and D.G. Roseneau. 1977. The distribution and                                       Quimby, R. and D.J. Snarski. 1974. A study of fur-bearing
                   movements of the Porcupine caribou herd irv northeastern                                           mammals associated with gas pipeline routes in Alaska.
                   Alaska and the Yukon Territory. 1976. Renewable Resources                                          Arctic Gas hiol. Rep. Sec. Vol. 6. Ch. 11. IOU pp.
                   Consulting services Ltd. Unpubl. Rep. submitted to
                   Northern Engineering Services Ltd. 59 pp.                                                    Roseneau, D.G., P. Stein and C. Warbelow. 1974. Distribution
                                                                                                                      and movements of the Porcupine caribou herd in north-
             Dau, J.R. and R.D. Cameron. 1986. Effects of a road system on                                            eastern Alaska. In: K.H. McCourt and L.P. Horstman
                   caribou distribution during calving. Rangifer, Special                                             (eds.). btudies R large mammal populations In northern
                   Issue No. 1. 198b:95-101.                                                                          Alaska, Yukon, and Northwest Territories, 1973. Arctic
                                                                                                                      Gas Biol. Rep. ber., Vol. 22, Chapt. 4 197 pp.
             Davis. J.L.. P. Valkenburg and     R.O. Hoertje. .1985.
                   Disturbance and the Delta    Caribou Herd.    Pp. 2-6 in A.M.                                Roseneau D.G. and J.A. Curatolo.      1975.   A comparison of the
                   Martell and D.E. Russell    (ads.).   Caribou and human                                            movements and distribution of the Porcupine caribou herd,
                   activity. Proc. Ist North Am. Caribou Workshop. white-                                             1971-74. Paper presented at annual meeting Northwest
                   horse, Yukon. 28-29 Sept. 19b3. Canadian wildl. Serv.                                              Section Wildi. Society, April 3. 1975.
                   Spec. Publ., Ottawa.

    ~0

                                                                                                                                                                                                                                                                     7,
                                                                                                                                                                                                                              ~a~E4 ~Ur~,~)~,~,~.
                                                                                                                                                                                                                                            ~S~E4
                                                                                       34

                         Rose    neau. D.G. and J~.A. Curatolo.                                   1976. The distr                  ibut~ion and
                                    movements of the Porcupine caribou herd in northeastern
                                    Alaska and the Yukon Territory.                                    1975~.~ In:               R.D.                                                                                                              ~qV~,
                                    Jakimchuk ~qied.). Studies of mammals alo~qi~2qFg the proposed                                                                                                                                      ~qI~n
                                    Mackenzie Valley gas pipeline route, 1975. Arctic Gas
                                    Biol. Rep. ~Ser~. ~Vol. 36, chapt. 1. 82 pp.                                                                                                                         -'EXPLANATION
                                                                                                                                                                                                              ~P~q@
                         ~o~uck, L.G~.               and R~.D. Jakimchuk.                        ~19~8~6. Caribou monitoring
                                    studies         in the Central Arctic Region of Alaska, Final
                                    Report.           Prep. by Renewable Resources Consulting Services
                                    Ltd. for A~lyeska Pipeline Service Company, ARCO Alaska
                                    Inc., Exxon Company U.S.A., Standard Alaska Production
                                    Company and BP Alaska Exploration Inc.                                                                                                                          Figure 11-4-~Migr~ati~on routes and winter range of
                                                                                                                                                                                                                 the Porcupine caribou herd
                                                                                                                                                                                                    were as low as 101,00~0 ~(~LeRes~ch~e. ~19~72). The lower levels
                         Whitten. K~.R. and R.D~. Cameron.                                     19~85.         Distribution of caribou                                                                  ~0~1 "Tiff contraries may reflect ~a truly s~r~"~i~n~t~er population;
                                    ,calving in relation to the Prudhoe Bay oil fields                                                                                                              less accurate or less c~ornp~le~t~e survey ~lechni~c~iues~. or a
                                    Pp. 35-39 in A.                 Martell and D. Russell (ed~s.)                                    Proceedings                                                    Combination of these factors. Caribou Populations appear                   ~qs
                                    First Nort~qK Am.               ~Caribou workshop, Whitehorse,                               ~ 1983.                                                             to fluctuate unpredictably over the fang ~fe~r~i~n. The k~i~n~g~-~t~er~m
                                    Canadian W~i~ld~l.                  Serv. Spec. Pub~l., Ottawa.                               6~6   ~p.                                                             ~Pax~hnu and ~In~in~inu~r~, Population of the PCH and th~e
                                                                                                                                                                                                    carrying capacity of the PCH we unknown.
                         Whitten, ~K~.R~.                  1986~. Demogr~aphy of th~e                            Porcupine Caribou Herd,                                                                                                                                             ~qp
                                    1978-19~86~.              Presented at the Joint                          Industry - Alaska Dept.                                                                        The PCH ranges Over~-~9~8.~100 square ~n~*~n of
                                    Fish and Game Caribou Workshop. 28~-30 October 1986.                                                                                                             northeast Alaska ~a~nd northwest Ca~nad~c and constitutes
                                    Anchorage.                                                                                                                                                      ~the largest population of large ~n~ia~n~w~ads shared between
                                                                                                                                                                                                    the two nations ~i~f~t. 1~1~-4~)~.

                                                                                                                                                                                                           The traditional calving grounds of the PC~H extend
                                                                                                                                                                                                    throughout the Arctic foothills and coastal plain ~fr~or~n the
                                                                                                                                                                                                    Canning River in Alaska to the ~B~obb~a~ge River in Canada.
                                                                                                                                                                                                    ~b~x~k~m~f~mg the ~o~n~f~ir~e 1002 wen, the coking grounds                            ~qa
                                                                                                                                                                                                    ~e~nc~on~wa~s~s ~a~n area of new~i~f~i~r 8-9 rn~f~i~f~l~on Mass ~(p~l. 2~t~%~j~.                  3
                                                                                                                                                                                                    From yew-to year. [he c~bs~tr~ibu~t~i~on of caribou on these
                                                                                                                                                                                                    calving Wounds varies considerably. with mat calving                       b
                                                                                                                                                                                                    ~asual~l~y taking place in the arm between the Hu~l~ahu~l~s River
                                                                                                                                                                                                    ~a~nd the Canadian border. During 19~72~-85 detailed                           fir
                                                                                                                                                                                                    observations were ~in~ad~e ~a~t calving w~eas of the PC~H. As a
                                                                                                                                                                                                    ~r~e~s~ull ~a~t these studies. areas where c~o~rib~ou were present                  ~qc
                                                                                                                                                                                                    dt~ir~ing calving of a density of at least 50 c~an~b~o~u/squ~are
                                                                                                                                                                                                    note were identified as concentrated calving areas. The
                                                                                                                                                                                                    core calving area is a location to which pregnant cows
                                                                                                                                                                                                    have shown a strong fide~f~f~i~f~y as traditionally favored calving
                                                                                                                                                                                                    h bit    ~Th~os ~c~o~n~cen~t~r~o~led calving areas used in at least                  ~qf~qi
                                                                                                                                                                                                    ~f~r~i~v~i~s~t
                                                                                                                                                                                                                   the 14~,yew ~s~ludy were identified as the core
                                                                                                                                                                                                    coking am. Of ~th~e 2.1 million awes identified as
                                                                                                                                                                                                    concentrated calving Areas. 934.000 acres ~144 percent) we
                                                                                                                                                                                              2.    within the 1002 area. An even ~W~a~i~d~e~v proportion. 242.~0~0~0
                                                                                                                                                                                                                                                                               ~qa
                                                                                                                                                                                                    sues US Percent). ~a~t the 311.000 awes ~o~f core calving
                                                                                                                                                                                                    area is within the 1002 area.

                                                                                                                                                                                                           Spring ~rni~r~s~ti~ons to the calving grounds start in May
                                                                                                                                                                                                    horn winter ranges. which we usually south of the Cann.
                                                                                                                                                                                                    nen~t~al Divide in Alaska and in central Yukon Territory ~a~nd
                                                                                                                                                                                                    adjacent Northwest Territories in Canada (fig. ~1~14)~ Timing
                                                                                                                                                                                                    ~nr~@d routes o~f ~rni~qations very annually depending on winter

                                                                                                                                                                                                    2~8 ARCTIC REFUGE RESOURCE ASSESSMENT

    ~0

                    fe~~~~~~s, and bulls occupying the southern and eastern                                          The Central Arctic ca~t~i~b~m~i held ~JCA~H) has been                                                                                     pop~,~i~h~i~on~~r~j                                                      A~,,~t~u,~
                                                                                                                                                                                                                                                        ~R~.~f~i~,~q, ~.~,~, ~1~9~6~9 -~d 1~9~7~0 ~11~1~0-~1-~1 -~.~1 ~'~;~1- ~1~1~)~14~1 ~I~h~,                                       ~and ~qI~qmb~q.
                    periphery of ~~e calving grounds begin ~t~o Mix with the                                    increasing, and in 19~6~5 numbered abou~l 12 ~0~~1~0 to 14 0~00                                                                                  ~,~x~i~f~ox p~op~u~l~a~t~i~n~n his grown ~e~~,p-~n~i~m~l~ly ~1~-~1- ~0~74 ~1~6~9                                        d~j~a~qcen~qt
                    cows ~~d carves. ultimately ~f~or~m~~l~ing huge po~s~ical~vin~g                                    Its range is enti~te~fy north of the Continental ~1~1~-ide~. from ~1h~.
                    aggregations By late June or early July aggregations                             of-      l~i~k~i~f~f~i~l, and Colville Rivers on the west to ~the Sa~c~i~l~v~ochi~l                                                                              11~5~2p~1p~~. o~r I        ~jh p-~lu~c~Wdy ~and low ~-~1~1~1~,~1~1~1~b~l~y ~I~r~i                                  sedges (I
                    80.000 or More caribou on the t~0~02 area, .~0 ~.~0~"~s"~O~n                                       ~R~W~V on ~th~e ~.~&~M ~fp~f 2~Y) ~Th~e TAPS. Dennis Highway                                                                                           ~I~.~IH~S h~e                    ~r,~h,~q~e population -                                a~t           ~i~ndi-~qle I
                    P~s~ca~ving ~ov~a~m~en~ts show considerable annual variation.                                 corridor and ~P~h~udh~o~e Bay Kup~wuk o~i~l fields he within ~the                                                                                  4~7~6 more than ~I~np~le ~th~e 1979 ~popula~unn                                                      ~o~m~qvem~qen
                                                                                                     ~-~1~1      had's range In July 1983 the herd Comprised 4~6 ~P~KCMI                                                                                                                                                                                  ad~ap~qla~qho
                            Although rather small ~i~n proportion to the held's                                 cows. 21 percent cakes. and 33 percent bulls ~g-fi~r~ur~l~an                                                                                          Mu~,~ko.- .~,~a highly social. -a~ll~y ~I~nu~n~d in Mixed                                      show the
                                                                                                              ~1~9~6~5)                                                                                                                                     ~n~e~s fields ~f~l~e~i~d s~q~, .1 ~lh~t 1002 area ~p.p~u~l~a~l~l~o~n ~anes                                       Refuge a
                    entire range. ~h~e ~c~a~lv~i~n~g~i~lpos~t~c~a~lv~in~g area is an important.                                                                                                                                                                                                                                                                             n
                    ~de~~~i~~~b~e habitat that has been repeals* used by the                         ~v                                                                                                                                                  s~e-~M~an~y. the ~s~m~a~ll~"~I fields occurring during ~the ~Fu~l ~i~n                                     year~qrou
                    PC~ during ~he$~* critical file stages                                                            Females of ~th~e CA~N ~i~n~j~o~i~n~g in the mountains and                                                                                    August Many bull ~m~u~s~h-~e~n do not ~i~o~na~m with . Mixed                                          Most Irv
                                                                                                              foothills near the western part of ~th~e 1002 ~0~1.~8 Migrate                                                                                  ~%~e~, h~ad ~1- long periods of time. but move from h~ad ~I~n                                       Table
                                               ~(~q2~1~-~1                                                                                                                                                                                                    h~a~d~ associate with Other bulls in Small ~g~lO~u~P~s or travel
                            As ~h~ spring progresses. weather conditions                                      north nor~th-~1 across ~th~e noting uplands so~u~lh 01                                                  ~1~p~.                                                                                                                                 N~.~q1i ... I
                    promote the mergence of swarms of m~u~ls~e~l~i~s~lo~es Harass                                     C.md- Say to ~t~h~e caking grounds ~o~n o~l, hear the                                                                                           g~l~o~o~l, ~g~i~e~m~o~ld. and ~o~lh~q-~ 19~8~5~1 In response ~1.
                    most by these Insects drives ~the caribou into dense                                       Canning and S~la~m~n Rival, deltas A northward movement                                                                                      g~u~l~l~d~a~t~h~i~s or ~o~lhe~r threats. MOO~q- f~o~r~r~i~n 8 ~C~o~m~i~r~i~s~c~l
                    ~~g~r~~~~~~~~ and results ~i~n ~I~n~& increased ~m~o~v~e~r~r~qi to                                     along the Canning Rival corridor also occurs                                                                                              d~e~f-ve ~lo~ir~m~a~l~l~o~o
               ~    areas of relief The groups usually ~mo,,e rapidly ~Io~v,wd ~th~e
                    coast seeking r~efi~e~l~f ~w points rive deltas. ~mu~c~i~f~ta~t~s. ~su~l~e~t~s.                                   CA~N Caking activity has bear co~m:~en~t~r~a~t~ed in two                                                                                         ~Mus~ko- have used the same areas along the
                    ~w~~ gravel bars. banner islands, and in ~th~e sh~alk~av~v~s of                                 areas the vicinity of ~th~e Iowa Kup~aru~k Rive AM the                                                                                        N~egu~anak Ok~wo~ko~v~i~k Ang~f~un, S~a~c~h~w~o~chil. and ~T~an~i~s~tr~en~al~l
                    lagoons ~p~ 2~N Some groups also move to higher                                            Canning River d~e~f~l~o Most years at many ~a~s 1~.000 ~I~w~v~We~,~qj~q/~,                                                                                 K~a~t~a~ktu~rul~l river ~c~h~2~t~r~a~g~e~l ~f~o~r ~t~h~e Past Several years with
                    elevations in the mountains ~I~m ~r~el~l~e~f~ in other years that                                calve c~in ~th~e Canning River delta within fire 1002              ~8~,~0~8 ~(~p~f                                                                  app~ro~Ama~le~l~y ~80~. ~1~60. and 23~0 ~o~urn~i~r~s using those
                    ~~~ be a gradual westward shift across ~th~e co~r~is~l~a~t plain                                 2~Q~) Sc~a~r~t~w~ed. low density taking extends as ~la~r east as                                                                                   drainage?. respectively, ~Mu~s~k~o~l~o~n using the S~a~d~vo~chit
                    and n~~~h~~~~f~o~o~lhill~s                                                                     the S~adlero~ch~il River Little ~o~r ~" caking has been                                                                                         and ~T~e~h~i~s~tr~a~nak weas seem ~t~o be pod of ~th~e same,                               a            High sea
                                                                                                              ol~os~qm~ed in [he TAPS Prudhoe Bey ~O~N Said we* since                                                                                         ~subp~opu~l~a~t~i~On~. whereas ~s~m~i~n~a~l~s in ~t~he ~Ok~w~okov~i~k are
                            The po~s~t~c~alvin~g season is ~th~e low, point of the                          ~1~q6       about ~1~9~7~3 ~IU~. Fish and Wildlife Service. ~I~qM; Whitten                                                                                   seem to be a separate ~sub~P~O~qW~8~0~04~i Many of th~e cows                                          round
                    &must physiological cycle when energy reserves of I ~"~.                           ~.        and Cartoon. 19~65).                                                                                                                       Mused for ~th~e baseline study research in 1982 ~85 have                                       "Wing
                    pediment cows are ~e~s~i~l~mm~i~l~ly ~t~ow The stresses of winter.                                                                                                                                                                            remained in these areas ~(~P~I ~2~r~@~) and show a high ~s~il~e~.                                      High sea
                    pregnancy, migration. birth. lactation. heir mall. anger                                         Ago caking. some, CAN c~anbo~i~r move                                                                                                 specific ~f~id~e~f~it~y, Riparian areas ~a~r~e important travel corridors                            round
                    growth, and insect h~w~as~s~m~e~n~t draw heavily upon this                                       ~s~ou~th~e~a~s~t~i~va~rd. to the uplands south o~f Camden Day.                                                                                       and m~usk~o~xen regularly feed ~th~w~e year round ~D~isp~w~s~&~l Of                                     caking
                                                                                                              During the insect season (Ally~) there Is Often a strong                                                                                   mixed se~a bards into n~e~w areas on ~the K~a~l~s~k~lu~,~.~k Rive                                       Total ~qOb
                    ~~~~~~~ of ~h~e population (Dauphine. 1~9~1~6: While and                               ~V                                                                                                                                                                                                                   curdling                 ~i~qn~qclu~qd~qh
                    others. 19~5~ Access ~to insed-~w~el~v~e~l~ habitat and ~1~W~A~g~O                                   "~s~t~w~o~rd m~o~v~i~@merd ~al~l~on~g coastal h~a~b~i~l~a~t~s between the                                                                                     and ~c~ha~r~n~ages east of ~T~he Ai~eh~i~kk River i~s also ~o~c
                    resc~~c~~ during this period my be critical 1~9-h~e~l~d ~4qd),                             ~4~.    Canning River delta end C~and~en Say. An estimated 2~.OD~O                                                                                                                                                                                w~qe~qs~qs~
                    p~~c~~:~~~~~~ In early k~ily ~th~e h~ards usually move east and                               3.000 caribou of the CA~N use the 1002 area (Canning Rive                                                                                         Though not migratory. ~mu~skoxe~r~% apparently move in
                    sd~ih. vacating ~th~e 1002 w~as by n~i~ld~-Ju~l~y. In certain ~ye~w~sw                        ~i~,-~'   d~eft~s ~a~nd coastal habitats along Condos ~B~a~y~l for po~l~d~-                                                                                    response ~t~o seasonal changes in show cover ~a~nd ~v~e~g~e~t~a~-                                               ~qM
                    residual groups numbering up 10 15.000 ~S~n~o,11~1~2, have                                     ~c~al~v~o~g ~a~nd insect relief 1P~1 2~1~D During ~th~e ~s~u~rnm~e~r. on                                                                                   hop in ~su~m~m~e~ir and ~I~&~S. they are often found ~i~n riparian                                    f~r~onn ~qth~qe
                    remained on the 1002 or" and adjacent                 ~loo~d~ull~s ~a~nd                        additional ~1.000 animals my be ~sc~al~l~a~wl west of the                                                                                                                                                                                   ~1~9~63 ~qF
                    ~~~~~~~~~s through ~Au~gu~s~l. Occasionally. remnants of such                                 S~ad~le~r~a~ch~i~t River ~a~nd north of ~th~e ~S~e~c~l~ao~thi~l Mountains                                                                                                                                                                               ~1~9~q8~q3~q. 19
                    ~~o~~p~ (up to 2000 am~m~a~ls) have w~m~t~we~d in n~or~lh~o~n                                        Riparian areas are used for travel ~C~.~O~r~d~q"~s as well ~i~t~s                                                                                                                                                                                ~re~s~qpec~qt~qi~qv
                    mountains ~nd foothills                                                                   ~Vo~r~lar~il spring and ~s~i,~mm~& feeding areas In l~a~f~t                               ~6qG,
                                                                                                              summer and ~ta~g. CA~N caribou ~w~e~'~4qQ~n~d scattered across                                                                                                                                                                                   MOOSE
                            An international agreement I~m Management of the                                   the ~c~o,~u~g~o plain s~o~u of Camden Say. in ~loo~lhill~s n~ewth of
                    PCH ~ cur~w~ily being negotiated between th~e governments                                    the Sad~k~eo~chil Mountains. and in uplands ~so~t~i~lh of ~the                                                                                                                                                                                         ~qP
                    of the Unr~ed States and Canada. The State of Alaska ~*.~i~t                                 ~S~e~d~ler~o~r~ch~d Mountains where they remain fair the winter
                    provincial governments as Well as local users are                                         During ~m~c~a~l winters. scattered groups of CAN caribou                                                                                      ~z                                                                                           Range
                    ~W~~~~~~ng in ~the negotiations                                                             range throughout the 1002 ores west of the K~a~l~ak~lu~x~u~k                                                                                                                                                                                 Occur ~qs
                                                                                                                                                                                                                                                                                                                                                    ~.0~q0~q3~q0
                                                                                                              River and adjacent uplands to ~the south The nu~m~b~e                              Of                                                                                                                                                     Rive d~qr
                            Harvest of the PC~H occurs ~0 both the United States                                ~vv~in~tering animals ranges from ~100 to 1.000,                                                                                                                                                                                          ~ther ~qM,
                    and Canada The harvest by m~c~k~4i~du~al Native ~v~d~ages is                                                                                                                                                                                                                                                                            Orators a
                    highly variable. depending upon herd movements Recent                                            The annual harvest of CA~N caribou by ~K~ak~l~o~v~il~l                                                                                                                                                                                 ~M
                    annual harvests from the PCH by K~ak~l~ov~k the Wily village                                  residents has ~m~os~l recently beat estimated ~to be 25 ~7~5
                    adjacent ~o th~e 1002 are&. have ranged from 25 ~t~o ~7~5                                      a~m~n~u~i~ls (Pedersen and Co~f~f~ing~. 1~9~8~4). This honest occurs                                                                                                                                                                                       In
                                                                                                                                                                                                                                                                                                                                                    ~W~qW~qp~qs
                    animals (Pedersen and Coiling. ~19~84). Ar~e~su~el h~er~n~e~e~l of                                  along the coast during the summer when residents ~C~a~n                                                                                                                                                                                  Moos*
                    the PC~ throughout ~i~ts range was estimated ~a~t 3.000 5.~0~00                                 travel by b~o~al ~a~nd ~k~f~t~nd during the tag and spring what                                                                                                                                                                               ~t~i~o~qn~qs to
                    ~~ir~al~s ~~eB~o~od. 19~7~2)~ The harvest varies greatly from                                s~t~i~c~h~w~h~r~,~ch~in~e travel Is possible (or 2Q~)~                                                                                                                                                                                            early Au
                    village to village and train year to yew within ~th~e &am
                    village ~~~ annual harvest ~a~t Arctic ~V~i~g~ag~e~. Alaska. ranges                               MUSKOXEN                                                                                                                                              ~6-~6 ~-                                                                           ~a~n~qy me
                                                                                                                                                                                                                                                                                                                                                    moose
                                                                    During 1~9~6~3~45 annual
                    from ~~ to ~.000 (L~o~B~l~o~nd~. 19~79)                                                                                                                                                                                                        ~I~s~,~,                9                                                                   October
                    harvest of the PCH within Canada averaged approximately                                          Mu~skox~m were exterminated ~fro~n~s [he North Slope by
                    1.700 ~~im~~~ for the years in which data v~v~e~re available                                 ~t~h~e late ~1~8~0~0~'~s. so carrying capacity and post historic levels                                                                               Figure 111-5-~Es~t~u~na~led nu~m~b~as o~r ~mu~sk~o~%~@ ~i~n Post                                         moose
                    (Yukon T~rri~~r~t, W~qW~O Branch. unpublished dais)                                           are unknown. Men effort to reestablish ~W indigenous                                                                                               -~1-~9 populations in ~the Arctic Refuge 1972 ~8~4                                       valleys
                                                                                                                                                       EXISTING ENVIRONMENT 29                                                                          ~1~0 ARCTIC RFFU~GE RESOURCE AS~SES~qWENT

    ~0

                      Comprise a Major part of the forage used ~b~y moose.                             Wolves on file North Slope are known ~10 prey n~e,                                                                         M,~o~v~.~"~.     ~u- ~@~n~d ~t~h~e ~1-~.~1                no
                      mou~~a~~ ~a~lde~t is an ~w~a~r~io~na~nt winter load where available              caribou MOOS@, Sheep. ground squirrels~. small ~v~o~r~l~en~i~s and                                                               ~1~1~1~1~4-~1         ~l~u~t~-1-~1 ~. -~I~,~ml~ly                 p~O~p~i~t~i~a~t~o~n
                                                                                              t~o~i~nds Wolves are typically associated with Ch -~ge
                                                                                                                                                                                                                       h~e~,~P~aS -~1-n~e~s ~o ~th~e~, ~l~O~n2 area in.) -~1-~1 ~.~1~.
                             Subsistence hu~m~er~s from Ka~k~l~o~v~ik take one or two                 systems which They use as ~lra~@e~l corridors Th." a~t                                                                       ~o~u~t~o~m~y h~w~ve~l~l~ed by ~K~a~s~lo~a~k ~t~o-~I~m~i~"         I ~Ih~.~--e.
                      moose annually (Jacobson and Wentworth, ~*~9~02) Other                     attracted to riparian areas because of the ~abund~in~c~e o~f                                                                  ~s~o~qh~I~m~q records Too the 1002 area a~r~e %p~a~v~s~p ~F-~I FWS
                      hunters harvest a few moose, generally less than 10                     prey. including ground squirrels During ~Th~e Summer when                                                                  ~sl~o~u~b~" have ~e~ps~u~lted in very ~few ~s~i~qht~,~,~qs
                      annually. from the North Slope of ~The Arctic Refuge Most                play species are MOST abundant. wolves a~re distributed                                                                     W~.~I~ve~m~les feed o~ppo~llun~i~l~l-~I~fy ~and h.~,e b~e-
                      of this harvest is ~0 ~the Canning River and K~o~nga~kul                     throughout a~s 1002 area habitat Types ~(U S. Fish and                                                                     reported pursuing large ungulates such as ~ca~rbou~moose.
                      drainages. and nearly a~l~l ou~i~v~e~le the 1002 area                         Wildl~rfe ~S-c~e 1982. "auger~r. ~19~94. 1985; ~V~qi and                                                                          a~n~d D~al~l sheep. though they are more ~c~r~on-onl~y ~s~c~a~ven
                                                                                              others~ ~1~9~65) Wolves are hurtled and trapped by Kak~love,                                                                 gets than ~O~u~p~d~a~l~a~r~s In ~Oh~s Arctic. ground %~qu~r~ue~lls ~w~o an
                                                                                              residents Most of the harvest occurs in ~Th~e Hu~lahu~l~a                                                                     ~O-~I-~l load Ilia ... It ~and P~,~a~,~son ~1~9~,~72) Cw~rbot~o a~re
                                                                                              Sadlerochi~t~ and O~lkp~dak River areas (Jacobson and                                                                       ~,~a.~e.~q~,~d p~a~d~t~,u~l~a~,~ly during May a~n~d June when They
                      GALL SHEEP                                                              Wentworth~. 1982: Weiler and others. ~l~9~o~f~t~). Gene~v~el~t~y.
                                                                                              fewer than 10 waives ar~e harvested annually. usually south                                                               ale ~n~1~o~l~e~v~o~t~i~s on ~the 1002 ~w~o~& During Jun~e~and July
                             ~~~Ihough the estimated total population of ~Dal sheep             o~r ~The 1002 ar~m                                                                                                                 ~,~I~s~. prey an birds ~and eggs
                      within the original ~8 9 ~m~l~l~io~n~-acr~o Arctic Refuge is ~appro~x~i                                                                                                                                      K~a~ll-~d~- ~p~s~,den~i~s hu~n~i -~w~e~l~oe~s most frequently ~M
                      merely ~.~000 Dal Sheep are very rate ~a~n ~The 1002 area.                  ARCTIC FOXES                                                                                                             ~..~Ih~d~i~s n~o~r ..~,~Th~.. ~a~r~o~t~in~i~e~v~u~lu~, areas of the Sadie
                      because suitable habitat is lacking The Sad~ler~o~chd                                                                                                                                               ~m~chd ~H~u~f~@hula. ~a~nd O~kp~d~al~l Rivers ADF~9G records
                      Mountains contain an estimated 270 sheep. and ~co~n~s~l~at~t~l~e                       Arctic foxes Marto seasonally between summer                                                                      indicate that an average o~r about ~O~ne w~a~t-tr~ie p~e~r year is
                      ~h~ n~rlhernmo~s~t extent of their range ~i~n North America                 breeding habitats in ~w~a~r tu~nd~s and winter habitats along                                                                 harvested from ~The 1002 area this my be an
                      (~G Stalin. ~19~7~9)                                                       ~Th~e no~r~ih~qm Alaska coast ~a~nd Onto Ohs $to ice                                                                             underestimate because of ~s~oc~omp~te~le reporting ~Mag~oun
                                                                                              (Ch~ese~more~. ~1~9~6~7). They we limited In their range by                                                                     ~(~1~9~8S) believed that h~a~mes~i in Game Management Unit 26A
                             Traditional Summer range consists history ~a~t ~s~p~arr~i~e             habitat and ~in~le~spec~ific competition with red foxes. ~(~2qV                                                                  ~(Western Arctic) was 2 to 10 times great& than reported
                      slop" ~~nd meadows Winter range. ~q"~ad mostly by                           Periodic outbreaks of rabies can reduce fox p~op~u~t~a~l~l~o~n~s                                                                  During the warder of 19~80 81. seven wolverines were taken
                      topography. consists of windblown slopes and ridges.                    Productivity ~a$ foxes is totaled to abundance of m~ocr~ofin~ts                                                              by K~ak~l~o~v~il~l residents ~1.~1~a~c~obs~on and Woodworth ~1~9~82)
                      usually south-facing FWS surveys Indicate that Dal sheep                (small rodents). Foxes replete ~th~o~w food supply. despite                                                                 Wo~Ne~r~in~es ate Sometimes harvested by trappers near ~The
                      have used the Tower foothill t~erra~n near Sad~leroch~il Spring.            fluctuating prey availability. by c~ochin~g load in early ~su~o~nn~o~o~r                                                         village of K~a~k~lo~wk These animals ate mostly ~su~b~adu~h~s
                      mostly in winter; in summer. they cross this ~tu~r~i~alr~e w~e~s in            when prey is abundant and utilizing food caches and                                                                      that my be d~ispe~rs~An~g onto ~T~he 1002 area ~kom the
                      moving to other habitats TO Ross and M A Sp~o~i~d~w                         cartoon ~i~n tole summer when ~f~orwe~ir prey are available At                                                                ~l~o~a~thi~ll~s ~to ~The south Information is lacking is ~10 whether
                      unpublished data. 19~91)                                                 Demarcation Say arctic ~fo~r~r~e~s spent most of Their time In                                                                the 1~0~0~2 area wolverine p~opu~fali~on is resident or transient
                                                                                              ~on~w~il~lum tariff. low center polygon and meadow habitats.
                      WOLVES                                                                  preying an small mammals ~a~nd bird nests (Burgess. ~1~984).                                                                 BROWN BEARS
                                                                                              In ~1~9~1`~9 when ~md~an~I~2 were ~a~t low population levels. foxes
                             W~~r~l~ove~i are lou~nd throughout Alaska's North Slope               at Demarcation Say depended mainly art birds end eggs.                                                                     Brown bears Seasonally use the 1002 area At
                ~     On the 1002 ~we~e. ~Th~e population density is lower Than in                No pups wee pr~i~adu~ced that year (Burgess. 1~984).                                                                         pounds of greatest abundance fill June~) ~u~se ~is estimated at
                      areas ~~~th~e~r south Wolves occupy large home ranges             In             Arctic taxes are Trapped by ~K~ak~lov~ik residents in the                                                             me beer per 10 square miles. or ~apg~xo '-rely ~1~0~0 boa's
                      winter wolves tend ~to congregate ~I~" areas of over~o~vi~rdering                                                                                                                                      ~fr~i~x~i~M~er ~a~nd others ~19~8~4) ~8~,o~w. bears north of ~Th.
                      ca~~~~~~ and possibly moose or Dal sheep Dealt move                     ~q@~f~w ~f~a~r Our Th~e number Oak" s~o~m~m~o~s~t~i~r fluctuates                                                                         Brooks Range ~w~, ~.~1 ~th~e north- limit ~O~f their ~r~og~e
                      Intent depends on availability of p~r~ov Estimates of density             according to Their abundance In years at abundance Moore                                                                 These populations are characterized as having low
                      ~~~ restricted geographic areas ~v~w~v widely. b~u~t most Oaf                than 100 foxes my be l~a~k~m Most trapping is within 1~5                                                                     -~wo~ok~ic~irve rates as a 'nun of $hall Pounds of food
                      within the range of ~8 ~to 200 square ~m~il~in per wag (Mech.                miles of ~Th~e coast. Mainly on or new Bedell Island                                                                       ~o~l-~r~i~d~b~l~y large ~ind~w~.~1-1~1 home ranges (95 ~to ~520 Square
                      1~70~ Mating occurs in March. and pups (usually 4 ~7. p~a~r                (Jacobson and Wentworth. 1~982)                                                                                           md~e~l~l and habitats that Provide Mile pr~o~l~ec~i~,e cover
                      final are born ~i~n dens 2 months later Although the 1002                                                                                                                                          ~I~F~I~P~V~n~o~l~ds and others 19~75. Reynolds ~1979. Gain& Water
                      arm appears to contain suitable donning habitat. no dons                WOLVERINES                                                                                                               ~ind Marto 19~9~3)
                      have been found Dens Thai have been d~ocu~men~ced are ~i~n
                      m~~~~~.~c~r~u~s terrain ~10 to ~40 Miles swill of ~Th~e 1002 was                       Wolverines frequent a~l~l types of ~I~s~ma~rn found in A~sc~l~ic                                                             ~f~1~low~n bears appear ~a~n the 1002 ~a~t~e~s ~n late May
                      The number of wolves using ~The 1002 area on a seasonal                  areas  as evident from observations and ~l~o~ac~k~s Rovers and                                                                andIare generally most ~o~bund~a~n~i during June and July
                      basis is low ~a~nd apparently does ~n~ot exceed 5.10 animals                Mountains ate frequently associated with territorial                                                                     when contralto are most plentiful The beats breed during
                      annually                                                                boundaries S~n~o~w~ed~a~t~is are Important ~f~or~ol~o~v~erin~e d~e~n                                                                   this same period Brown bears ate found ~I~t~t~r~a~l~l~igh~o~u~l the
                                                                                              soles. and. in the handle. ~rem~o~ran~t snowdrifts In small                                                                  -1~o~e 1002 area There ~a~r~e two known. ~f~i~-~gh~u~s~e areas
                            Popu~t~a~t~i~o~ns in or adjacent to ~Th~e 1002 arm were                   drainages are used by females for testing their o~f~fspr~ong                                                                On~e used by SO 70 ~wk~i~l~l bears and cubs I ~i~n the
                      depressed in ~Th~e ~t~at~s ~1~9~1~41~1~'~s by an ou~lt~ar~e~s~~x or rabies A             ~(~M~a~g~o~u~n ~1~9~8~5~)                                                                                                            southeast~q- ~se~c~t~ic~u~l of the 1002 area where c~a~u~b~w
                      ~~~il~r Outbreak occurred in 1~9~65 when six dead wolves.                                                                                                                                          calving ~is ~co~n-~ha~t~ed The Second. u~le~d by IS 20 bears
                      Including four radio-colored ~anim~s~t~s. were found, Four of                      A I~e~w wolverines inhabit ~Th~e 1002 ~are~w Accurate                                                                   Is a Much smaller area along the upper teaches of the
                      the animals were confirmed as rabid. Historical don she%                population figures we unavailable  ~1p~tough estimate of ~O~ne                                                            l~o~a~t~ak~lu~n~d~, River ~O~p~t ~1~1~2~) Motivate use (~30 00 b~e~ws~l is
                      ~~ the ~~~n~g~s~ku~t. ~Hu~t~el~oul~s. and A~l~chd~i~k Rivers were                     1002       ~v~m~k~w~in~* population c~ar~l be mile from the                                                                      located between a~nd wound the high ~use areas and a~re
                      ~~~~~rl~d in 1~9~6~5 Death of breeding wolves from rabies                  wolverine densities and ~as~su~r~o~g~it~ions used by Mag~ou~t~o                                                                    generally used I~m . sho~der period ~l~k~in~e~-~Ju~l~y~l ~JN~o~te That
                      was suspected as the reason However. fault n~e~w dens                     (19~85) ~l~o~t estimating the population in ~Th~e West" Arctic                                                                 heat numbers born e~ach~se area cannot be~~added
                      were found. three of Ohm occupied by wolves which were                  On M~a~g~ou~r~t'~s assumptions. the estimated density ~f~a~r ~Th~e                                                                  h~,~1p~p~1p~p~hey represent ~d~~oll~e~r~m~t times .1 residency Each
                      ~~~nn~r~~~ of sadist~ ~p~s~o~cl~u~s                                           ~t~0~02 a~t~" is 90 wolverines This figure my ~no~r be very                                                                     beat may tole More than one at a~l~l areas delineated I After

                                                                                                                                 EXISTING ENVIRONMENT 3~1                                                               ~32 ARCTIC, REFUGE RESOURCE A~%~%F.S~SM~ENT

    ~0

                     ~:
                     If ~~~~l~~~~ Pa~; of the ~l~0~n~? ~-~I- the brown lemming Is                               which polar bear dens and ~d~r~i~o~n~t~o~g ~a~c~t-~b~i~r have ~h~i~m                                                                                   ~IFA~I I ANT~) W~I ~IA~I I ~S                                                                ~S~q'~q.~qI~qe~qen
                     ~ore along th~e coast and ~i~n high popu-                              absented ~d~ur-~9 more then ~O~ne i~i~w n-, or r~r~i~m~i~n~g                                                                                                                                                                             ~b~q.~qm~qw
                     lation years can account in, more plant consumption then                            activity has also been observed in other ~1002 a'"                                                                                           ~n~.~n~q~e~l            ~b~e-~l~ed -~1~1 -~d~                                               ~"~qIn~qA~qr~qe"
                     ungulates ~~~~l~t~di and others ~19~80) ~fr~i~p~ac~i~s ~a~n the                                  locations bu~t data ate inadequate to confirm recurrent Use                                                                            Polled -~.1~,              ~in ~th~e ~R~e~r~a~t~t~l~.~,~t Sea ,.,1 ~.1-~1 ~th~e                          ~t~w~qo g~qe~qn
                     vegetation ore cyclic and correspond to the brown                                                                                                                                                                         ~c-~I north of ~the co-~l~a~t plain. ~lnc~fud~,~n~g ~l~b~e ~l~a~g~o-~n of                                ~w~qr~qi~ql~ql~qa~qnd
                     ~~ ~ to g's I to ~5~-~ye~ar population cycle L~e ~r~a gs and                                                                                                                                                                     ~]~b~- 1002 .~1~-8 ~(~1~) S Fish ~and Wildlife Ser~v- 19~4~2~)
                                                                                                                 Female polar beers that ~i~t~" ~a~n land move onshore                                                                              A~llh~o~k~i~gh there is %area evidence of tinged seal% ,thin the
                     vales are active as year. ~gr~alin~g frozen plant material and                         to seek -~1 den sires in October a~nd November ~d~e-d~u~I~r~t                                                                                 refuge ~In summer ~&.~i~t ~ta~g, their pri~m~a~ny h~.~H~.~1~, - ~q~r~m~w                                n~uel~qls    A
                     t~~~~~~ g under ~The snow Maximum population den~s~i~lie~s                               ~m ~i~ce ~i~n~a~ver~e~r~ml ~a~nd ~I~c~e buildup in ~th~e tag I~t~e~n~f~i~e~l' ~A~nd                                                                             By ~n~u~t~,~e~f~e~, ~the ~1~1~1~0~2 a," Ringed s~e~a~[~, rise stable. share                             cover In
                     occur ~~~~ successful winter reproduction Shallow snow                              Hensel. ~1~9~9~0~1 Denning females give birth to I ~o~rr 2 cub%                                                                              fall ,,~@ ~a~s their pr~u~m~a~ry pupping habitat (T ~n ~S~m.~lh 1~9~90)                            season.
                     depths result ~i~n low temperatures under ~t~he in" creating                            in December at January and bears ~i~sn~"~9~0 in tire M~f~i~l~r~h n~'                                                                             to ~i~v~i~n~o~v~e, chances of successfully tearing pups, older.                              June an
                     ~~ energy stress that ~c~a~n reduce winter reproductive                                early Ap~r~e~. depending upon weather c~a~n~d~ilio~ns The ~f~r~e~m~a~l~,                                                                             more dominant female ringed near$ select and c~l~i~v~e~fy                                  birds a,
                     success                                                                             and cubs generally remain ~a~", the den. making short                                                                                   defend ~I~r~v~e~r~d~mi~e~S an stable sh~o~n~e~-~l~as~t ice f~a~r pupping                                staging
                                           MARINE MAMMALS                                                ~l~a~r~ays f~a~r 1 1~0 2 weeks ~u~r~a~t~o the cubs gain strength and                                                                              Subadu~ll onto ~y~oun~r~ier females are ~l~orc~od to construct Is"                            until fr~qe
                                                                                                         became acclimated to Outside conditions ~SO~-~o ~th~"~I'~s~l~i~e~r                                                                               on active pack ice ~i~n~c~t~e~n~s~ing the chances of p~t~ed~a~l~l~" by
                                                                                                         they move ~to the ~a~m ice Its bled ~a~n seat' Many females                                                                                polar bears Bearded ~i~m~i~s are chiefly ~a~i~s~oci~n~led with ~the                                        L
                            Fourteen species of marine ~o~u~rr~o~m~a~l~s my Occur Off                            ~w~q:h new cubs concentrate their foraging ~a~n ~th~e shore last                                                                             Pack ~i~c~e edge throughout ~th~e yea,. Primary breeding and                               ~o~re We
                     the coast of the Arctic Refuge Some of ~lh~e~s~e~.~-~I~f~t~e spoiled                          ~I~c ~. which varies ~i~n width from ~0 ~f~e~w feet to more than ~30
                     seal and walrus -we occasional wisdom~Others such as                               role,                                                                                                                                 Pupping habitat is ~a~s~lo~ci~at~ed with the Ice edge A smog                                More ~qth
                     t~~ killer whale. Way wh~a~h~t h~urr~o~pb~o~c~k whale. ~a~n whale                                                                                                                                                                    ~m~r~o~b~w of bearded seals remain in northern ice bound                                   o~ldsqu
                     narwhal. harbor porpoise. and hooded seal Ste Only lovely                                                                                                                                                                 areas The extent of active Pack i~c~e use by ~3~-~81~3 Is n~o~t                               water ~qP
                     ~~m because this part of ~the Beaufort Se~a is of ~the                                         When the n~e~w~sh~a~te Ice breaks up In the Spring. ~th~e                                                                            w~a~s understood within the t~O~O~2 area, ~Ho~w~"~m seals in                                   ~m~qa~qy be
                     ~~~~~~~m ~~~g~r~n of their ranges Five of the species verve                            beers move with ~T~he sea Ice Slid r~e~a~r~m~y concentrate at The                                                                            Canada do occupy active pack ice. a preferred hunting ~@~(~@~a                            from lei
                     evaluated polar bear. n~o~g~e~d seal. bearded semi. be~fu~rg~i~s                            south edge of the pack Ice, This position varies ~s~w~is~on~a~ll~y,                                                                          fair polo, bears (~F~1p~mith. 1~9~60)                                                    ~e~nd ~qSan
                     whale. and the endangered b~o~@~h~md whale.                                             but usually is between the coast and latitude ~72"N                                                                                                                                                                          during I
                                                                                                                                                                                                                                                     K~al~d~ov~ik residents h~o~me~s~o spotted. ringed. and                                  imports
                     POLAR BEARS                                                                                                                                                                                                               bearded seals for su~b~,~l~s~l~ence, though relatively low, seats                           and ~qa~qlh
                                                                                                                 Except ~fo~r ~a share lead. ~The Beaufort See Is                        Ice                                                       we taken ~(~J~a~c~d~bs~m ~a~nd Wen~t~w~i~c~r~ih 19~8~2)                                                and b~qt~qa
                            Polar bears are closely associated with Pack ice ~a~t                          covered year~-round, Open water n~e~ar~sh~me begin$ 10
                     the Arctic Ocean Throughout most of the year The ~@                                  freeze in September ~c~o October. and ne~w~sho~r~e ice does                                                                                       ~Bowh~e~nd and gray whales are listed ~as endangered
                     Beaufort Sea population of polar bears ~a estimated ~10 b                             ~n~o~t ~v~a~f~t until May or ~w~o~r~t~y June. Mate ~a~nd n~o~r~id~enn~in~g                                                                                species Gray whales ~w~o Occasionally found In ~th~e                                      ~w~qint~qeri~qn
                     20D~ Some females move ~to coastal 1                                        ~1~6q6       ~f~a~m~a~l~s polar beam Inhabit the sea ice throughout ~th~e                                                                                  Beaufort See. north of the 1002 arm (U S Fish ~and Wildlife                            ~I~. differ
                     ;;;fly farther Intend during October and Na~v~err~i~f~te, to                             winter The d~i~s~t~rib~u~a~l~m of polar bears Is influenced by the                                                                            ~S~er~v~i~r~c~@~. ~1~982) The b~orwh~e~ad whale Is known ~10 Inhabit                                national
                                                                                                                                                                                                                                                                                                   p~l~e~m~b~e~r and                       been IS
                     ~~ maternity dots %ties Pregnant polar been, ~a~nd farm                       -       :v~al~o~bil~i~f~t~y, of their ~A~RI~O~! prey species, ringed ~a~nd bearded                                                                         waters offshore of the Arctic Refuge in ~S~e
                     their cubs probably spend more ~b~o~r~t~o ~a~n the 1002 area                      ~6q&         egos. which concentrate in arms of drifting pack Ice                                                                                 October during As fall migration along the Beaufort S~m                                Soviet
                     than ~~h~~ sew ~u~l ~1~2 ~a~t the polar beat Population Ollie~,                            ~(~L~e~n~t~ler. 1~9~71: S~l~i~t~in~g and others. 19~1~5) Ringed goals                                                                                coast the southern boundary of the b~o~whe~ads~' ~?~a~l~l                                     addition
                     Woos of polar beam seasonally ~trequ~e~n~t the coastal                                  probably c~o~n~s~l~i~b~u~t~e ~9~5 p~o~n~c~e~a~l of the polar been's diet                                                                               ~"~i~7~s~l~i~on c~a~p~od~ar is generator the ~68 loot ~isob~a~lh. ~@11~bou~gh                           contain
                     periphery of the ~w~as Recapture of polar bears marked by,                            (Bums ~and ~Eley. ~1~9~7~8~).                                                                                                                they ~o~re occ~*si~on~s~l~y seen in shallower water Demarcation                              W~q4d~i~qf~qf~ql~qe
                     ~~~ FWS ~~ recent years indicates that            "    flu. of females                                                                                                                                                    Bay past of the ~1~0~02 area is a feeding area f~a~r these                                 agree.
                     accompanied by cubs as old is 20                                           1~1               Polar before are pr~a~lec~i~ed under' ~Th~e Provisions of ~the                                                                       h~A~fes: wales off the 1002 wee may also be used
                                                                                                                                                                                                                                               (National Marine Fisheries Service, ~1~91~13) Belukha (belu~ga)
                     Starlets coincides with the Is$ ice-edge advance to the                             Memo M - to P~r~o~l~e~c ~l~o~t Act of ~1~1~9~72 An ~in~i~qm~e~t~t~o~n~a~l                                                                                   whales also ~o~r~i~q~u~a~le through waters north of the 1002 area                            ~c~a~ql~qe~qgo~qt,
                     shoreline                                                                           ~ag~r~e~t~w~o~o~l~o~o~l ~l~o~t the conservation of polar bears was ratified                                                                                                                                                               sh~qo~ql~qeb~qir
                                                                                                         in 1~9~7~6 by ~the g~o~ve~n~a~m~V~i~S of Canada.               Denmark. Norway.                                                                         ~B~o~wh~e~ad whales are taken fair subsistence by
                            Polar beat dens have been found as ~f~a~r as 2~50 miles                          the Un~l~o~o of ~S~ovi~d Socialist Republics.           and the U~n~hed                                                                       residents of K~a~k~lov~ilk Subsistence whaling of K~n~I~to,~v~il~i                              SWANS
                     offshore and 32 miles Aland Eighty ~s~e~q:~- p~q%.~-~I :~qb~qO~qSn~.                                States o~f America, Article of ~w~o~u~s~e~s That Appropriate                                                                                 b~e~rp~m in ~19~8~4 During ~1~9~91,~6~5 the annual h~a~m~e~s~t hill
                     located in ~~~6~3 ~T~I~S were Offshore The               ~a~q. am                  It       actions be fakers to protect ecosystems o~f which Polo,
                     the Colville delta to the Canadian border is within ~th~e area                        beers ate a pan. especially de~n~n~i~n~g and ~f~e~ed~l~l ~9 also                                                                                averaged me whale. with on "wage of one additional                                              T
                     used by the Beaufort S~am population of polar beers for                                                                                                                                                                    whole s~tr~u~el~, and lost each year                                                      thaw-to
                     de~~~n~ However. the most consistently used tend
                     de~~~~~~ ~~~~s wee ~o~n and adjacent to ~th~e 1002 wag                                           ~L~!~q~1 ~f~t~y~"~qf~qt~s of polar bears my o~iccur seasonally                      2~0                                                                                     BIRDS                                                  ~qZ~6qZ~q"~q,
                                                                                                                                                                                                                                                                                                                                     ~M~qa~qy an
                     ~h~~~ ~.2 dons were found in ~4 ~a~t the 5 years. between                              along the coast of the Arctic Refuge near ~T~h~e village of                                                                                    one hundred eight        special of birds have been                             Tommy.
                     winter 1~~1~02. when the ~q" began ~a continuing study ~o~r                              K~eh~i~o~vik h~e~r~* wh~a~f~t c~o~n~c~as~s~es c~o~m be ~Sc~i~W~e~ag~e~d
                     North Slope polar boars. and winter 1~9~6~5 ~0~6 (A~r~n~s~w~i~f~l~.                              ~(Am~s~trup and o~th~e~m. ~T~O~M) Each year many basis are                                                                                     recorded on the Arctic Refuge coastal Plain ~(~6~8~i~n~e~r ~and                               takes.
                     ~~~~~~~~~ The ideal de~n~n~ing sit" am riverbanks. dr~av~m~. "~i~t                          available to ~101CIll subsistence hunters. but ~1~. most recent                                                                          Reynolds. ~19~11~6~2. b~l. The majority ~a~re migratory present                              ~of~qi~qv~qi~qo
                     the ~~~~a~d side ~a~t bluffs where snow accumulation is                               years ~th~e kill has been ~a~qm~$ ~(FWS. unpublished data)                                                                                   only from ~M~a~y to September. San species ore considered                                ~191~q1~q1~q2 to
                     sufficient to support den construction At least ~1~5 d~On                              Annual subsistence harvest of polar beets by local                                                                                    permanent residents rack ~a~nd willow p~l~arm~ig~an. snowy Owl.                             Square
                                                                                                I                                                                                                                                                                                                            The                     offer
                     .~~~ located a the 1002 area. 1~9~51~0~5 ~(p~l ~I~f~J. Another                               residents was as NO ~as 23 to ~2~8 ~in 1~9~90 ~81; ~01 forest we                                                                              common raven. ~gyrf~al~co~n. and Am~i~lr~i~c~a~f~t dipper
                     love dens have been located on ~IC~S near ~th~e 1002 ~I~t~s~*                               pow beer ~w~as confirmed as being taken In each of the                                                                                  common and ho~s~l~y ~r~e~d~p~oll~. ~i~v~or~v Wool. and Ross* quill                                 Average
                                                                                                         Wowing ~4 yews. with three bears being taken In 1~9~85 ~N                                                                                 Occasionally winter on the ~1~0~0~2 wee, Twenty me species                                studied
                            Three ~~a~i~c~l~i~f~l~ons in the 1002 arm ~(p~l I~E~) ~h~e b                               ~(S~c~h~f~i~e~be. ~1~9~65~. Jacobson ~a~nd Wentworth. ~i~s~e~z: FWS.                                                                                   occur offshore. mostly ~f~r~o~a~r tell July to mild S~ep~f~w tons. with                       th~qe b~qr~qe
                                                                                                ~"' ~'-~f~r~qa~2qw~q) ~u~npub~ash~ed data).                                                                                                                                                                                                         those ~q9
                     delineated as confirmed d~e~nnin~g arms~that is. *less                       ~-~k-~1                                                                                                                                           distribution generally ~g~r~o~ned to within 35 miles ~a~t ~$~b~a~n~@

                                                                                                                                                 EXISTING ~EN~v~moNMENT                  33                                                       ~34 ARCTIC REFUGE RESOURCE ASSESSMENT

    ~0

                         reported include arctic chat, arctic g~r~A~t~i~ling~, arctic c~isc~o                   solved ~ox~y~l~ler~v concentration. Include density n~t ~n~i~g~i~m~s                s                                       ~s~chn~n~i will~, ~i~n~,~,~, ~I-~c- ~I~~h~,~,~,y ~qv              ...... ..... ~n~ -       ...........       ~T~h~e re-
                         arctic flounder. ~f~ou~rhom sculpin. least c~osco. round                           in the p~a~n~. ~a~r~e~.. species' ph~y~%i~o~l~og~i~c~a~l ~f~i~n~l~e~r~anc~e~i. ~v~o~r~m~i~e                                                    ~P~.~01 ~;~i   I ~I.~Ich-      A ~vn-~o~n~n~al ~,~f~n~,~a~h~.~n                                      ~f~h~l to j~e~n~t~l~qy off,
                         whitefish. broad whitefish. ~hi~n~esp~ine ~s~tic~kleb~ack. chum                        of he pool ~l~emp~e~ra~b~n~e. amount of organic -~I~t~e~r~-~1 ~T~he                                                          ~I~n~i~n~,~l~i,1~1~.~d ~in 19~1~11              ~n~d -n~i~n~, high ~1~i,h.nI                         ~1-~0 fi~l~k~il~y 1. con
                         salmon and b~urbol Lake ~IT~Ou~l a~re also found in several                         ~n~Ru~enc~e of springs        ~Ov~er~v~i~r~m~le~r~n~i~f habitat is probably the                                                ~e~m~oV~i~n-~l~i tot ~the ~1~"~ It-) ~s~r~h~o~ol ~y~e~n, w          ~s 3~6                        ~s~t~i~s~c~e~p~l~i~b~l~e ~qto ~qdi
                         lakes within the Canning Rive drainage but outside ~the                         greatest limiting factor for Arctic ~an~a~d~f~am~o~u~n and fresh
                         1~~2 area Other 1002 area streams (111 1~9) that support                        ~w~r~i~l~er fish populations ~(III ~l~y~)
                         fish Populations are hated below,                                                                                                                                                                      K~a~k~t-~L has a health clinic staged by a            h~e~a~l~l~h aide
                                                                                                               Springs supply most. if no~r ~o~f~f. of ~th~e ~I~t~"~ flowing                                                     Two N~S~R Department of Public Safety Officers              are ~l~o~c~a~l~l~e~l
                                   Streams that support fish population,                                water in ~the  ~ 1002 area during late winter Th~e ~i~m~p-l~a~n-                                                       at Ka~6~t~o~v~s~k, federal f~a~r~d~if~i~e~s include ~the Post          Office ~th~e                      Re~cr~eal~qiona
                                          ~lexclud~ing Canning River)                                     of springs ~[~a~t spawning. ~e~sm~g. and ~o~v~er~v~v~in~f~er~in~g arctic                                                        Arctic l~i~-~hu~g~e~ held office and the Bar Main DEW site                            related to wildlife
                                                                                                        fish populations has been well do~c~t~i~m~e~n~t~l~ed in ~th~e Arctic                                                                                                                                        of r~pcreal~i~on are
                         A- Arctic gT~o~ry~ling.,              C  An~od~romous arctic chat                   Refuge and other Arctic area, Macro invertebrates (a~m~i~ali~c                                                                                                                                       climate. and poor
                         8: Resident arctic   Char          D  Pink salmon                              ~i~n~l~oc~l~s consumed by fish) are generally much ~h~i~m~e                                                                                        ARCHEOLOGY                                              annually Wet an
                                                                                                        abundant and diverse in spring, and spring led sections of                                                                                                                                       summer season
                                                                                                        Stream channels than ~i~n other Arctic Refuge ~3~1~t~ram habitats                                                             Appr~o~xi~tr~af~ely ~100 archeological sites ~a~re known ~to                      periods of cold a
                                                                                                        ~(~G~lesne and ~D~e~s~ch~e~irm~pie~t. 1984~)                                                                                occur within the 1002 area ~(pl ~I~N, Doled sites appeal ~t~o                         recreational uses
                                                            A        a       ~C                 ~D                                                                                                                        be comparatively recent and of either Historic ~Inupia~l                           almost exclusively
                                                                                                               Lakes are uncommon in ~the 1002 area The ~f~e~w that                                                         (approximately AD ~t~83~8 p~i~e~s~"~l~) or Western Thule (about                           use of the 1002 a
                                                                                                        exist ate generally ~lhaw lakes located along ~the coast                                                          AD 900 ~t~83~6~) origin, Several smaller ~s~i~tes~.~-m~os~i~ly ~sc~a~f~ier~s                      better known and
                         ~~~~y~~al, R~w~e,                    ~X                                           Lakes less than 6 Or ~7 feel deep generally lack fish over                                                       of r~dh~ic debris from the manufacture. maintenance. and use                       improve
                         ~~k~~~~r~ak Creek                  ~X        ~X                                  ~w~a~r~t~er~in~g capabilities they either ~be~eze to ~the bottom by                                                       of s~l~a~h~e ~I~c~a~l~s are no~t yet datable bu~t ~m~ay be considerably
                         S~~~e~~~hd River                   ~X        ~X                         ~X        Late w~in~fe~, or have pow wale quality because of freeze                                                          aide,                                                                                     The most c
                         Hu~a~u~~~ River                    ~X                ~X                          concentrations of dissolved solids and I" dissolved oxygen                                                                                                                                       area are h~u~n~qli~qng.
                         Al~u~~k~~~ River.                  ~X                                           levels Lakes near the coast my be brackish. Owing ~to                                                                    Sites neat the 1002 area ~a~re known to be a~s much                         the larger rivers s
                         Ok~d~k Rive                        ~X                                           saltwater intrusion or windblown ocean spray. In contrail                                                       as ~6.000 years old ~fU S Fish and Wildlife ~S~a~r~v~l~c~e, 1~9~8~2~)                A        ~A~u~ch~i~f~il~k ~O~lh~qw re
                         A~ch~~k River                      ~X                ~X                          to ~the more inland lakes, some shallow coastal lakes may                                                        fairly widely accepted date from the Old Crew area of the                        photography~q, sigh
                                                                                                        be ~fr~o~~p~r~orl~an~t summer feeding areas f~a~r ~anad~r~o~r~m~iu~s and                                                        Y~uk~" ~T~er~ri~l~o~ry ~(~ab~ou~ll 1~50 miles ~sou~lh~pa~s~l of the ~I~0~n2                           nature Study~, M~qe
                                                                                                        marine fish. depending an access                                                                                weal indicates that people have been present in the                              variety ~a~t these a
                              These and many other smaller streams and coastal                                                                                                                                          ~9~"~e~c~a~l rare ~f~a~r ~the last 27 ~O~M years Even though sees                            ~sn~ow~m~a~b~l~i~n~qg
                         takes hove Populations of nmesp~i~ne s~t~ick~lebac~Ps The                                   Coastal lakes ties, the Canning Rive de~h~a~. sampled                                                       ~a~t such on early period are ~f~e~w. %ties 5 ODO ~6.000 years old
                         Other maim streams ~i~n ~the 1002 area ~(~Ka~l~a~k~l~u~n~u~k Amer                           during su~m~m~i~m. have contained arctic char. arctic g~r~ay~f~ing~,                                                     my occur on ~th~e 1002 ales, but ate ye~t to be discovered                                   In ~1~9~9~q4. 13
                         Marsh Creek. Carter Creek. Ja~go Rive and tributaries                           arctic flounder. round wh~i~l~efish~. and broad ~wh~i~lefish (Ward                                                                                                                                      ~th~ou~r~sh none ~qauid
                         "risk River. ~S~i~k~r~e~lur~ok River A~n~q~u~in River and Ko~go~lp~a~k                        and Craig. 1974) In deeper ~m~e~r~m~l~o~in and football lakes to                                                               In the ~1002 ~&~fe~e archeological sites may occur                           ~r~e~c~r~e~ali~o~nal guide
                         Awe) apparently do not support maim fish populations                           the sough at the 1002 area. arctic chat. arctic g~r~a~y~f~i~ng.                                                       ~w~e~h~i~S~I anywhere However. some w~i~l~a~s we much more                                 ~a~n the refuge F
                         ~T~h~~, my Support fish locally and ~1 ~qme as summer feeding                     ~and~/~w take Paul ~m~ay be found The best known and most                                                            likely ~1. have ties. especially coastal ~P-s ~a~nd ~c~iff~S~h~ore                        the 1002 ales. F~qf
                         areas IN a ~f~e~w fish but ~s~ee~n~Qn~q~y lack ade~a~rt~rat~e                               widely used for recreation and subsistence we Lake Peters                                                       b~a~f~f~e~w islands Most Identified ~s~ite~t, C~O~"~S~is~f Of ~t~he remains                     Figures ~a. ~h~qo~qm~qqu
                         ~~~r~~~~~~q h~ab~o~&~I                                                              ~a~nd Lake S~c~h~t~r~ider. in the ~h~e~s~c~h~v~e~t~v~t of the ~S~a~c~n~e~c~t~i~ch~i~t                                                       of led houses log cabins burials~. cache.$. lookout ~T_~s                           probably ~I~t~h~qi~qt~qe~qr ~qi~qh
                                                                                                        River These takes contain at three ~a~t the ~s~l~ar~e~m~er~i~ll~on~ed                                                       and related features Older sites mist, hove became buried
                                                                                                        fish species                                                                                                    under considerable sediment                                                      over the ~1002 are
                              The drainages that original# in or ~f~ir~an~s~m~i the 1002                                                                                                                                                                                                                       the ground in ~qth~qe
                         well range from small ~In~f~e~m~i~l~l~e~c~i~f flow lundr~a streams 10 the                                                                                                                                                                                                                   other locations on
                         Canning ~~he~, which hat an estimated ~SO~-ye~s~t flood                                     Most Native subsistence use of ~f~i~th ~accur~ts along ~t~he                                                            Archeological sites are ~of~s~a ~h~i~e~f~y along rivers and
                         discharge of ~t3 ~500 cis (Ch~dde~r~s and others. ~1~9~7~7) The                                                                                                                                         streams that class the ~f~00~2 wire Own the Philip Sr~d~th
                         integrity of n~pw~u~m areas is Important ~l~e~t maintenance of                       coast Arctic char and arctic c~t~s~c~o are the primary species                                                      Maim~,~.                                                                                           WILD
                         water quality and fish stocks an ~Th~e Coastal plain Most               ~a~t       caught during Summer when they a~r~e present in large                                                                     ins These rivers could have. provided fishing areas
                         the water present IS a result of precipitation. surface                        numbers ~i~n the Arctic Refuge lagoon systems The arctic                                                          Ind would hove been natural travel ~m~le~s between ~the                                       The Arctic
                         pe~~~~~~~~~~ thaw processes, deep                                              c~i~sc~o is an international resource believed to ~or~qW~a~t~e in                                                                nd the foothills Sites known f~rOm ~the Over, course%                      unit that protects.
                                                               -lake drain. or swings                                                                                                                                   ~q:~1~0~i~qo'~qc~h~ie~ll~y~ lent rings. although thrive file two Interior sites               spectrum of the ~qv
                         Peak ~~~~~~, are associated with showmen in early s~u~f~f~r~o~m~e~r                    the ~M~acI~n~t~i,~t~r~ie Alves in Canada Some. subsistence use of
                         or with ~~~n~t~a~ll during late Summer~ slid fall. By tale                         arctic cod occurs ~i~n winter in apparent response to Its                                                         with sod houses Points of particular Interest we high,                           America~ Appro~qx
                         October~most rivers ~i~n ~t~he 1002 area have no measurable                       increased abundance during that time Arctic cod ~(~L~q"~r~y~                                                          well drained banks. especially near stream ~c~on~f~luence~s                           designated as ~qwil
                         Now As note areas freeze ~h~i the bottom. ~av~e~r~v~r~m~le~ring fish                    and others. ~1~9~?~8~) title constitutes mole than 95 percent of                                                                                                                                      adjoin the 1002 ~qa,
                         become isolated in deep~w pools. spring areas. Or brackish                      ~the diet of ringed goals which in turn are the major prey of                                                            U~n~c~l~i~sco~v~e~red sites may also be ~a~n h~I~gh points                  of       coastal plain. from
                         river deltas Substantial movement from Summer feeding                          the areas ~8 polar beers Some winter subsistence fishing                                                         land that provide overlooks above ~the surrounding moist                          Canadian border I
                         areas to small Ov~e~r~v~i~on~t~er~ing areas has been recorded (West                    also occurs at fresh water ~o~v~erw~i~n~i~e~wing sites. ~T~he most                                                        ~tunc~h~o such spot, are known to produce archeological
                                                                                                        .*Table of these ~w~e 'Fist, ~l~4~o~l~e ~(~)~.~a' find *Fish Hat* ~T~w~o                                                      ~l~ides throughout most ~a~t north- Alaska and Canada                                         Wilderness
                         ~~d W~~war. 1~985~). Ice accumulation ~a~n Arctic rivers is                        on ~th~e ~Hu~f~ahu~l~a River ~(p~I IQ) where arctic char and arctic                                                      There ate relatively ~l~e~w such locations on the 1002 area.                        ~19~6~4 (Public La.
                         ~~"~~~ ~~~= tale March ~lhr~mgh early May                                          g~r~a~t~i~f~~ng we caught from holes in the river Ice.                                                                and sites ~o~d~i~ml~i~f~ied in such locations ~#~,~a uniformly smog                        Federal land% rate
                              Available ~f~f~sh ov~er~w~i~n~f~e~r~in~g habitat. Such as deeper                                                                                                                                      ~Sca~"et~s of ~f~i~l~h~ic material                                                       without permanent
                                                                                                                                                                                                                                                                                                         which Is protected
                         pools. is greatly reduced in early soling Although pool                               Sport fishing is cu~,~te~n~tl~y, minimal ~I~. the 1002 were                                                             Archeological site, are even less ~Hk~e~t~y an ~the                           natural conditions
                         depth is Important. several ~O~l~h~e~t~~f~a~c~l~a~c~, affect Suitability for              because of difficulty In ~a~mes, and seasonal ~q"~J~al~i~o~n~s ~a~n                                                         ~r~e~f~i~r~l~i~v~i~x~t~y, stable sandy areas in ~W~, d~efta,~As with ~the                       been affected p~qfirr
                         ~v~r~~~~h~ri~n~g Those factors. which ultimately affect IDS                      fish abundance                                                                                                  overlook sites~ material ~I~,.~- blowouts ~i~n such deltas                   is       -print of man's
                                                                                                                                                                                                                        ~cu~f~f~"~l~l~y Hinged to li~thi~c remains                                                outstanding op~qp~qo~qr~qs
                                                                                                                                              EXISTING ENV~IF~I~ON~M~ENT ~3~7

    ~0

                                                                                                     Table V~I-~I.~-~-~De~f~in~itions of environmental effects                                                                                                                                                          Table V11-3~.--Ft~es~ou~m~@ categories and r~ni~ti~q~a~t~i~nn ~q~o~n~ls
                                                                                            ~11-ong~-~ter~m~. 20 years or more. Short-term. less than 20 y~ea~r~s~t                                                                                                                                                      FWS Mitigation Policy FR. ~Y. 4~6, no 15. January 23.
                                                                                                                                                                                                                                                                                                                  19~8~1 Habitat value: a measure of the sui~l~ab~i~l~t~ty of
                                                                                                                                                                                                                                                                                                                  an area lo support a given evaluation ~speci~e~sl
                                        Effect level                                                                                                          Definition

                                                                                                                           Physical resources                                                                                                                                                                   Resource               Designation criteria                        Mitigation
                                                                                                                                                                                                                                                                                                                category                    of habitat to                          planning
                                        Major     . .........................           Widespread modification of considerable Severity in la~ndf~q"S. surface appearance. or                                                                                                                                                                   be affected                          goal
                                                                                        distribution of physical resources. or contamination of those resources. tasting several
                                                                                        tens of years Modifications cou~hl occur during de~ve~lopmen~t/produc~t~io~n phase,
                                        Moderate           .................-           Local modification of considerable severity in t~and~lorm. or surface appearance. or co~n~f~a~m.
                                                                                        in~a~llon of physical resources. tasting several tens of y~0~srs: or widespread modification of                                                                                                                             I           Habitat of high value for                        NO loss of existing
                                                                                        lesser ~s~w~e~rf~ly in surface appearance or other characteristics of physics) resources.                                                                                                                                                    evaluation spec~l~e .                                habitat value
                                                                                        lasting from a l~aw years to several tens of years. Modifications could occur during the                                                                                                                                                 Unique and ~Wrep~l~ace~-
                                                                                        exploration phase.                                                                                                                                                                                                                      able on a national
                                        Minor     . .. ..................               Lo~c~al~iz~zed. relatively isolated change tasting from ~*~as then I year to no more then ~t~o                                                                                                                                                  basis or in the ~a~m-
                                                                                        years, with no observable residual modification in surface appearance. distr~ibuli~on~. or                                                                                                                                                 region.
                                                                                        other characteristics of physical ~nes~qWCe~SL
                                        Ne~g~l~o~b~le           ...................          U~l~f~t or no change in the surface appearance. dis~t~i~lbu~tion or other characteristics of                                                                                                                                   2           Habitat of high value for                        No net loss of In.
                                                                                        phy~s~-~k~al resources.                                                                                                                                                                                                                     evaluation species.                                kind habitat
                                                                                                                                                                                                                                                                                                                                Relatively scarce or be-                           value.
                                                                                                                                                                                                                                                                                                                                      ~I~ng scarce on a
                                                                                                                         Biological resources                                                                                                                                                                                   national basis or In
                                                                                                                                                                                                                                                                                                                                ~th~e ec~o~n~t~i~l~ion~

                                            Nor.                                        ~q-~a~-pre~ad~, ~lon~g~,~l~om~s change In ~la~bi~t~a~l~l ~f~ev~el~l~s~b~il~l~, ~, quality which would likely modify                                                                                                                                 1           ~1~1~1~1~1~,~1~1~4~1 ~a~t high ~to ~rned~iurn                   M~in~in~f~t~e loss of In,
                                                                                        natural abundant@ or distribution of species using the ~1~0~02 wen. Modification will persist                                                                                                                                              value for evaluation                               kind habitat
                                                                                        at least as long as modelling influence* exist.                                                                                                                                                                                         Species. Relatively                                value. No
                                        Moderate               .............            Widespread. sho~r~l,~l~er~m change In habitat availability or quality which would likely modify                                                                                                                                              abundant an a national                             ~ne~t loss of
                                                                                        natural abundance or distribution of species using the 1002 am; or local modification                                                                in                                                                                 basis.                             I~             value.
                                                                                        habitat availability or quality which would ~Ilke~l~y modify natural abundance or d~is~t~r~i~bul~l~o~n at                                                                                                                          4           Habitat of medium to low                         M~i    I~n~qW~te loss of
                                                                                        least as long as ~m~o~d~d~y~i~ng Influences, exist.
                                        M~~o~r      . .........................           Shor~t4~f~a~m. local change o~f species abundance. distribution. habitat ~ev~a~b~b~l~i~f~ty~. or habitat                                                                                                                                              value for evaluation                               habitat value
                                                                                        quality.                                                                                                                                                                                                                                species.
                                        Negligible~-        ..................           ~L~O~S or no change In population. habitat availability~. or habitat quality.

                                                                                                                     Socioeconomic resources                                                                                                                                                                    consequent d~ele~; ~d~i al~i~on of mitigation goals is based upon
                                                                                                                                                                                                                                                                                                                the habitat values assigned to specified evaluation species:
                                                                                                                                                                                                                                                                                                                This habitat value is a measure of the suitability of the area
                                        Major                  ...............          Requires substantial changes in governmental p~ok~les~. planning, or budgeting. of is Rely                                                                                                                                 to support ~a given evaluation specie
                                                                                        to aff~e~d the economic or social well-being of residents o~f the area.
                                        Moderate           ..... ................       Requires Some modification of governmental policies. planning, or budgeting. or ~m~ay affect                                                                                                                                    The mitigation policy recommends that "ally
                                                                                        ~t~he economic or social well~-being of ~t~es~id~e~i is of the area.                                                                                                                                                            designated or ~se~ll-~as~id~e arms, such as National Wildlife
                                        Mina      ........................              Requires "tag" change in g~i~o~ver~n~me~n~t~al policies. planning. or budgeting, or ~m~ay margin.                                                                                                                                 Refuges. ~b~e given opt" c~o~ns~ld~l~e~al~t~i~o~n as either Resource
                                                                                        ally ~aff~e~d the economic or Social~! w~ell~-bein~i~t of residents of the Wes.                                                                                                                                                 Category I or 2. As des.                           In Chapter a. h~i~gh~-~v~al~lu~e
                                        ~~~i~g~ag~it~"          .. ..................        Not Sufficient to have ~a~ny measurable ~e~f~f~e~d an governmental ~V~,kk . ~p~h~o~m~b g or budget.                                                                                                                                   habitat for each of ~t~h~e.~f~i~v~e evaluation species exists within
                                                                                        Ing. or my ~m~a~ssu~r~a~b~l~e effect on ~th~e ~eco~nc~a~r~ti~c or Social well-being of residents of the                                                                                                                                 the 1002 ~s~te~s. ~Th~e Porcupine ~c~arb~o~a~r~t herd ~JPCH) core ~q(~q@
                                                                                        &NIS.                                                                                                                                                                                                                   ~c~a~d~v~ing arm Is ~con~s~i~c~h~w~ed ~q~ and Irreplaceable. Habitat
                                                                                                                                                                                                                                                                                                                in ~I~N~S area has been designated ~R~f~t~o~w~c~e C~a~teg~qM I ~(~M.
                                                                                                                                                                                                                                                                                                                2~6) because of ~I~ts high fish and wildlife values, particularly
                                                                                                                                                                                                                                                                                                                for PC~H caribou. The ~w~anal~md~o of the 1002 area has been
                                                                                                                                                                                                                                                                                                                designated Resource Cat~ego~ty 2.

                                                                                                                                                                                                                                                                                                                      The FW~S ~nom~n~al~l~y r~e~c~om~n~s~a~n~ds that as losses of
                                                                                                                                                                                                                                                                                                                Resource Category I habitat be prevented. as these ~o~n~q"~I~.
                                                                                                                                                                                                                                                                                                                ~S-k~ind arms cannot be replaced. ~Ins~W~f~f~c~s~r~wt changes that
                            ~~ A~~CT~IC REFUGE R~ES~O~qMCI~E ASSESSMENT                                                                                                                                                                                                                                               go ARCTIC REFUGE RESOURCE ASSESSMENT

    ~0

                      what methods, without seriously affecting fish. wildlife. and              Mitigation                                                                                                   harriers ~to movement which reduce ~acc~e~s~s to insect relief
                      habitat that rely on the spring. H~q"e~ver, the existing 'no                                                                                                                               and other habitats. and di~s~lurbance/har~a~ssm~en~i~). and direct
                      surface occupancy' restriction l~o~t o~i~l exploration and                            Experience gained from construction ~and ~op~qm~l~ion of                                                    ~or~i~nr~i~a~li~ty ~le.q~. hunting. collisions with ~v~ehic~l~e~@~or other
                      development is assumed to remain In effect. This                           docks and causeways for Prudhoe Say should be used to                                                        accidents) Analogies comparing the effects of current oil
                      precludes surface dev~ok~ipm~ent and disturbance. maintaining                 plan and construct docks and causeways f~o~r the 1002 area                                                     development on ~th~e CAN and effects of pole~r~i~lial 1002 area
                      the area's physical features end Important fish. wildlife. and             so that those facilities do not affect l~ongshore water                                                       development on ~the PCH must be drawn with cauli~on~
                      subsistence resource values.                                               transport and lagoon water chemistry or ~Im~pecl~e fish                                                         Movements. density. and traditions of the PCH differ from
                                                                                                 movements. Release of fuels and other hazardous                                                              those of the CA~N (Chapter 11). Because of ~the greater               ~i~2qf~q)
                      Conclusion                                                                 substances ~to the environment should be m~in~k~i~f~ted by                                                         density of PCH on their calving grounds. ~the PCH would ~L~,~@
                                                                                                 developing and ~Impl~e~r~i~u~m~f~i~ng control. use. ~and disposal                                                      interact with o~i~l development much more extensively and
                             Development as a result of fully leasing the 1002 area              Plans lot such substances.                                                                                   intensively than ~the CA~N has in~ter~ac~led with o~i~l
                      would have negligible effects on the S~adler~och~f~t Spring                                                                                                                                 development in the Prudhoe Say area.
                      Special Am under current protective management                             Conclusion
                      regulations.                                                                                                                                                                                  Caribou calving ~i~n the Prudhoe ~q::y ~ar~d~q@a was
                                                                                                        Overall, the effect of full leasing Is anticipated to be                                              reported by Gavin (1~9~71). Child (1973) nd         h~i~le and
                               COASTAL AND MARINE ENVIRONMENT                                    minor o~n coastal and marine habitats. However. there is a                                                    others (1975), when development of ~i~t       ~Pru  ho
                                                                                                 Small probability of major adverse effects depending on the                                                  field was beginning. Later studies (C~a~m           and               ~-~q1
                             Petroleum development and production in the 1002                    extent and duration of future cumulative developments or in                                                  1979, 1980; Cameron and others.             ~2q=i~f~fen   ~.~8qrd ~"'
                      area and associated transportation at both onshore and                     the event of a ~c~At~es~tr~oph~ic offshore or coastal off SPIN.                                                    Cameron. 1~905) indicate an ~abse~n~e~A I calving ne~ar~.~l~2qjhe
                                                                                                                                                                                                                                                                      or
                                                                                                                                                                                                                                                        ~P~.~"~.~,
                      offshore ~s~h~e~s would have a v~anety of effects. Docks and                                                                                                                                 coast at Prudhoe Say during ~1~97~6~-8~~"~,               ~qd~4q@~.e I.
                                                                                                                                                                                                                                                                                  w.
                      causeways ~ca~n ~o~f~f~ec~t dispersion. nutrient transfer.                                          TERRESTRIAL MAMMALS                                                                        avoidance of the activity area by calving caribou.                  wo
                      temperatures, salinities. invertebrate abundance and                                                                                                                                    centers of concentrated calving activity were identified; (~1)
                      diversity~. fish passage. and other uses of those areas by                  CARIBOU                                                                                                      es~t of Prudhoe ~Ba~y In the vicinity of ~th~e Kuparuk and
                      fish and wildlife. Disruption of natural nearsh~o~re c~urre~in~ts                                                                                                                            U~g~nu~ra~v~ik Rivers (including recant o~i~l development in the
                      ~~n result in sea water intrusions into lagoons causing                           Caribou use the 1002 area during the summer                                                           Milne Point and Kup~aruk areas); (2~) east of Prudhoe Bay.
                      lower water temperatures and higher salinities. Salinity and               months for two Im~p~or~l~on~t activities. calving and ~s~e~q"g~qW                                                       primarily in the Sullen Point ~to Conning River delta area           ~q(~4qV
                      temperature changes could after Invertebrate abundance;                    relief from Insect harassment. During that period. ~3~.0~0~0-                                                    ~Shidel~er. 1985). Su~m~e~y~s in 1~981 indicate that the Canning
                      decreases in invertebrates would me~e~n lower coastal area                   4~1~.0DO caribou from the 1~2~,~0~D~O~-114,000 member CA~N use th                                                     River delta area may support more calving caribou than the
                      values to fish and wildlife, Such Intrusions my also after                 1002 area. Up to 82 percent of ~the calving caribou In the                                                    Kupa~fuk area (Whitten and Cameron. 1985). Table V~I~-~4
                      fish movements by reducing existing f~a~vor~ah~l~e habitat                      PCH calved ~11~11~1~1~7~1~q%~1~q-~C~q@2~*re~a In recent years (1~9~72~-85) and                                                  compares calving in the Prudhoe Say area and population
                      conditions in ~n~e~ar~sh~ore zones                                              the entire ~1~80~.000-m~err~iber PC~H may use the ores in some                                                     of the CA~N with development of the Prudhoe Bay ~ON field.
                                                                                                 years. mainly during ~th~e lot@ Jun~e~/~e~ad~y July ~In~sect-~re~f~ief                                                   The apparent herd increase has been attributed to high calf
                             Noise created by construction and other operations                  period. Concentrations of caribou are generally absent                                                       proch~iction and survival ~as well as relatively light hunting
                         coastal areas could be a disturbance factor. sufficiently               from ~!~h~e ~1~1~0~0~2~2 area in -win-or. except 'a; as many as ~1~q=                                                    pressure %^,Written ~a~nd Cameron. ~1~9~8~3~3).
                      reducing the quality of the coastal and marine habitats to                 animals (~7 percent) of the CA~N scattered between the
                      cause avoidance by some marine birds and ~m~a~ir~v~irr~i~a~ls                      S~a~c~l~e~roch~it Mountains and Camden Bay.                                                                              Even more tenuous are parallels bet~w~r~e~en caribou
                                                                                                                                                                                                              activities and population trends on NP~RA with those which
                             ~~~~f~t washing ashore from transport and offshore                    Exploration                                                                                                  might result from ~ON development on the ~1002 area.
                      activities could increase with increased human activities in                                                                                                                            Although NP~RA has been extensively explored. no 0~0
                      the area.  The dr~iftl~ine is used for nesting habitat by several                   Winter seismic programs In      1~9~84 and 19~85 on the                                                  Production or Infrastructure development has occurred.
                      species of waterfowl and seabirds ~(p~l. ~3~& ~Q. ~Q~)~                           1002 area. and exploratory drilling an adjacent K~ak~lo~vik
                      Disruption and physical ~a~f~t~er~a~l~lon of the ~6~11111~% ~a ~q"~i~n                    ~I~nup~ial Corporation ~(KIC~)/A~r~d~b~c Slope Regional Corporation                                                         Approx~im~a~lle~t~y, 242.00~0 acres of the 1002 area used
                      activities associated with of development could affect       ~b~kd           (AS~AC~I lands in the winters of 1~985 and ~1~91~31~5. resulted In                                                  as a care calving are@ by the PCH has been de~te ill ~ad
                      nesting success by disturbing nesting birds or ~af~t~er~ing their              no apparent con" with CA~N or PCH activities. S~k~n~br                                                           Resource Category I habitat In accordance with the ~FWS
                      nests. Debris and disruption of dr~M~ine~s would &ISO ~&If~ecl                  results were found during both seismic and exploratory                                                       mitigation policy. More than So ~c~o~f~f~t~b~ou/s~q r~r~A have boon
                      esthetics. Occasional fish ~and w~i~d~l~l~e mor~t~e~ll~ifi~e~s could                   d~ri~f~f~i~ng work in the NP~RA and on State lands within the                                                      present during calving in of least 5 of 14 years ~(1~9~72~-~85) for
                      occur where animals become entangled In or Ingest debris.                  range of the CAN (U.S. Bureau of Land Management. 1~9~83:                                                      which detailed date exist ~(p~l. 2~6)~; pearly ~I   ~qT~qY~q!~"~S~o~n~,             of the
                                                                                                 Fancy. 198~3). Winter o~i~l exploration. Including exploratory                                                  total core calving am for the ~I~0~Q~,~0~0~Q_~Z~c~f~f~q" PCH occurs
                             Any sp~r~ill of ~O~N or other hazardous materials along                 drilling. would l~ikell~y have a negligible effect on PCH caribou                                              ~i~n this portion of the 1002 area ~(~1~.~1~qre ~q-V~I~S) The remaining
                      the coast could severely affect coastal and marine habitats                since they are generally absent from ~the area. ~O~lstu~tb~anc~qaj~q@~q;~q)                                               approximately ~1.3~04.000 acres. considered Resource
                      end fish and wildlife. F~o~r example. decreased invertebrates                resulting in displacement. could Occur to ~th~e CA~N.                                                           Category 2 habitat. includes areas used ye~ar~@round by up
                      result In decreased food for fish and w~ild~i~f~f~e~ ~S~a~o ducks.                 Disturbance and ~d~q"~cem~e~n~t to both the CA~N and PCH                                                             to ~4.000 CAN caribou and for concentrated and scattered
                      such as ~o~ldsqu~aw which heavily use this coastal am.                        from the sho~i~l~-~f~orm. scattered and local activities of summer                                                calving, post~ca ~mg             ions. an ~mse~c~l~-~r ~ie a at y
                      could be displaced, and d~i~re~d modality could occur. Level                  surface geology programs would be, almost negligible.                                                        the PCH.
                      of Impact would relate to ~the volume of ~o~ll Spilled. location,
                      effectiveness of cleanup. lime of year. and fish and wildlife              Production. Transportation, and Development                                                                        If ~t~h~e 1002 ~area~*~s anticipated o~i~l and gas resources
                      species present.                                                                                                                                                                        were developed across the entire area, direct modification
                                                                                                        Effects on caribou from petroleum Paid development,                                                   of caribou habitat could total approximately 5.550 acres.
                                                                                                 production. and transportation would occur from direct                                                       East of the S~adle~roch~i~t River about 3.~650 acres used by the
                                                                                                 habitat modification. indirect habitat loss (displacement.                                                   PCH. of which about 1.300 acres are Resource Category I

                                                                                                                      ENVIRONMENTAL CONSEOUIENCES                    105                                      0~6 ARCTIC REFUGE RESOURCE ASSESSMENT

    ~0

                                                                                                                                                                                                                                                                                                                                                                                                                        h~qa~qs
                                                         Table V~I-5.-Porcupine caribou herd calving area potentially affected by development under fun leasing                                                                                                                                                 Caribou select caking areas because of favorable
                                                                                     or limited leasing. assuming an app~ro~x~im~a~le~4~y 2 mile s~ph~we of influence                                                                                                                                          ~w~r~a~th~m "using early ~sn~o~w~n~re~"~. advanced e~m~e~,~g~e~-c~- ~a~t                                                               card
                                                                                                                                                                                                                                                                                                      new vegetation. relative absence of predators, ~pl~u-i~f~y 10
                                                                                                                                                                                                                                                                                                      i~nsec~t~-re~f~ief habitat. absence of disturbance. or some
                                                                                                                                                                                                                                                                                                      combination of these and other factors. Maternal Cows                                                             di~qs~qp
                                                                                                                                                                                                                                                                                                      and their calves are most sensitive to disturbance dur~m~g                                                          the
                                                                                                                                                                                       Concentrated                          Core calving                                                             calving and immediately                thereafter (C~a~le~l and others. 1976~:                                        hab~qi
                                                                                                                                                                                     calving areal                                           ~a~ma~2                                                     Miller and Gum. 19~79: El~is~on and others. 1~906)                                                                    c~qa~qh,
                                                                                                                                                                                                                                                                                                                                                                                                                        ~qm~qc~qlu
                                               Total calving area .11h~in 1002 area ~jacre~s~)                                   ................ ....... ...... ....... ...                    934.01)(1~1                                       242000                                                            Displacement of the PC~H fr~orn a core ~c~a~b~y~l~l area to                                                      ~qm~qo~q.
                                               Area team) potentially influenced ~b~y development:                                                                                                                                                                                                      a less desirable area would be expected to reduce caribou                                                         cal.
                                                  Full teasing          ................. ........... .......                .................................................  ..........  ~3~5~7.000                                          7~8.~000                                                   p~roduc~q". ~o~s                              or~l~an~t habitat has ear shown to                                          ~qre~qlo
                                                                                                                                                                                                                                                                                                                         ~c~t ungulate populations (Wolfe. ~19~78: Sko~vIin                                                  ~qp~qa~qt~qt
                                                  ~timi~led leasing         ..........                                         .............. .......... ...... ..... ..... ..........        2~61~.000                                          ~1~0.00~0                                                   ~19~92~q@~,~ ~ou~l-n~e~-~r~e~c~o~9~f~itz~a ~a.                        9~, erm effect upon the CAH                                    coin
                                               Percent of 1002 calving area potentially influenced ~b~y de~vek~ip~men~t:                                                                                                                                                                                                                                                                                                      post
                                                  Full ~I~ms~in~g....~~         ......................-                          -- ............. ...   .................... . ........                          38                              32                                                       as a result of c~lisp~lac~ern~e~int by o~i~l development in the
                                                  Limited leasing          ..............................                    - ---- .............    - .... . ... .................                          ~2~8                              4                                                        central Alaskan Arctic ties been demonstrated to date. In
                                               Total calving area ~jacr~@~) in U.S. ~a~nd Canada..                                ..........      ... ..................................      ~2~.~1~1~7~.~0~0~D                                                                                                    considering the effects of displacement of the CAH from
                                                                                                                                                                                                                                             3~1~1.oDo                                                  traditional caking grounds. Whitten and Cameron (1985)                                                            sill
                                               Percent of total U.S. ~a~nd Canada ~a~r~m potentially influenced by development:                                                                                                                                                                            contend that the CAH has not experienced a reduction ~'~i~n                                                          e~qi~qa~ql
                                                  Full leasing..           ...... ........................                   ~:........................... . ......- ............. ...................        17                              25                                                       productivity or ~c~onseq~u~a~r~t population decr~o is because: (t                                                        oth
                                                  Limited leasing                         ...............                    ..................................... .......... .................              12                              3                                                        the CAN has been displaced from only Part 01 ~is caking
                                                                                                                                                                                                                                                                                                      grounds; ~J~2~) suitable alternative h~i~gh-quafily hal~b                            ~q!                   ~0q6~1
                                                                                                                                                                                                                                                                                                                                                                                     flat appear
                                               -        ~IA~I least 50 ca~r~d~x~x~ds~quwe nine during caking. in ~1-4 years. 1972~45.                                                                                                                                                                           available for caribou displaced from Prudhoe Bay: and (3)                                                         pot
                                       ~qQ~0qV               2A~t least ~50 ~cl~u~il~l~-~W~qua~l~e ~-~-~A~s during caking for at least 5 years. 1972~-~qW~7                                                              ~5~@                                                                                                   overall density of CAH caribou on their calving grounds Is                                                        and
                                                                                                                                                                                                             I                                                                                        much Iowa than that of other ~ar~e~f~t herds in Alaska.                                                               Cat"
                                                                                                                                                                                                                                                                                                                                                                           ds are roughly                               the
                                                                                                                                                                                                                                                                            ~1~1~0-                                                                                   herd caking gr~ou~4~-~d is                               ~qh
                                                                                                                                                                                                                                                                                                      Although the CAH and PC" caking ~V~m~m
                                                                                                                                                                                                                                                               I ~A~e.                                  equal in size and ~th~e Western Arctic
                         August that carbon~; seek relief on u~r~iveg~etated gravel roads'                                                       of Intensity. Disturbance~ can resu~l~l ham ~a variety of                                                                          ~i~t~t                      b~o~u~s So percent              ~Erg~w~. ~th population of the PCH Is ~ab~ou                                               dur~qin
                         well pads. or ~the shade of pipelines and buildings on those                                                         sources Including presence of p~ip~ell e and mods. aircraft                                                                                                ~8~15 times larger and that ol~e~the Western Arctic herd is abo~u                                                      yen
                         pods (~ur~to~l~o. ~1~9~63~: F~a~i~n~cy~. ~1~9~8~3). Insect harassment of                                                           operations. general construction. routine operation of ~th~e o~n                                                                                            ~to times larger than the CAH (based on ~1~98~2 Population                                                            (~q1~q9~q8
                         PC~ on the 1002 area generally results from "arms of                                                                ~k~id. presence of people, and hunting~. Reactions depend                                                                                                   ~e~s~t~irr~ia~le~s~)~                                                                                                     ~qd~qe~qv,
                                qu~~oes early In the summer season. The PC~H usually                                                          upon several factors. Including c~a~r~bou age and sex. herd                                                                                                                                                                                                                   in"
                         'ewes the ~0D~? area prior to the emergence of o~e~str~id ~M~es                                                           size. presence of calves. season. and type and distance of                                                                                                        Both absolute (number of caribou. Including calves.                                                      ~qc~qa~qrl~qb,
                                                                                                                                             ~the d~i~sturt~s~im~m.                                                                                                                                         on ~the caking grounds divided by arm o~f calving grounds)                                                          nine
                                   Secondary modification of habitat clue to changes ~i~n                                                                                                                                                                                                               ~a~nd effective (allowing for the "It of lime a herd uses ~i~ts I                                                     of ~qth
                         surface water flow. snow accumulation. roadside dust                                                                       Behavioral avoidance of                                     I arms a                     c~e~s                                                      calving grounds each yes" densities                          Of ~th~e ~CAH W~O ~2
                         d~p~~~~~~. gravel spray from vehicle movements, and                                                                 earth- ~k~q-                           l~i~w~i~v~A~r~i~f~t ~f                                ~h is                                                                     ~b~a~r                                                        herd
                                                                                                                                                                                                                                                                                                         ~.1~1~x~v, *I pCH ~a~n~d Western Arctic                                 -king g~r~q-d                     ~q(~4q9~4
                         pollution i~c~ider~ds would reduce the habitat value of                                                               generally believed to result from ~1 u~r a ~ac~t~i~qf~qt (noise.                                                                                                  densities. As described by Whitten and Cameron (~1~985).                                                            de~qr~qa
                         additional acreage. These changes in ~v~ag~e~l~at~i~o~n. and thus                                                           vehicle movements. pr~e~s~e~i~n~c~e~-~o~f people. and odors). instead                                                                                              absolute density ~t~or the PCH is nearly 14 times. and for ~the                                                      c~qa~qr~qlb
                         food ~~~~~                                                        ~        ~f 7.000 a                     ~q6~8q0 of the mere presence of roads. ~I~*~w~b~qm~. and bu~ld~b ~f~i~s.                                                                                                             Western Arctic herd nearly ~15 tir~r~i~m greater than for the                                                         and
                                                  . ~c          occur on
                         of ~~~~~~e~*dy ~1.                    a~cr is ~i~n e~f~tso~m~m~W~ce ~B~1~8~~9~-~0~-~r~y~q"                                               Avoidance of o~i~l d~e~ve~lop~i is and other human activity by                                                                                                 CAH The difference in effective densities is even greater.                                                        con
                         percent) Total modification of caribou~ habitat ~a~f~fr~ibull~a~b~l~e                                            I          caribou has been ~ep~o~t ed by m~a~r~i~n~trous Investigators ~(D~a~u
                                                                                                                                                                                                                                                                                                      particularly for the PCH~. which are found at approximately                                                        ar~qe~qs
                         to direct and secondary changes would occur on about ~1-                                                             and Cameron. 1~985: Cameron and others, 1~9~7~9~. Whitten                                                                                                                                                                                                                       Res
                         12.650 acres. or 0.8 percent of the 1002 am. and 1~1.3                                                               and Cameron. 1~9~63: Fancy ~e~m~l others. 1~981; Urquhart,                                                                                                     24 caribou per square kilometer as compared with                                                                  cusp
                                                                                                                                                                                                                                                                                                      ~approx~i~n~a~le~ly 5 caribou per square ~k~Dom~et~a~ir ~f~o~r the CAH.
                         percent of the core caking ~a~r~m (Resource Category ~f                                                                 1~9~73: Wright find Fancy. ~1~98~0). _The reported end                             ~ent of                                                                    Effective density of the Western Arctic herd i~s 15 carbon                                                         ~qinc~qlu
                         habitat),                                                                                                           displacement var~i~m. Displacement of the                                                         ~hls~I~q~q6~0qW~'
                                                                                                                                                                                                                                                                                                      per square k~i~lor~m~f~l~er~.                                                                                            CON
                                                                                                                                             caking grounds in ~r~e~spon~s, o                                             I at Prudhoe                                                                                                                                                                                      Cat
                                  M~~or Indirect losses of habitat end additional                                                                                                t     (Dan and                            1~9~8~5~.                                                                                                                                                                                        pro
                         reductions in habitat value would be w~Mes~p~i~r d throughout                                                           Cameron and Whitten. 1~9~7~9)~. Whitten and C~w~r~w~qm ~l~i~g~a~q@~                                                                                                              With the CAN caking density remaining ~l~ow
                         ~he 1002 am. The habitat value losses from these ~i~nd~h                                                               ~f~d~W~O -~qc~oni~qf~qfe~-~n~I~0qF~F~a~w~ numbers of caribou and generally                                                                                                   compared to other herds. despite ~0 recent Population                                                              rep~qp
                                                                                                                                                                                                                                                                                                      increase. overcrowding and consequent habitat stress                                               that           pro
                         effects would r~e~suft insist ~b~e~f~u~r~i~l~q" avoidance of                                                                   low percentages of calves in the Prudhoe Bay o~i~l ~k~M ~fro~nn                                                                                                might result in reduced productivity have not ye~t occurred.
                         _d~vel~pm~~ ar~e~a~r~s: de~cr~e~~qis~qe~qi ~a~c~c~m~s~n~t~q@~2q@ to undeve                                                                                                                                                                                                                           n~o~r have caribou bear displaced to areas of reduced                                                               ~qe~qf~qf~qe~qc
                         ~~"~~~ (~n~ecl~i~f~n~i~el h~ab~li~a~l~qs ~qi~i~0q" the coast) due to                                                                                                                                                                                                                           habitat value or areas where they might be exposed to
                         physical barriers find d~is~tu~f~t~e~r~me~s such as pipelines. tra~qf~qt                                                                                                                                                                                                                 increased predation. Unlike ~th~e Western Arctic Or
                                                                                                                                                                                                                  ~u~n~n~i~s' ~'~9~7~qM
                                                                                                                                                                                                             ~l~l~n~0q@
                                                                                                                                                                                                             ~g ~0
                         or facilities: and other disturbances or harassment by o~i~l                                                  ~'~6qU~.~q.~6qTlwer~e 2 ~1. ~1~q"~6qM higher ~1. at                                                                                                                                                                                                                                                   ~qind~qir
                         d~~~l~p~ m I activities and personnel ~du~*~V se~ns~i~f~l~iv~e~                                                              Prudhoe Bay. ~O~s~su and Cameron (1~9~q". In what my be                                                         ~qW~-~-~q-                                           porcupine ~c~ar~t~i~o~u herds. the CAH has been exposed to
                         caribou We stages.                                                                                  ~*-~q;-            the most ~sy~st~a ~i~n study of caribou displaces a ~b~y Of                                                                                                     ~n~w~l~i~n~a~l predation in recent years. With the influx of                                                             ~qp~qres
                                                                                                                             Jr.                                                                                                                                                                      workers and use of the h~au~t wed ~f~o~r Prudhoe BOY                                                                   Dep
                                                                                                                                             development reported that maternal ~c~a~r~b~o~u groups sho~xe~d~-
                                 Disturbance to c~i~nb~ou Is unavoidable ~9 all                                                  -~4              measurable declines In habitat use within approximately 2                                                                                                development. the wo~f~f population in the Central Arctic area                                                       ~qthos
                         d~~ll~pm~~o~c~c~u~rs~o~n~th~e~,~1~0~0~2~s~ir~m. H~is~l~od~call~y~the                                                                      miles on either ~Wd~e of the Mine Point road in the ~c~e~9~qW_                                                                                                  decreased in the m~id~-119~7~0~'~s because of hunting. At that                                                          I
                         entire ~~~ has b~e~e~n~i used by PCH c~arlb~ou at varying levels                                                          Alaskan art~s~ic.                                                                                              I-   I                                      time CAH numbers began increasing. The ~w~off population
                                                                                                                                                                       ENVIRONMENTAL CONSEQUENCES                                            to?                                                      ion ARCTIC REFUGE RESOURCE ASSESSMENT

    ~0

                        of caribou through ~o~i~l or ~o~l~he, development areas has been                       Kupw~uk oil fields. ~Cu~r~a~t~o~l~o and Murphy (in press) attributed                                                              ~e~p~o~r~l ~m~v~o~t~ve~d 1~0 ~c~a~nh~o~u rad~io-co~l~i~n~t~p~d on ~w~in~l~er range in
                        inhibited because of linear o~d~de~ve~lopm~en~t ~ta~difie~s ~a~nd                           the lower crossing frequencies a] p~ope~f~in~e~f~r~oad sites ~to the                                                              t~he Arctic Refuge. two t~ro~m the ~CA~M and ~e~s~qh~l from ~the
                        associated activities (~Cu~ir~a~t~o~l~o, and others. ~I~S~B~2: Smith and                    combined stimulus of vehicular ~o~r~a~qf~qt and a pipeline.                                                                      PC~H. An ~m~l,~,~acli~o~n was defir~ied as h~e~n~e,~er a ca~nbou
                        Cameron~. 19~85a. ~b~.~, Klein.      1~9~80) This is of particular                                                                                                                                                point location. ~m any segment of a line conne~c~lin~g two
                        ~~~~~e~, ~i~n ~the 1002 ~a~n~o~o~l~l~-~6~q;c~qau~s~e the probable                                         A~f~t~w evaluating caribou responses to pipelines.                                                                   ~P~o~n, locations calculated for ~the same caribou on adjacent
                        p~per~e~hau~l road mile would bisect ~the ~w~as                                      roads. ~a~nd p~ipefin~i~s~f~ro~ad complexes in the ~Kup~o~nu~k, o~i~l ~f~i~dd~.                                                             days. was within approximately 2 miles of a road. pipeline-
                                                                                                         Cur~a~lo~b ~a~nd Murphy (~1983) suggested that c~a~r~b~ou                                                                           drill pad. a~i~d~i~e~l~d. or other development facility. Point
                               Barriers to caribou ~m~o~n~a~m~e~n~t~s~; could result ~i~n                            m~i~r~n~s~m~on~ts could be facilitated by separating ~p~i~t~q" ~e~s from                                                                locations ~f~o~r the love caribou from the PC~H which entered
                        decreased calving success by reducing a~c~ce~-s~qT~to Preferred                        heavily tr~a~iv~el~e~d mods and constructing rumors at strut                                                                   ~th~e 1002 area in summer 1~285 can be examined to Indicate
                        caking areas. compounding [he d~i~s~o~p~l~a~c~e~m~e~r~d ~h~om caking                           locations over elevated ~p~ipellm~o~s~. Other researchers                     ~4q4~1~0qW~qJ                                             the extent  ~a~t finite ~c~w~6~m, usually spend w~i~lh~in the
                        areas which Could ~r~e~su~f~f from disturbance as discussed                           cor~cuff~ed that roads should be separated from                                   ~W  ~k~q;                                     development Wes. of ~th~e 232 point locations. 51 (22
                        previously. A greater co~nce~r~n~.~~fe~l~ativ~e to the location of                       a means a~t Improving caribou pas,                                                                                         pet e~n~t of the time) were within approximately 2 miles of
                                                                                                                                                                                                                                      ~c
                        ~~~en~~~l barriers under ~the full leasing scenario. would be               ~1~0~1~.  ~C develop~m~e~m~l we~s~s (~Cu~ra~t~o~l~o and others. 1~9~82:            Robu~s ~a~nd                                                       ~th~e Infrastructure our ~t~A development. Moreover. 34
                        ~~h~~~~t~n~ movements ~tor the ~far~g~e p~os~t~c~a~dv~in~g aggregations               ~-     ~@~Cur~o~n~d~o. ISM; ~E~l~ls~on and others. ~191~1~M~. The ~op~li~m~u~rn                                                                     percent of caribou routes between locations ~c~u~@ adjacent
                        which annually occur on, the 1002 area as they move                                    ~s~t~ion between roads and Pipelines depends upon                                                                      days were also within the approximately 2-~m~ile area
                        between in~tind footling areas ~a~nd coastal ~Ins~e~qwe~l~e~t                                       preliminary into low Indicates that a s~q~u~i~r~afi~c~a~n of                                                             influenced by d~e~v~e~j~op~m~e~n~L ~T~he two CAM caribou
                        habitats. ~tr~i~'years when ice breakup is late and more of                         ~at least ~4~0~0-90~0, fed improves caribou crossing success                                                                   encountered ~the dee~l~oP~m~e~r~t scenario to a much greater
                        the PCH caking occurs east and southeast of the 1002                             (Cu~r~mo~lo and Rages. 19~8~6).                                                                                                extent than cod the coffered PC~H caribou: 413 (32~.7
                        area. there Is a strong westward ~m~*~v~qmen~t blowing                                                                                                                                                           percent) of ~12~64 point locations and ~8~3 percent of routes
                        Caking. ~qWh~i~all~y, the entire PCH gathers an the 1002 area                   ~1~%           Where Cura~lo~l~o and Murphy (1~9~63) and Smith ~a~nd                                                                     were within the approximately ~2~4~"~Ne Interaction area-
                        ~~~ foraging and insect relief. with large portions of the herd                  Cameron (198~%. b) documented reduced crossing success
                        lending to remain on the 1002 area later Into July and                           in areas of ~ol~l-c~o~ol~o~st~ed development, It ~h~as been ~f~o~r caribou                                                                   Effects of disturbance might 81~30 include injury by
                        August during the years of late breakup ~(R~os~en~e~t~ru and                           e~Vc~r ed to major o~f~f and gas development for extended
                        SIM. 1974; U-S. Fish a~nd Wildlife Service. 1~98~2; U.S. fish                       pe~d~o~x~is annually In the combat Alaskan Arctic since the                                                                   trampling during stampedes. particularly calves: energy
                        and Wildlife Service. unpublished data). The Insect season                       early ~1~97W~s~. Because som~i~s habituation would pr~es~urn~o~tb~ly                                                                 stress. possibly ~v~i~t~i~ca~l during ~t~in~ve~s, of low energy ~n~i~se~me~qs~q'~q.~q"
                        is a period OF e~x~h~i~s~qm natural harassment ~a~nd one of the                          have o~c~cur~re~c~L ~a~t I ~ed in the CAN m~or~y be more ~lk~q* to                              ~J                                      such as winter and pos~tcal~king: and inability to reach
                                                                                                                                                                                                                                   ~inse~d~,n~o~l~ef habitat which also Increases energy loss. Miller
                        Primary driving forces in the annual caribou cycle This                          cross an ~c~oll~i~4~e~ld development than the PC~H which would                                                                   ~a~nd Gunn ~(~1~9~7~M and Northwest Territories Wildlife Service
                        harassment blows closely behind the critical calving period.                     encounter such develop ~ve~t is for only 2 or 3 months each                                                                 ~(~i~g~r~g~) noted that major physiological responses to
                        -insect harassment can h~a~i~e a pror~iounced negative effect,                       year.                                                                                                                     harassment may occur at the absence of visible behavioral
                        on caribou survival. ~Mel~l~e and T~a~rv~id~n~en (~1~9~6~4) reported                                                                                                                                                   changes
                0       that insect harassment reduced growth In reindeer calves in                             Eighteen percent (29~4.000 acres) of the 1002 area.
                        ~ir~@~ ~~nd contributed h~e~ar~v~il~t~i~r                       ~m~c~i~r~ta~i~d~y,                ~in-~or~t~t; ~R~I~C~A~S~qK !ends, used for ~insec~t-~reliel ~a~nd other
                        ~~llow~g winter. ~I~ns~e~d harassment also ~q~ed the                                   purposes by ft P~C~H So north of the proposed                                                                                      Aircraft ~a~d~w~i~t~ies we another cause *I d~is~tu~tba~n~c~W
                        ~~2p~1p~~912;5168;44;16q-tmatur~il~y. Insect h~o~r~r~o~l~o~w~ne~n~t and the avoidance                         p~ipeli~m~e~/r~o~ad corridor. Use o~f this we* by the P~CH could                                                                  numerous ~lnst~anc~@ WON" ~c~a~n~t~i~m, have been
                 4      ~:~~~~~s of caribou put considerable energy abuse on                              be affected by two possible factors. If c~a~n~bou refuse to                                                                  documented. For ~ex~am~n~f~e. Ca~W and others (1~9~7~61
                        ~~~b~u (Reimers. IWO~: While, ~1~983). Davis and                                    cross through any d~ev~e~l~qM vie I areas. then ~2~9~4.OO~D acres                                                          ~2.~q)     reported that helicopter$ which h~azed -ft- ~b~or~s the rear
                        V~~kenburg (1~9~7~9) repo~rt~ec~qk several deed and sick cakes~ ~i~n                      would be u~n~a~v~al~l~oble ~as habitat. That ~s~c~o~o~f encompass"                                                         ~%~,~,~qM       caused the most severe panic ~r~e~e~c~t~io~n.~: Large herds Of ~qu~qp
                        the Western Arctic caribou filed. a~l~l with heavy infestations                    52 percent of ~l~o~il~al ~insec~t-rel~le~1j~i~o~h~l~i~a~l~s, and over so percent~;                                                         to ~60.000 ~w~irm~i~ls could be herded b~y ~q"g at attitudes of
                        of nose but larvae                                                               of coastal i~n~s~ec~t~-~mli~e~l~ habitats. This would mean ~#h~o~t &I                                                                UP to ~2~.~i~foo feet above ground level ~(~A~G~L~).~j Calves wave
                                                Reduced access to ~i~nsedreli~el habitat                                                                                                                                              more sensitive than other age classes and caribou on
                        would result ~i~n greater energy stress with possibly reduced                      coastal ~i~ns~e~d-re~f~le~f habitats within the 1002 area. except for                                                            caking grounds were most reactive.
                        survival                                                                         Ja small am In the eastern portion. would become
                                                                                                         unavailable under full development. The second factor Is to                                                                      Recommendations for aircraft restrictions differ~.
                              Numerous investigators have reported on the varying                        assume the ~s~p~o~n xima~t~e~ly 2-m~il~e sphere of Influence for o~i~l                                                               According to ~C~o~l~le~f and *~I~he~rs ~(~1~9~7~6~1~. ~q"~h~t ~e~l~i~e"~n~i~ons ~0~q1
                        successes of caribou a crossing roads and ~p~ip~eli~me~s.                             development used previously. Under thin ~a~ssum~pl~i~qm.                                                                        ~500 feel AOL would prevent         Most injurious caribou
                        associated with Prudhoe Bay ~f~ac~ili~f~fes (Fancy, ~19~82~, ~1~9~8~3~;                       caribou crossing through the development am would avoid                                                                   reactions and attitudes of 1.000 feet AGL would avoid mild
                        ~u~a~o~, 1~9~8~4: Cu~r~a~l~o~b ~a~nd Murphy. 1~98~3~; South and                               using approximately ~7~2~,00~0 acres car 29 percent of identified                                                                                ~a~,~. These investigators recommended that
                        Cameron. ~1~9~8~5~5~a. b)~. Crossing success depends an s~a~ver~s~t~a~i~r~i~,                    coastal insect~ habitat within ~th~e 1002 ~v~a food                                                                           escape respect
                                                                                                                                                                                                                                   a~irc~r~a~ll maintain attitudes of ~J~.~qW~0 feet AGL doing caribou
                        factors inducing traffic and human activity levels. pipeline               ~'~f~.~qJ~' K~IC~4A~SRC funds ~(P~a~nk and others, 19~0~6). Failure to obtain                                                                 caking, caribou rut. find early winter. Davis arid ~V~a~&~e~n~qb~qw~qg
                        design. season. and ~q" and amount of ~br~is~e~d h~er~es~s~imen~t~.                          re~f~ie~f l~~n~s~in ~i~n~s~e~d h~a~qm~sm~e~n~t from either t~act~o~rr could                                                                    (~19~79~) also noted a. ~qWer~s~e relationship between ~th~e
                        Cari~~~u crossing success Is g~e~r~"~r~id~ly greatest of bt~a~l~e                         shorten foraging ~V~or~m leading to po~o~n~er ~phy~s~t~i~-~c~a~l condition
                        pipelines and then d~e~c se~a for mods without traffic. to                          and subsequently to increased susceptibility to predation                                                                 attitude of ~a~rcra~f~t ~ll~m~d se~ve~qf~qt Of the "~w~i~t"~a"~.~3 ~r~e~a~d~"'~n~q-
                        elevated (at least 5 ~q" toilsome ground) pipeline% adjacent to                    and reduced ~ov~env~ir~de~r survival.                                                                                          They recommended ~s~t~i~f~tu~de~s of 2~-~O~w ~f~qW A~O~L from ~M~qa~qy t~qo
                        mods without traffic~. to pipelines adjacent to roads with                                                                                                                                                  August. The ~P~e~wy caribou herd in Canada reacted
                                                                                                                                                                                                                                   s~k~r~dafl~y ~1. helicopters (mom end Gunn. 1979~)~; attitudes of
                        traffic. Large mo~squ~i~l~o~-~h~o~ur~o~ss~ed groups do not readily                                 Notwithstanding the lim~i~l~ed sample We fund                                                                                                                                                   ember
                                                                                                                                                                                                                                   ~2~.~0~0~0 feel AOL were recommended ~l~o~t May to Now
                        -cross b~~i~e~-~s~t~h elevated '~qPl~i~m~il~i~m~es (Curii~qW~a~n~d Nl~2qAi~f~ty~.                  ~f~.~.~o~J t~h ~te~b~w is covered the s~a~tel~ke ~l~e~f~er~n~e~ir~y work of ~P~a~t~* and
                        ~9~3: Smith ~a~n~d Cameron. ~i~9~qm~)~;~~a~ie~t~te~c~qtio~qm~e ~qc~qi~u ~0                                others (ING) p~r~o~v~id~i~es an ~2           t~i~on of the extent to which                                                         ~a~nd 1~.000 feet AGL of other limes.
                                                                               . ~-~P~-~L
                        miles during ~q~ caribou ~frolt~ed ~- ~r~wr~i~-~I~t~"~I been                            ~q1~q1~4q0   ~'~4q7~.~q-~q-                 could Interact with facilities and                                                                          ~0.~1~. ~a~nd V~o~lke~n~b~wg (I-) reported that caribou
                        observed in the central Alaskan Arctic. During the oe~st~orl~id                     in structure necessary for full leasing. Their preliminary                                                                may respond more to People on the ground than t~o ~fl~y~qwg
                        ~~y season. c~ari~b~qm crossing success was markedly                                 analysis o~f ft potential interaction between PCH and CA~M
                                                                                                                                                                                                                                   aircraft. They recommend that people and ~veh~I~d~w~o maintain
                        increased. In ~c~om. ~m~i~z~b ~9 their 1~98~1-~03 studies of caribou                       caribou and the ~a~l~l d~ev~elopr~i~v~er~d scenario used In this                                                                       ~n~i~.   u distance of 3,000 feet from caribou during
                        crossings of mods ~a~nd Pipelines in the Prudhoe Bay and
                                                                                                                              ENVIRONMENTAL CONSEQUENCES                          log                                              too ARCTIC REFUGE RESOURCE ASSESSMENT

    ~0

                       difficult to assign Staff to such remote areas to enforce                    4.    Site nonessential facilities outside caking areas and                                                occur in the area of evpl~oralion wells if ~c~a~r~,h~n~i~i ~er~i~l~p-~d the
                       existing laws and regulations                                                      major movement zones (Cameron and Whitten. 19~79~:                                                     area while well dri~f~lin~g activities were underway Because
                                                                                                          E~f~i5on and others. ~1~986)~                                                                            h~i~tman activity would be low. effects would m~o~M ~h~6~e~l~y
                               Based upon ~e~xpe~n~e~nc~e with TAPS and Prudhoe Bay.                                                                                                                                 instill Irom some avoidance and displacement around well
                       mortality as a result of vehicle collisions, entanglement and                5~@    Separate roads and pipelines as necessary in areas                                                   Pads
                       other accidents should be minor ~(R.D~ Cameron and K.R                              used lo~t Crossing to improve Crossing success
                       Whitten. unpublished dais).                                                        (Cur~s~tol~o and Murphy. 1983~; Cur~a~t~o~lo and others.                                                            The expanding population trend for the CA~M in the
                                                                                                          ~1982; R~obu~s and Cur~s~t~o~l~o~. 1~9~83: ~El~ison and others.                                                   past decade would indicate that the CA~M is not at carrying
                       Mitigation                                                                         1~9~0~6; C~u~r~a~t~e~k, and R~e~ge~s. ~1~986~),                                                                     capacity (the number of healthy animals that can be
                                                                                                                                                                                                               maintained by habitat on a given unit of land). However.
                               The following measures would help avoid and                          ~6.    Acquire authority to establish time   and arm closures                                               the point of which cumulative effects and expanding
                       minimize habitat v~ak~ie losses in the ~1.304.000 ~scr~es o~f                            or restrictions on surface activity to minimize                                                      developments all modify suitable displacement habitat is
                       Ile . .... ce Category 2 caribou h~abi~l~s~t. Mitigation of the loss                   d~is~turb~anc~m during calving or In c~oncen~tr~a~ded use                                                    unknown Also unknown is carrying Capacity of the P~CH
                       of caribou habitat in Resource Category 1 (242.~0~0~0 acres of          ~4q0~8q0            areas (Cameron and Whitten, 19~7~9~: Cur~s~tol~o and                                                       Given the geography o~f ~th~e caking areas and current
                       core calving area) Is n~o~t possible.                                                others. ~1~082: Ro~bu~s and Cur~al~o~to. ~19~83)~.                                                             der~milie~s in those areas. the a~v~e~f~l~ability of suitable
                                                                                                                                                                                                               alternative habitats is not apparent.
                               For exploration activities. a~l~l environmental protection             ~7.    Establish Ores and area closures and minimum                                                                                                                ~0q0~1
                       ~~5~~~~5 required during the previous 1002 coastal plain                            ~al~lifucle restrictions for, aircraft operations of 1000 feel                                                A major change in distribution as an adverse result
                       exploration program (50 CIF~IR 37.31) and the drilling of an                        AGL (Aug. ~1~6 through May 1~9) and 2000 feel AOL                                                       of displacement of both that portion of the CAM using the
                       exploration wee on K~IC~IAS~RC lands (August 9. ~1~9~0~3~.                                 (May 20 through Aug. ~11~5). A~i~ll~itud~e and time                                                        1002 area as wee as ~the entire PCH ~c~g~u~l~o occur if the
                       Agreement between Arctic Slope Regional Corporation and                            restrictions ~m~ay be modified after further study.                                                    1002 area were fully deve~foped. The m~e. ~a~i~r-~pipel~i~ne
                       ~he United States of America. Appendix 2~. Land Use                                                                                                                                      would bisect the 1002 area between the western and
                       Stipulations) will maintain most habitat values. ON                          ~8~   Monitor the effects of ~o~i~l d~e~ve~lo~pme~s t on caribou.                                                  northeastern bounded". Disturbance would occur from the
                       exploration. with the exception of surface geology ~stu~d~les.                                                                                                                             presence and activities of up to ~6.~000 people. hundreds ~a~t
                       should be ~q"~ad to the period of winter conditions.                            9     Annually m~o~rr~i~f~t~m herd size. product~q"~. movements.                                                    vehicles. and major constriction ~a~nd production activities
                       generally November I to May I                                                      distribution, and general health. ~i~f grater or                                                       scattered throughout the 1002 area. including sensitive
                                                                                                          additional adverse effects are found to occur then                                                   caribou caking areas. Use of approximately 25 percent of
                               For oil development. the success ~o~f various                                those ~I~n~A~l~v~ill~y Predicted, additional mitigation or                                                  ~the total PCH core caking area and 29 percent of the
                       stipulations designed as mitigation will ulti~ma~l~e~l~t, determine                     Protective management actions would be Implemented                                                   coastal ~in~sec~t~-rel~lef habitat could be reduced or eliminated.        ~q1~0q4
                       the degree to which o~i~l developmer~i~l~l actually affects caribou                     upon the recommendation of the FW~S. In conjunction                                                   Potentially a much larger portion, nearly ~00 percent of
                       using the 1002 area. Measures previously used with                                 with the State where effects extend beyond the                                                       coastal ~In~se~c~t~-~ire~f~ie~f habitat. could be affected ~N develop~r~i~t
                       success for Arctic o~i~l development ~a~s well as other                                bound~a~r~l~e~s of the 1002 area. Additional mitigation                                                   proves to be a barrier to caribou movements. Loss of
                       measures which should further help to reduce negative                              could Include further seasonal wee closures. surface                                                 caking habitat, barriers to free movement causing reduced
                       effects an caribou include:                                                        ~w air traffic restrictions~, phasing of field development.                                            access to inse~c~t~-~te~l~i~e~f and other areas. disturbance. stress,
                                                                                                          or ~s~t~a~l~q"f~-~th~q"~d measures.                                                                             ~and other factors would cumulatively reduce both available
                       ~.      Bury all pipelines where possible (Cameron and                                                                                                                                  habitat and habitat values an remaining areas. resu~f~f~in~g In
                               Whitten. 1979: Efis~or~, and others. ~1~9~M). Because of                  10.   Protect ~Insec~t~-~r~el~~ef habitat and facilitate free                                                    Caribou population declines.
                               permafrost. opportunities for pipeline burial will be                      m~o~v~e~merd ~and access ~f~i~x caribou by reducing
                               ~~.. Where burial is not ~lea~sible~                                         surface occupancy in ~t~he zone from the coast to 3                                                           These changes in h~ab~l~i~a~ll availability and value.
                               ~                               ~~@ ~1p~  I ~     ~, I      ~               miles Inland (E~lso~n and ~d1her~s. ~1~98~6). Occupancy                                                     combined with Increased harvest. could result In a ~M~N~J~W
                               A  Place ramps over structures in areas of natural                         would be restricted to marine ~f~a~c~i~f~f~les and                                                          population decline and change in distribution of 20~-40
                                  ~a~oss~in~g~s of where development tend$ to funnel                           ~I~r~Ssfru~c~h~ur~e necessary to move Inland beyond the                                                     p~e~r~i!en~i, based an the amount of caking and in~se~c~l~-rel~ie~l
                                  caribou (Cur~af~o~lo and Murphy. 198~3~; Robus and                           restricted zone                                                                                      habitats to be adversely affected. Because 0
                                  Cur~s~to~lo~. ~1~9~63: E~g~s~o~n and others. 191~11~1~1)~                            ~I~n                                                                                      ~"~N           variables involved and lack of relevant experience in                ~8q0~q1~8q@
                                                                                                    ~11.   Protect riparian and adjacent areas by placing                                                       estimating impacts on this herd and because of the
                               ~  Elevate pipelines ~(~the most common practice) to                         Permanent production ~I~s~e~f~f~i~l~les outside ~th~e areas                                                    t~1~offi~cu~r~r~y, in quantifying impacts. this estimate is uncertain.
                                  allow free passage *I caribou in areas without                          within ~3~1~4 ~"~qf~qt of the high-water ~mae~k an both sides
                                  ramps (E~Nson and others. ISM).                                          of Identified watercourses (p~l. 2~8~) and by ~f~l~ar~ri~t~i~ng                                                       For the CA~N. a moderate change in distribution or
                                                                                                          Crossings of ~b~a~rn~s~i~p~q"a~l~i~on facilities                                                                decline in that portion of the CA~M using the 1002 ores
                       2.      Reduce disturbance from vehicle activity by limiting                                                                                                                            could occur. The effect on ~th~e entire CA~M population
                               use of development infrastructure to essential industry,             Conclusion                                                                                                 throughout its range may *Igo be moderate. Those effects
                               :nd agency personnel on official business (Ell~so~n                                                                                                                               c~~n the segment of the ~CA~M within the 1002 area would be
                               ~~ others. ~1~9~8~5~)~                                                          Surface geologic exploration and study conducted                                                     similar to those on the PCH that occur from disturbance.
                                                                                                    throughout the year would be controlled by specific time                                                   di~sp~tac~qmen~t and barriers to ~fr~e~a~, movement. The
                       ~       Close the area within 5 miles of &I development and                  and area closures to avoid c~a~rr~i~f~f~ic~t~s, with caribou caking                                                p~~l~@~q@~Ia~ll~r~o~r~a cle~d~h~e of distribution change would be 54~0
                               associated infrastructure to hunting and trapping. as                and movements during the ~In~sec~t-rel~i~al~ period. Seismic                                                    percent for the CAM throughout ~i~ts range
                               wee as to discharge of firearms. so as to reduce                     act" would be confined to winter work only. Based
                               disturbance to caribou and to protect people and                     upon experience ~f~ir~om the ~1~9~63-1~9~6~5 exp~l~a~i~n~t~i~l~i~o~n, program In
                               equipment (E~N~son and others. INS~: Carruthers and                     the 1002 area. only negligible effects would occur.
                               others. 1~9~94).                                                       Localized avoidance ~and disturbance of a minor nature my

                                                                                                                     ENVIRONMENTAL CONSEOUENCES                      111                                       112 ARCTIC REFUGE RESOURCE ASSESSMENT

    ~0

                                    Partially offset by habituation which has berm ob~smed b~v                                                 and L~aP~l~an~t ~J~I~S~S~S~)~. a 2~-~mil~e sphere of ~mf~i~l~i~e~n~ce ~w~e,                                                                                                                     ~m~l                                                                                             ~qF~qo~ql~ql~q'~qa
                                    Maw ~a~n~d Gum ~0~9~7~9~1 during ~c.p~q@~,~I~a~l h~rk~o~p~f~w                                                                assumed in ~cal~c~u~b~d~i~n~j the ~r~p~g~r which ~c~o~u~" ~b~e ~f~f,~(~qW
                                                                                                                                                                                                                                                                                                                                                                                                                     ~qe~qs~qo~qn~q.
                                    harassment                                                                                               ~b~y full ~l~ess~-~9 Table Via Shows that hab~d~a~t values could                                                                                                                Maim ~n~"~a~l~i~v~o~~0.1~1~F,~1~3 upon the ~mu~sk~o~,~en ~p~op~u~l~i~lin~n                                              ~qth~q, a
                                                                                                                                             ~be ~10~3~1 of greatly reduced ~ohro~ug~h~o~u~l~l about One third                                                                                                         from ~m~i ~r~~f-~l~o~p~m~e~rr~i~l could occur. consider~; the p~re-~I                                                   numb
                                              ~Mus~k~ox~m are Present on the 1002 area ~l~o~n~m~9h~o~u~g                                                 ~05~6~.0~00 acres) of the mus~l~u~t. long& within the 1~0~02 area
                                    ~he winter when most exploration and Construction ~c~l~ov~d~i~a~,                                                                                                                                                                                                              management objectives ~l~or continued p~opu~fa~lmn growth of
                                                                                                                                             ~"~8~1~1~4~01~1~1 Used for ~q" ~m~g,~n~a~l Or ~f~r~ew~n~gu~r~ad use,                                                                                                                 the held un~d~w natural regulation ~a~nd the d~i~ip~l~ac~e~m~en~t from
                                    would take place Illustration daily activity my decrease                                                 ~"cording ~C~O~"~a~r~g. would b~e d~i~sP~l~O~o~r~o~di~r~m~a~l~e~l~y, affected.                                                                                                        h~a~bd~a~t ~I~&~A~V to ~F~r~acur Mu~s~k~o~me~n could be displaced ~Ir~qm                                                    come
                                    during --I- ~(~Re~"~Ol~i~f~t~. 1~9~86) as poll of ~Ih~ew behavioral                                                  ~m~o~lsl~u~n~t~m would be displaced from~ approximately s~3.
                                    strategy 'Or energy Conservation Repeated d~i~s~i~turb~anc~e                                                   P~W~C~W~d1 Of those habitats Habitat a                                                                                                                             up to It percent~! of their high use. year found with calving.                                            work
                                    C~~~~~9 ~m~e~qm~s~ed of Prolonged ~a~c~t~q" during the winter                                                        nearly ~7~5 percent of the high use hit                                                 ~1~.~0 ~o~n                                                                   habitats within the 1002 ales. This, coupled with direct                                                 some
                                                                                                                                                                                                        ~,~.~at~. =e
                                                                                                                                                           Such                                                                    or Calving                                                               mortality and ~the unavoidable ~ell~3~t~u~r~b~anc~e~i would "use                                                   Moos
                                    results in energy drain which May ~p~h~u~S~e~ly affect ~S~u,~m~a~f                                                  occurs                        high percentage of loss                :~Idu~able c~a ~in~g                                                                           ~the population to decrease and ~i~ts distribution to ~be                                                    ales
                                    of individuals ~W Product" of pregnant females                                                            habitat Could ~q4~1~0             ~.a ~m~il~l~m negative ~influ~m~in~e on held ~o~v                                                                                           ~of~ler~ed ~E~f~fe~c~is would be ~q"~a~t ~pr~o~n~v~a~rr~uced on the
                                             The effects an ~m~u~s~koxe~n from h~a~b~l~ia~l loss ~C, stress                                             productivity                                                                                                                                                   ~s~u~b~popu~l~a~ti~o~n using the N~i~go               ~1p~1p~p~p~p~1p~p~1p~p~p~p~p~p~Ag~ur~r ~A~t~,~.                                 ~qM~qi~qf~qig~qs
                                                                                                                                                                                                                                                                                                            ~q:~1~.~8 This ~sub~o~r~m~o~ru~fall~on Is ~th~e smallest                                                   ~8~0)
                                    due ~0 di~S~l~u~x~t~r~a~nc~e have ~b~q@ ~o~k~i~i~i~c~uq ~to -~a~su,~e Mow                                                                Direct ~q~1~1~11~t~y could result from hunting. vehicle                                                                                                     nd has ~th~e least amount of interchange with other
                                       of
                                    an Gunn 11979) concluded that lack ~M visible response                                                    ~c~0~a~l~s~i~l~t~"~I~s~. ~S~oll other ~s~ec~id~a is associated ~w~4~h                                                                                                               to
                                    do                                                                                                                                                                                                                                                                      u~b~p~o~p~u~b~f~i~a~n~s~, C~o~ns~p~o~r~m~f~l~y, ~th~e likelihood I ~i~t~,~,~* ~t~i~on                                                   Imes
                                       e~ ~"~C~o ~ne~c~es~s~s~r~*V mean the absence of physiological                                                   ~d~m~gk~*~q@~t Mu~s~ko~m~en we highly ~vu~l~n~u~g~l~o~o~l~e ~1~0 hunting. 14                                                                                                          111 Filling population depressing Imes on, I~M~S~O                                                          ~qc~qo~ql ~ql~qd
                                    Changes or energy ~d~r~a~n~a winch ~may have a major effect on                                                       direct ~1~1~11~3~"~0qW ~w~o~u~i~d be extracted to ~o~n~o~.~,~,
                                    ~h~ population over fall*                                                                         ~q(~qF~q:~2qP~~w                                                                                                                                                                ~su~b~p~o~q"~l~i~o~n we                 be very ~q"~ad                                                                l~qa~qcli~ql~ql
                                                                                                                                             ~f~i~n~x~i~ as ~OCC~O~m ~k~~qf~qt pr~e~~v~i~ou~sl~o~r undeveloped ~am                                                                                                                                                                                                                        Arctic
                                    ~~T2 Ores. will b~e exposed to year round ~ac~h~v~i~l~y As                                                       increased ~I~n~cr~o~o~m~ad hunting regulation ~a~nd enforcement                                                                                                                 Predicted population changes resulting bull                                                      ~qc~qo~qol~qg~qol
                                    described in ~t~he previous section on caribou~. loss of                                                    would be required to ~.                       ~q" l~o~q-~p~o~l. Voter adequate                                                                                          p.~.~0o~l~eu~r~n~ development we Speculative, Th~i~f~f~e, ~o~re ~n~o                                                   kept
                                    -~~r~~an~t h~a~b~d~o~l has bee" s~h~q~ to have ~m~e~oc~e negative                                                      ~a~r"~I~qm~O~n~O~r~d Of season ~a~n~d ~b~i~g *will ~r~e~e~k~k~a~o~s~s~. me                                                                                                               references ~I~n ~T~he literature ~t~o analogous ~a~c~l~ov~i~l~l~e~s ~o~n ~Mh~w                                              and
                                    effects                                   oven. ~N~K~O Carew. ~q;~-~q;~6q@                                          ~-~Ifi~r~ib~iff ~o~f ~s~t~~o~k~q-~f~t Idl~o~ad would be ~e~We~cled to p~e no ~on~i~y,                                                                                                  ~m~u~s~l~u~n~t~en ranges. H~q@e~v~er. c~on~s~i~d~e~o~f~f~i~,~v ~t~h~e large extent
                                    elect ~-~in~l~erin~g and Calving wells because of factors                                              ~     ~4 ~1 0~1 ~q~ on I~f~t~e~r Population,                                                                                                                                  ~J~I~S~9~.~0~0~0 sues. 43 percent) of ~M high use ~m~u~s~tro~z~e~n                                                       ~qC~qo~qn~qd
                                    favorable ~1~0 herd Productivity and survival availability of
                                    ~re~~~e~d forage. below weather ~o~r ~sn~q" ~c~m~d~o~f~t~o~g, ~e~l~s~h~ve                                                   Mitigation                                                                                                                                                     habitats within the ~100~2 ~v~t~o. as well as ~m~o~r~t~e~r than ~33
                                    absence of predators tacit of disturbance or some                                                                                                                                                                                                                       percent of the population's high use habitats throughout ~the
                                    co~~~~~a~l~l~o~n of these and other ~f~ac~l~o~rs Displacement ~k~u~n                                                          Negative ~q~~a ~1~0 ~qM~sk~o~x~w, could be ~m~e~g~a~t~ed by                                                                                                             Arctic Refuge which could be affected under kill leasing. a                                              loss a
                                                                                                                                                                                                                                                                                                            change in ~cl~i~s~t~r~i~bu~l~l~o~n or decline affecting ~2~5~-S~O percent of                                            would
                                    ~~1-9 areas would have a ~neg~m~w~e effect on ~m~u~s~k~o~xe~n                                                       Standard sl~i~t~sur~b~o~o~k~a~u~s pro ~w~i~s~a~~m ~9 disturbance. ~I~mp~l~e~m~,~n~i~kg                                                                                                  the =lion ~q" occur,
                                    ~m~uc~h~on The ~"~W~o~or~utu~de o~f that ~e~f~f~n~i is ~d~i~r~a~lu~f~t 1~0                                                      ~"~OC~"~I~t~q" ti~e~w and ores closures. and requiring ~o~n.~s~h~@
                                    accurately Predict P~a~r~l~o~c~u~l~arl~y in view of ~t~h~e expanding                                                 ~m~0~r~o~l~l~c~O~n~g Continued ~mc~in~N~o~v~in~g ~o~f the p~oput~ati~o~l~ls                                                                                                            MOOSE                                                                                                    GALL
                                    ~~~~~ ~*~1 ~t~h~e ~p~r~p~ul~b~a~u~l~n ~a~nd refuge ~-~0~"~9~q@~t ~-~b~i~e~c~t~i~v~a~s                                                     ~or~o~w~t~h~; ~A~.~'~r~a~b~l~R~i~O~n~. ~a~" ~M~o~v~p~l~v~q@~s                                   ~qd.e~c~! ~c~o~r~u~r~g~.
                                    ~0 allow ~u~r~n~h~oued Population expansion The affect on                                                     end de~l~u ~W, a what. of ~a~ny~. additional ~m~i~n~g~a~t~i~on ~m~ay ~b~e                                                                                                                The 1002 ores Is no~t high ~q~u~ar~d~o~r moose h~ab~i~l~a~U
                                    ~~~d~~~t~l~on would likely be related to ~th~e magnitude and                                                  n~o~w~le ~BeC~f~t~g~o riparian W~a~s~$ ~a~n~@ ~11~1~FO~re~d habitats. those                                                                                                       Peak use by moose Is during ~th~e su~r~n~e~m~n when the 1002                                                    Mow
                                    du~~~~on of dis~plac~en~w~i~                                                                                 51~1p~~r~l~at~ion~s~; lot ~C~W~IbCK~l ~I~f~il~l close valuable riparian ~o~r~t~m~o~r to                                                                                             area population probably is less than 25~: during the willow.                                             ~qth~qe
                                                                                                                                             ailing Of Permanent facilities ~a~nd l~i~a~ti~l Crossings of those                                                                                                   moose are Fare on the area The portion of the total refuge                                               hun~qt~qin
                                           No m~f~or-~p~l~on Is available on ~th~e ~l~e~a~c~h~o~n of                                                       areas by transportation ~l~o~c~l~i~t~i~f~t would ~m~in~i~m~i~l~e potential
                                    mu~k~~~" ~10 ~sus~t~a~m~f~t~f ~o~d d~e~ve~l~o~o~m~u~l~t ~A~nd production                                                       ~i~n~I~V~I~NC~U~M~S ~a~nd ~C~k~b~j~e~o~M~c~o. which would ~F~uj~o~X~9 ~$~f~f~#~C~g,                                           ~0~.                                                              population ~t~ep~r~e~se~a~lled by this ~q" is not known                                                           could
                                    ~~~~~~~~s From ~th~e reports ~o~f ~P~us~s~@~q ~1~1~9~y~7~) ~q" Reynolds                                             I      MUS~I~F~O~-~O~n as wall ~l~o~p~l~. ~2~g~)                                                                                                                                            Direct ~qW~e of habitat Is expected ~to be ~abou~l IQ                                                  ~qM~qi~qt~qi~qr
                                                                                                                                                                                                                                                                                                            sues ou~t of the ~9~8~.00~0 so" of the ~1~01~12 Wes identified ~8~9
                                                               Table ~V~l~-~e~'~-~-~O~b~'~q@~'d ~q'~S~k~O~x range ~00~1~"~I~'~M~a~i~r ~8~1~f~i~eC~te~d by development under full ~le~a~s~.~9                                                                                                                                                        moose use a~r~e~s~v~ Affected Was% we low density habitats
                                                                                            o, limited ~le~ss~mg~. Glistening a 2 mile ~sphm~, of ~m~h~u~m~c~e                                                                                                                                                          ~f~f~ess then one ~m~e~ros~e per 2~6 ~I~Q~qW~* ~F~r~o~l~l~"~I~. ~F~r~aff~i~nl~y' on Block                                                    ~qi~qnc~qr
                                                                                                                                                                                                                                                                                                            ~D ~(~o~f IQ)                                                                                                ~qP~qD~qP~qL~qd~qe
                                                                                                                                                                                                                                                                                                                                                                                                                     ~qas~qs~qm
                                                                                                                                                                                                                                                                                                                    Moose adapt ~m~adi~f~f, a~nd h~ab~i~f~t~r~al~* ~1~0 ~the Presence
                                                                                                                                             H~i~gh,~t~is~t range seasonally                     Other                 Total                                                                                     of human activity. they an, not easily disturbed (D~er~m~is~l~on.                                             Co~qm~qe~ql

                                                                                                                                                                                                                                                                                                            North America ~W ~th~e ~o~u~f~f~o~r~ld~ ~l~W~f~t ~th
                                                                                                                                                    or year round                           range                range                                                                                      1~9~5~6: Peterson. ~I~qM~2p~oose have
                                                                                                                                             Without Calving With calving                                                                                                                                                                                          =                                    ~-~q;~4q0
                                                                                                                                                                                                                                                                                                            has spread (Davis and F~,~an~tr~on~s~wr~i~. 19~7~9)~ On the Kenai                                                  would
                                                                                                                                                                                                                                                                                                            Notion ~to Refuge In Alaska. h~e~�C~qWW supported                                                            an Do
                                                Total ~m~u~sko~x range              (acres) within Arctic ~Re~l~lg~e~.~                                    ~2~5~1~.~O~W                  ~2~110~0~0          ~0~4.000            ~1~2p~p~p~p~p~p~                                                                                     art~. seismic s~u~m~W~9 using ~u~tp~i~r~l~s~N~es ~d~id not modify                                                       cons
                                                Area (acres) willow development sph~er~s, of Influence~:                                                                                                                                                                                                       moose ~C~%~s~q~~I~u, patterns. ~m~o~w~wr~ient~s~. or behavior (Bangs                                                   a ~ql~qe~qs
                                                   Full leasing      . . . .. .. . . .... ...... .. ...... .........                  _ - ~1p~p~   ~~"~.~0~0~0                 1~1~2~.~0~0~0          ~9~8~000             ~2~5~6~~0~W
                                                   ~L~i~a~r~l~ied ~le~s~si~n~g         ...... . ..... ......................... ......           ..............  ~4~6~~0~D~O               ~1~10.~00~0          9~8~.~0~0~0             254.0~00                                                                                      and ~S~a~il~ley. ~1~9~8~2) Most studies have dealt with Moose i~n
                                                percent of Arctic Refuge range influenced by development                                                                                                                                                                                                    forested areas. The response ~o~f ~m~c~F~ese ~10 dis~fu~l~b~Onc~t in                                                 ~qV~8qW~qIL
                                                   Full ~l~e~a~S~t~r~i~g~                                                                     ... ...........      to                    ~5~3                   is                           23                                                                       ~u~m~d~O areas hag n~o~t t~t~q@ de~m~o~n~s~t~r~8~t~t~?~d
                                                   L~i~n~v~ied leasing-                                                                                        to                    ~5~2                   ~15                           23
                                                total ~m~u~s~k~o~x range (acres) within ~1~1~1~1~1~2 peg                                                       20~7.000,                ~1~5~6.000         ~119~50~0~0              ~T~qW~O~M                                                                                                Increased human development On ~Ih~V ~K@~n~g~-                                                         (Wee@
                                               Percent 61 ~1002 arm influenced by development                                                                                                                                                                                                                                                                                                                         when
                                                   Full leasing      .. ............ . ..... . ....~:..... .   ............... ....    ........ ..          22                    ~71                   25                           ]a                                                                       Peninsula, Alaska. has resulted In Increased moose "~O~"~2~5~t~y
                                                   ~L~-~Wed                         ... . ....... .. .. ..... .. ... ........                                 ~2~?                    ~7~0                   ~7~5                           ~1~1                                                                       from hunting. vehicle ~c~o~ll~s~e~t~n~t~s~. ~l~s~r~l~f~f~c~q"~ ~a~n~d other causes                                             d~qo~qcu~qr
                                                                                                                                                                                                                                                                                                            (Bangs ~a~nd o~th~ws. 1~9~82~1~ Moose ~m~O~r~t~s~o~l~t~i~r On ~lh~t~' 1002                                                   ~qin~qfr~qe~qa

                                                                                                                                                                      ~E~NV~IR~ONM~ENTA~t CONSEO~UEN~C~ES                                            113                                                             ~i~v~4 ARCTIC REFUGE RESOURCE ASSESSMENT

                           known to be cautious and wary of humans (Kron, 11960)                       BROWN BEARS
                           Wolverine distributions and movements on the 1002 arim                                                                                                                         Only 6 of 129 (4.7 percent) den sites documented                   of direct mortality, decreased prey availability, harassment.
                           would be &Rated by the presence of human activity                                  Brown bears are common on the 1002 area during                                        during the Arctic Refuge baseline studies were located on                and disturbance in denninq areas.
                           associated with ad development. Displacement of                             May-September when they Image and range widely, The                                          the 1002 area (Gomm and others. 1984. 1985), Therefore.
                                                                                                                                                                                                    the polenlial to disturb denning habitat and disrupt denning             ARCTIC GROUND SQUIRRELS AND OTHER RODENTS
                           wolverines from local areas of development an the 1002                      1002 area contains habitat used seasonally by bears at                                       clivities of the regional brown bear population from oil
                           area is very likely. In considering potential population                    moderate or high density (pl. IPJ. Habitat use and                                           :xploration and development would be low. and impacts                           Arctic ground squirrels are commonly found
                           effects to wolverines from the proposed Sushno                              populations throughout the Arctic Refuge have not been
                           hydroelectric project. Whitman and Ballard (1984) thought                   similarly delineated.                                                                        vould be expected to be minor.                                           throughout much of the 1002 area Moderate effects would
                           that local avoidance of work camps would not significantly                                                                                                                                                                                        result from localized habitat alterations such as placing
                           influence wolverine movements or productivity.                                     Under tug leasing. direct loss of brown bear habitat                                        Aircraft disturbance of bears is unavoidable. Doll and             gravel pads over squirrel colonies. Minor effects would be
                                                                                                       would total about 3.500 acres. 01-fWd activities would take                                  others (1974) and McCourl and others (1974) reported                     expected as a result of road kills.
                                  Because wolverines are primarily scavengers, their                   place throughout approximately 17 percent of high aild                                       variable reactions by beats to aircraft disturbance at 1,000
                                                                                                                                                                                                    feet AOL or less. Douglass and others (1980) reported                           Other rodents. primarily lemmings and votes. are
                           abundance is related to the biomass and turnover of large                   moderate brown beef use areas within the 1002 area.                                          bears reacted strongly to hazing by vehicles and aircraft.               naturally cyclic In abundance but can be expected to be
                           herbivore populations (van Zyt do Jong. 1975). Thus, the                    Ouantifyng the mn6er of animals Involved Is difficult.                                                                                                                affected somewhat by development on the IOD2 area.@
                           magnitude of anticipated effects an populations of caribou.                 Seasonal density of beers, an the 1002 area averages               we                              Direct bear ritortalilles from accidents or being shot in          Some effects may be posillve--structures and debris would
                           muskox. and moose upon which wolverines depend will                         bear/30 square miles. but local densities can range from                                     defense of human fife and property will occur. Drug.                     provide protective cover from hawks. owls, or other
                           directly affect the degree of effects on wolverines. Major                  one bear/10.5 square miles to one beer/2.200 square miles.                                   induced death of bears occasionally occurs when nuisance                 predators. Negative effects could include localized
                           effects have been projected for caribou and muskox
                           populations. mmor effects for moose. Magoun (1985)                                 Brown bears use the 1002 area mainly for feeding                                      bears are immobilized for relocation. Accidents. such as                 destruction of nesting sites and Increased modalities from
                           stated that successful management of wolverines in Game                     from late May through July when caribou are present. The                                     vehicle colfislons. could also reduce bear numbers.                      entrapment and traffic.
                           Management Unit 26A on the North Slope was directly                         potential decb a in caribou poputsftn and change in                                          Follmann and others (1980) reported 13 brown bears killed
                           related to successful management of the Western Arctic                      distribution probable with tug *aging (major for the PCH                                     in conjunction with TAPS construction and operation during               Mitigation
                           and Teshekpuk Lake cafibm herds. She further stated that                    and moderate for the CAH) could cause a decline In an                                        1071-79. The BLM 1191113) estimated that oil development
                           a decline In these herds could result In a decline In                       Important brown bear food source. This could result In                                       on NPRA In an area of bear density sirrigair to the 1002                        None additional to that already outlined Is
                           wolverine productivity. Whitman and Ballard (1984) believed                 decreased bear productivity and survival of young In years                                   area would produce a loss of one bear annually as a result               recommended
                           that a decrease In the populations of moose and other                       when aftemalle food sources. such as small rodents. are                                      Of confrontation between bears and oa development
                           prey as a result of the proposed Susftna hydroelectric                      scarce,                                                                                      personnel, The rate of rnortali-y would presumable be                    Conclusion
                           project could eventually affect wolverine densities,                                                                                                                     similar on the 1002 area. Most deaths would probably
                           population size. and movements. Reduction In abundance                             Brown beam are not readily displaced by human                                         result from bears' being attracted by Improper garbage or                       Developing 00 resources throughout the 1002 area
                           of the primary predators (wolves and brown bears for                        presence or activity. Brown beam along the TAPS corridor                                     food handling. or Illegal feeding.                                       would muse minor to moderate effects on squirrel
                             hich moderate and minor effects are predicted.                            became, so habituated to developmeni activity that they                                                                                                               Poputatims because of habitat loss and alteration. Effects
                           respectively) could also decrease the abundance of prey                     occasionally entered occupied bugdlngs In search of food                                           Bears that seasonally use the 1002 area are part of                on lemmings and votes should be minor.
                           carcasses available for scavenging by wolverines.                           (Foffmnn and others, 1980). routinely led at garbage                                         the same regional population inhabiting the mountains and
                                                                                                       dumps. and waged along roads and other activity areas for                                    foothills of the Brooks Range. Hunting pressure on this                                       MARINE MAMMALS
                                  During the winter wolverines on the tundra       are                 handouts. Electrified fencing successfully eliminated                                        population could Increase 0 oil workers remained on the
                           vulnerable to hunting from snowmabiles and aircraft.                        problems with both brown and black bears In two summer                                       1002 area during off-duly periods to pursue mcrealional                         Though 14    species of marine mamenals my occur off
                           Increased hunting and trapping could occur on the 1002                      camps of 100 people each in the Prooks Range (Folmann                                        activities. Increased harvest of bears occurred during                   the coast of the Arctic Refuge. only 5 species were
                           area as a result of the greatly improved access provided by                 and Hechlel, 1983).                                                                          construction of TAPS (Follmann and HechIL4. 11983).                      evatualtd: polar beer. ringed and bearded seats. and
                           the roads. traits. and @Wslrtps associated with oil and gas                                                                                                              Schalenberger (1980) similarly reported an increase In            bear   beluga and bowhead whales.
                           development. and the Increased human populations in the                            Disturbance to brown bears denning an the 1002                                        harvest as a result of increased human presence
                           region. Homocker and Hash (19411@ found that trapping                       area could occur. particularly from winter seismic exploration                               associated with oil development. Further regulation               of
                           was the primary cause of wolverine mortality. Van Zy2 do                    because such activity occurs after brown bears have                                          hunting by the Slate and the FWS would probably be                       POLAR BEARS
                           Jong (1975) fell that human predation was the factor most                   denned and den sites nay not be known. Disturbance of                                        required
                           likely to affect wolverine numbers.                                         derming bears. once development Is comittlele, should be                                                                                                                     Polar bears are one of the few large marnmell species
                           Mitigation                                                                  negligible since bears would likely avoid denning In areas                                   Mitigation                                                               present an the 1002 area during winter.
                                                                                                       where activity was occurring. Hanley and others (1981)
                                                                                                       found that brown bears In their dons were disturbed by                                             In addition to those measures listed earlier in the                       Polar bears are particularly sensitive to human
                                  Measures designed lot prey species      . such as caribou.           seismic blasting 1.2 miles away. as demonstrated by                                          chapter, strictly enfmdng prohibitions on feeding wildlife.              activities during the denning period. Beflkcrv (1976) reported
                           muskox. and moose will also benefit wolverines. Control of                  movement within the den. but no negative effect such as                                      dequale food storage. control of harvest. and control of                 that tornales will usually abandon their dems prematurely 0
                           access and harvest to minimize &act mortality would be                                                                                                                   :Ircratl '.light attitudes and corridors would lessen adverse            disturbed. Early den abandonment con be fatal to cubs
                           the most Important defer h anl of effects. This con                         den abandonment was documented. Reynolds and others
                                                                                              froll Is (1983) reported that seismic vehicles at shot detonation                                     effects of development resulting from fus leasing. An active             unable to land for themselves or travel with their mother.
                           recommended as mitigation for effects an several species.                   resulted In Increased heart rate and movement In the dens                                    monitoring program for brown bears during seismic                        Development of potential petroleum prospects In Block C
                           Conclusion                                                                  of instrumented brown beats. Harding and Nagy (1980)                                         exploration. construction. and other development activities              could have a moderate adverse affect on the conlimled
                                                                                                       reported brown bears successfully wintering within 1-4 miles                                 would help avoid disturbing denning bears. Buffer zones           of     suitability of the eastern portion of the 1002 area lot
                                                                                                       of active of exploration carrtps. Conversely. they also                                      at least 1/2 mile would be established around any known                  denning polar bears. substantially decreasing the habitat
                                  The cumulative effects of disptacernent/avoidence and                reported a den being abandoned when a seismic vehicle                                        dens as required for previous exploration In the 1002 area               values of this are*. At least eight polar bear dens were
                           reduced food resources could result In localized. long-term                 drove over ft. and den destruction during gravel mining.                                     (50 CFR 37,32 (c)j                                                       located within this are@ between 1972 and 1985 (pl. IFJ.
                           changes (a moderate effect) In wolverine distribution.                      Quimby (1974) reported that 5 of 10 brown bears                                                                                                                              Factors that may Influence responses of donning
                           Inadequate controls on access and harvest could possibly                    apparently abandoned dens In early October alter being                                       Conclusion
                           reduce by half or more the 1002 area wolverine population.@                 followed to their dens by helicopters.                                                                                                                                tamale polar bears to disturbance include: frequency and
                           11 this occurred, It would result in a major effect                                                                                                                            A/modevele decline in brown beer numbers or                        level of disturbance. distance of the disturbance from the
                                                                                                                                                                                                    change in distribution could result from the additive effects            den. and the stage of denning when disturbance occurs.
                           116 ARCTIC REFUGE RESOU             .RCE ASSESSMENT                                                                                                                                                         0@7                                                        ENVIRONMENTAL CONSEGUENCES                      117

    ~0

                                Pregnant females beginning ~10 den in ~the tag are especially                       Polar beers a~re attracted by garbage dumps and
                                vulnerable. A rac~go-~c~o~l~la~red female polar bear denn~in~g in                  could become a nuisance or threat to personnel In camps
                                the 1002 area emerged from her den in early February 1985                  Because beers a~re attracted to the Barter Island area to
                                (~A~m~3~trup. 1~986b)~, as the suspected result of repeated                      scavenge on whole carcasses. nearby o~i~l facilities could
                                disturbance from motorized exploration support equipment                   experience a higher occurrence of nuisance bears than                                                      ~O~HA~I~-~7           27 ~octob~er t~9~t~i~b
                                within ~1.600 feet of the den site. The bear was suspected                  other facilities report.
                                of being pregnant when she entered h~e~r den. even though
                                no cubs were Iota observed.                                                Mitigation

                                       pipelines and roadways may prevent l~em~o~t~e polar                            Some adverse effects to polar bears could be
                                bears from moving to and from Inland donning gross                         reduced by documenting den locations and use areas so
                                (Ams~tru~p ~and others, ~1~9~8~1~1: Le~n~t~f~or and Hensel. ~1~9~9~0)~.                     that o~d-d~evelop~e to I activities avoid them to the ~m~w~d~r~rwm
                                Disturbance from o~i~l exploration. construction. and                        extent possible. Avoiding suitable donning habitat is most
                                production in the Immediate vicinity of polar beer dons                    important. To prevent disturbance which could cause early
                                could cause the bears to abandon dens. Production                          den abandonment. buffer zones of at least IN nine should
                                activities could create disturbances that would likely keep                be established around known dens, such as the zones
                                bears from returning to those preferred donning areas.                     described lor brown bears 150 C~FR 37.32 (~c~)~j. Activities
                                                                                                           along the coast during the Into October-early November                                                                                                   THE REL
                                       Locating petroleum resources, with r~e~g~a~l~l~iar~d                       period when beers come ashore to den should be
                                development and production facilities, In confirmed coasted.-              ~m~in~kn~ized. Where possible. orienting seismic Ines.                                                                                             CAR~I~F~3~0~U SUMM~qf
                                donning areas could produce a ~m~a~j~o~ir~re~duc~i~l~a~n ~j~L~M~9 ~'~2q@~q@~2qp                    pipelines. a~nd roads of right angles to the coast In coastal
                                availability of t~O~O~2 area donning habitat. Although the                    arms could further minimize Interference with donning                                                                                                  AND THE I
                                number of bears r~etun~n~i~n~g each yew varies depending on                     bears. Also, Ice quality and movement data collected by
                                ice, ~an~q", and weather conditions. some researchers                         industry should be made available to the FW5 to ~su~gm~e~n~i~t                                                                        PIPELINE:               DOES ABS~qI
                                believe female polar beam show fidgety to ~b~kth sites ~e~nd                   research ~a~f~temp~ts to understand polar beer movements and
                                try to reach areas previously used for donning (~L~en~f~l~er and                behavior. Such dots would be Invaluable In ~le~x~am~ing how to
                                Hensel. 1~9~90). Ascent analyses suggest that m~or~t~a~l~f~f~ie~s of                 predict and m~in~k~i~f~t~s adverse effects of industrial s~c~l~qM~i~es
                                female polar bears are now about the maximum the                           on palm beefs.
                                Beaufort Sea population can sustain (Ams~trup and others,
                                1~986) without a decrease In population levels. Thus,                              It attracted by garbage, polar bears could become a
                                preserving undisturbed onshore donning h~al~t~ha~t each year                   nuisance or threat to personnel and would need to be
                                                           ~!~2 to ~1.~3 percent ~o~f I-                         ~n~e~i~t~t~e~l~ed~. proper garbage control and fencing ~al c~a~ur~r~i~t~s
                                den g on land rather than o~f~fsh~o~n~s ~I... M~o... It I               ~C~2qJ        would reduce this problem. Because killing polar bears by
                                there is an especially significant ~a~r~m for donning an ~t~on~c~U~ln              anyone except Alaskan Natives, Is prohibited under the
                                Alaska. it is on and adjacent to the 1002 area ~JU~S. Fish                   Marine M~om~m~al P~oote~c~t~ilo~o, Act of 1~9~72~. nuisance bears
                                and Wildlife Service~, unpublished data).                                   would have to be trapped and relocated.

                                       Additional habitat value Wass would result from                     Conclusion
                                development of marine facilities~. The P~okok port ago is
                                located in a confirmed coastal donning arm; polar bears                           Although only a ~l~6~w~ polar boars use the 1002 area.                                                                                                    R.D.
                                were known ~10 have denned within approximately I mile of                   the exclusion of only one or two bears from areas
                                ~the site in 3 of the last ~S years The ~C~omde~n Say area                      consistently used for donning would be a mode~r~a~l~                  c~!
                                has also been used by donning polar beam                                   on that segment of the Beaufort Sea population b~qa~qc~2qZ~q"~~q:             ~2qJ~qL~o
                                                                                                           some de~c~l~k e in the reproduction rate could res~i~l~a.                ~an
                                       The effects of 0~0 development on n~o~ndenning                         the apparently stable Beaufort Sea ~p~o~o~-~u~4qV~w-~r~-~o~f
                                segments 'of polar bear populations are not well known.                    ~appr~oxi~n~ta~t~el~l~r 2~.000 polar beefs. such exclusion ~a~nd decline
                                These segments of the population generally inhabit the                     in natality would likely not offset the Species' overall
                                pack ice throughout the year. although in the ~ta~g a number                 survival. so long as s~i~n~f~lar intensive developments ~d~id not
                                of animals, P~q-~q* family groups composed of females                          occur along the entire northern coast o~f Alaska and                                                                      ~J~c~)~int Industry                       Alask
                                and Juveniles. ~a~r~t seen along the coast (Amstrup and                       Canada. Biologists bellows that the Beaufort See
                                others, ~19~8~5~). Potential adverse ~g~i~f~f~e~d~s ~1~0 bears inhabiting               p~*pu~t~@~O~qm can sustain lift, ~N any. Increase In mortality of                                                                                                  Car~ib~qo~qt
                                pack ice could be caused by ~0~op~ing ~fr~a~qf~qt and ~i~ts                           females because population ~s~u~m~o~t~h~s ~a~nd calculations show
                                co~n~com~i~l~l~an~t disturbance of water and ice or from an                       that the number of animals dying each year Is                                                                                                             28~-30 0
                                accidental o~i~l ~31~3~01 from a ship or loading facility.                      appr~oxI~m~a~r~te~ly equal to the population increase from
                                Disturbance alone may no~t greatly affect nond~enn~in~g bear                   reproduction (A~r~nstrup and others, ~I~qM).
                                ~Oi~n~t~c~l ~0~1~1~9cl~s of ON contamination are not well known.
                                ~f~t~ti~al results of a study conducted in Canada (Hurst and                   SEALS AND WHALES
                                Others. ~1~982) indicate that bears forced ~t~o enter an ~ol~l stick                    ~O~t~d~av~e~l~opm~e~n~t activities with the greatest potential
                                and then subjected to cold ~ternp~r~i~ia~ture~s and wind win do:                 for affecting aegis end whales would be those occurring
                                that study did not determine if polar beefs will voluntarily               along the Immediate coast or just offshore. Under ~ha~l
                                enter an o~i~l slick

                                ~i~i~S ARCTIC REFUGE RESOURCE ASSESSMENT

                                                                                                                                         2

                                                                                                       between  controls as well as.test  (exposure) areas both before

                                                                                                       and after development. Finally,    the study design would

                                                                                                       encourage  identification and  measurement of exogenous
                INTRODUCTION                                                                           environmental influences such   as snow characteristics, plant

                                                                                                       phenology or seasonal flooding which may, independently of the
                          The ideal experimental design to test w  .hether calving                     previously mentioned vari Iables, affect the distribution of and
                and post-calving cow/calf groups avoid TAPS and are displaced                          habitat use by caribou between two apparently similar areas.
                by oil developments in the Prudh Ioe Bay are.a is not available to                     Such measurements would help account for variations in use or
                US. Such a design would have as its basic elements comparable
                                                                                                       density which might occur even where exhaustive attempts were
                pre-development baseline data for controllareas and areas which
                                                                                                       made to standardize the experiment based on the criteria I have
                would subsequently be perturbed. Comparable techniques would                           previously mentioned.
                be used to measure changes of various. ecological variables in
                control and exposure areas before and foilowing   .perturbation.                                 The lack of many of the foregoing elements has
                The experimental design would be careful to ensure that                                contributed to differing interpretations on the relationship
                comparisons are valid and would eliminate biases owing to
                                                                                                       between caribou distributions and North Slope petroleum
                either environmental variables or to the changing seasonal
                                                                                                       developments, especially as it pertains to calving
                behaviors and distributions of caribou.   The des .igns would                          distributions and the percentage calves associated with the
                endeavor to eliminate biases associated with the highly clumped                        TAPS corridor.   These differing interpretations, in turn, have
                or non-homogeneous distr .ibutions of caribou which characterize                       generated.controversy  which has often obscured rather than
                the species by recognizing the implications of differing                               clarified issues.   However, despite deficiencies in many of the
                densities, grouping behaviour, sexual segregation. and
                                                                                                       data requirements I have described, there are numerous bodies
                differential habitat use to the analysis.   Surveys would be                           of evidence which.  canIobjectively focus on questions of caribou
                conducted during comparable time and life cycle periods to                             interaction with the TAPS corridor and the implication of that
                .reduce the foregoing potential biases.  The foregoing would                           interaction.  These data-accumulated over a period of the past
               ..ensure that data were comparable for the test and control areas                       16 years, provide a basis for in  Iterpreting the relative role of
              ..within years, so that between-year comparisons could be made                           ecological factors and disturbance in governing the

                                                        3                                                                                                 4
                    distribution, movements and habitat use of Central Arctic                                         the conclusions pertaining to the oilfield presented by           Smith
                    caribou.    In this paper I can only develop and substantiate                                     and Cameron (1983) and Whitten and Cameron (1985).           Figure 1
                    some important principles: I do not intend to review and ,                                        shows the study area and the TAPS corridor.
                    debate the minutiae of 15 years of survey data but to point           out
                    some of the most significant findings which encompass the                                                     The major conclusions of Cameron and Whitten (1980-)
                    period prior to and following development of'the TAPS corridor.                                   and Cameron et al. (1979) are that cow/calf groups avoid the
                                                                                                                      TAPS corridor during calving and the summer period based on a
                                Specific data for the area are available for the                                      comparison of calf percentages along the corridor versus
                                                                                                                      regionally. The major conclusion of Smith and Cameron (1983)
                    period before extensive oilfield development, the construction
                    of the Dalton Highway in 1974, or the pipeline between 1975 and                                   and Whitten and Cameron,(1985) is that calving caribou have
                    1977.   The main sources of'pre-development data are studies by                                   been displaced from the Prudhoe Bay Oilfield.         This conclu  . sion
                    Angus Gavin from,1969 to 1978 (Gavin 1977;         Gavin and                                      is based on low densities of calving caribou in the field and a
                    Chamberlain 1979), White et al. (1975). and Child (1973).                                         lower calf percentage of total caribou in the field versus the
                    Post-development data are derived from a wide range of ADF&G                                      regional percentage.

                    and industry sponsored studies from 1975 to the present.
                                                                                                                                  The problem of comparability of datqt is a major

                                                                                                                      limitation to the conclusions drawn by Cameron and Whitten
                    METHODOLOGICAL PROBLEMS:      UNEQUAL COMPARISONS                                                 (1980-), Cameron et al. (1979, 1985).        In the latter final

                                                                                                                      report, comparisons of calf percentages between regional and
                               one of the major difficulties in any analysis of                                       corridor values during the calving period (June) are available
                    Central Arctic caribou and development interactions is                                            for only two years (1975-76) of the seven-year study (1975-
                    separating out the relative influence on caribou of the                                           1982).  other seasonal periods were compared but they,combined
                    pipeline, the Dalton Highway and the oilfield development.                                        periods in which seasonal distributions are known to vary
                    Although this paper deals with the TAPS corridor, it cannot                                       considerably and frequently in response to environmental
                    ignore pre-construction calving distributions as they relate to                                   factors.   Thus, comparisons of short yearling percentages in
                    Prudhoe Bay and TAPS.     Therefore I must comment, in part, on                                   April/May between the TAPS corridor and regional values does

    					BEAUFORT SEA

    Figure 1.   The study area.

    								6

    not take into account sexual segregation (Figure 2) and

    differential habitat use by the sexes at that time (Figure 3),

    while comparisons for the July-August period are confounded by

    the extreme flux in movements in response to insects which can

    affect calf percentages in a specific area drastically even on

    a given day (White et al. 1978).  Even so, calf percentages

    along the corridor and regionally were the same in two of five

    years for the July-August period (Cameron et al. 1985),

    suggesting that factors other than the TAPS corridor influenced

    those percentages.

    	Although Cameron et al. (1985) attempt to reduce

    previos biases in survey coverage of non-riparian habitats

    regionally by deleting road surveys south of Region 4 and

    coastal transects from aerial surveys, regional surveys still

    appear to oversample non-riparian habitats.  The published

    methodology (Cameron and Whitten 1979) states a deliberate

    effort to sample non-riparian habitats on regional survey for

    at least 3 km on either side of riparian habitats.  Thus, many

    high density non-riparian calving areas are sampled in the

    regional surveys (Figure 4) and compared to the 1 km wide

    surveys on either side of the Dalton Highway which is closely

    associated with riparian habitat of the Sagavanirktok River

    (Figure 5).  The route of TAPS does not transect such calving

    concentrations and traverses approximately three times the

    regional percentage of riparian habitat (Carruthers et al.

    1984).

                                                                  7

                                                                                                                                                                               see

                                       ISO-

                                   U)
                                   4% 100                                                                                                       X

                                                                                                                                                                                                                       44      440
                                                                                0                                                                                                                             17,              22
                                                                                                                                                                                                    to
                                                                                                                                                                                                            34
                                   LU
                                   z   so                                                                                                      U
                                                                                                                                               z

                                                                                                                                                            1H

                                        0-                                                                                                                  31S                                             So
                                                LA41!        CALVING        AWI ST            RUT
                                              WINTER                       DISPERSAL
                                                      SPRING          POST         PRE-RUT
                                                                    CALVING                                                                           - - - - - - -
                                                                                                                                                                                                                             221
                                                                                                                                                                      302                                  163
                                                                                                                                                                                                                    at
                                          n= 590       332     577    1065 1043       609     1164

                                                                                                                                                                           .0.1. W."                       9-1.6 Poor-COLT.0 "t-OUT
                                                                                                                                                                     To                            Mts               10        To
                                                251     28     522    506     422    445      $42                                                                                                                  A..$*       RUT

                     Figure 2.' Seasonal variation in average distance to coast for
                                     male and female caribou groups within the study area
                                     (1981-1983).

                                                                                                                                           Figure 3.       Seasonal variation in median distance to riparian
                                                                                                                                                           habitat (km) of male and female caribou-for four
                                                                                                                                                           subregions of the study area (1981-1983).
                                                                                                                                                           *Asterisk denotes that median distance is signifi-
                                                                                                                                                            cantly different than expected-based on a random
                                                                                                                                                            distribution. p

                                                                                                                  0    20    40km
                                                9                                                                                                                rs @, `D..
                                                                                                                                                                      REA
                                                                                                                        TRANS-ALASKA
                                                                                                                        PIPELINE                                   ALASKA
                                              BEAUFORT SEA

                                                                                                                                               PRUDHOE
                                                                                                                                                BAY
                                                                   %

                                         %

                                           %    0,                                                                                             BLUFF
                                                                                                                                                                     NT
                                                                                                                                                                   a@gw
                                               ell

                                                                                                                                 HILL'

                                                                                                                                 Al. F*
                                                                                                                                          3-

                      0    30  40 Wiii      oowwih
                                                                  BFkOO\1

                            AsOvE GROUND PIPE         CONSISTENTLY- USED
                                                        CALVING AREA                                                                                     SEDGE-MEADOW
                            8URI[D PIPE
                                                                                                                                                         T
                                                      OUTSIDE 9OUNDARY OF  FALAS A                                                                        USSOCK-MEADOW
                            DALTON HIGHWAY            ALL CONCENTRAT8en
                                                      AREAS                                                                                              MAT-CUSHION
                            SURVEY AREA BOUNDARY                                                                                                    ED RIPARIAN

                  Figure 4.    Location of calving concentration areas, 1981-1906.
                               lArea of concentrated calving in 4 of 6 years from
                               1981-1986 (between Canning and Colville Rivers) and
                               in 2 of 3 years from 1984-1986 (west of Colville                             Figure 5. Generalized habitat types within the study area.
                               and east of Canning River only).
                               2This boundary e-ncompasses all concentration areas
                                                                                                                                                              @
                                                                                                                                                                     AREA

                                                                                                                                                                    A KA

                               recorded from 1981-1986.

                                                                                                                                                                                                                                                  tn              D. W f@
                                                                                                                                                                                                                                                  o    z          0   M            10   1010       1010        %D @0      1010       M                        a,
                                                                                                                                                                                                                                                  a    0          0 0 V            'i   'i 'i      _j _j           'i     'i 'i      a,                       Ur
                                                                                                                                                                                                                                                  W               C   0            a)   '1 0%      @.n Al          fIj    -0
                                                         I do not disagree that                            calf percentages are lower                                                                                                             0    0, C.      In 0                                                                                        M
                                                                                                                                                                                                                                                  M    ap @@      -1 9,                                 -                                             0
                                                                                                                                                                                                                                                       rt 0       W 10             W    W W        _j 0        9-         CD M                        0
                                    along the TAPS corridor than for                                        the region as                 a whole but               with                                                                                          MW 0 99
                                                                                                                                                                                                                                                                  M X M            -    tj W       ;D '0       W ;J       O'M        Or'
                                                                                                                                                                                                                                                  Q    no         MI  rfi          -1   00         00          00         00)        X
                                    the interpretation of why they are lower. There is                                                                                                                                                            0V              00  M            0    00         00          P a        0 CD       0
                                                                                                                                                                                                                                                  <
                                                                                                                                                                                                                                                                                                                                                      M
                                                                                                                                                                                                                                                  n               :1 to r,                                                   kn      0                1
                                    considerable evidence that:                                                                                                                                                                                        ou M .     @ :X                                                                                n
                                                                                                                                                                                                                                                  a,   Cr M D* C M                 A         .4    'ob 'M          4.        ",0
                                                                                                                                                                                                                                                  D               up @Q r%         OD   o Ln       o q         o o        o 6,
                                                                                                                                                                                                                                                                  M 0)                  00         00.         00         0 W        M                :1      M
                                                                                                                                                                                                                                                                  0   11                                                             to
                                                                                                                                                                                                                                                  0    M          M M A
                                    1.      The Prudhoe Bay area was not an important calving area even                                                                                                                                           V    X          :3 'D 0)                                                                 Vn         to      0
                                                                                                                                                                                                                                                  M    n          -                                                                  0 M
                                                                                                                                                                                                                                                  9    m 1<       0                                                          0       0
                                            prior to development (Table 1;                                        White et al. 1975;                           Gavin                                                                              or   10 a       z                0    @j .9-     M -i        CD j       0% j       X                M
                                                                                                                                                                                                                                                  M    rt V           0                                                              M     0 M        Qa      V
                                                                                                                                                                                                                                                  %                                                                                        ow         -       0
                                                                                                                                                                                                                                                                                                                                           W          0       r
                                            1977; Gavin and Chamberlain 1979) (Figure 6).                                                                                                                                                         W    0          0n  r,                           W W         to            Un      -                ?
                                                                                                                                                                                                                                                                                                                                     1* *<
                                                                                                                                                                                                                                                                                   %V   01 0_0         ZI.     Z" W       '0'-       = M                      0
                                                                                                                                                                                                                                                                                   _j   00         00          0 %A       0%0        10                       10
                                                                                                                                                                                                                                                       %go 0          En           0    00         00          0 0        0 W        M                        r.
                                    2.      There is well                 documented              evidence that sexual segregation                                                                                                                %D   OD 0           to
                                                                                                                                                                                                                                                  @j              M
                                                                                                                                                                                                                                                                  <                                                                                   0
                                                                                                                                                                                                                                                                  m   04)                    w                            L In       C_               C
                                            (Cameron and Whitten 1979; Carruthers et al. 1984) and                                                                                                                                                                                 0    0 L@       00          00         0 CD       -                0       D
                                                                                                                                                                                                                                                                                        00         0 0         0 0        0          U,
                                                                                                                                                                                                                                                                                                                                                      (n
                                            differential habitat use                              result in different distributions                                                                                                                               n M X
                                                                                                                                                                                                                                                                      c
                                            of cow/calf and bull groups in riparian versus non-riparian                                                                                                                                                           C   X                                                              3                3
                                                                                                                                                                                                                                                                                   OD   00         W 0         4- kn      001
                                                                                                                                                                                                                                                                                   @j   00         00          00         00         al                       :r
                                            habitats (Jakimchuk et al., in press;                                                Curatolo 1985).                                                                                                                  -on              0    00         00          00         0 J@                                cn
                                                                                                                                                                                                                                                                  mal M
                                                                                                                                                                                                                                                                  M                                                                                           0
                                            Indeed, Curatolo found that this differential habitat use                                                                                                                                                             t"M                                                                0                        m
                                                                                                                                                                                                                                                                  0 m 0            W               tj W                              c
                                                                                                                                                                                                                                                                  0                     J@ 10      @j &        4 CD       01 -D@     IE
                                            occurred even                 within intensively developed areas and that                                                                                                                                             V   X                                                              (A               -4      >
                                                                                                                                                                                                                                                                  nm  C
                                                                                                                                                                                                                                                                  0   IU
                                            calf percentages were consistently lower in riparian                                                                                                                                                                  9                                                                                   V       to
                                                                                                                                                                                                                                                                                                                                                      0       @X
                                                                                                                                                                                                                                                                                                                                                      M
                                            habitat.             Jakimchuk et al. (in press) show that differing                                                                                                                                                  V0  N                 -N         W %Q        ID LA.     -j j       <
                                                                                                                                                                                                                                                                                                                                     M                M
                                                                                                                                                                                                                                                                  n   V
                                                                                                                                                                                                                                                                  0
                                            distance relationships to riparian habitats between bulls
                                                                                                                                                                                                                                                                                                                                                              0
                                                                                                                                                                                                                                                                                   V`   -i         ab tj       W 0%       4 @j       0 "0 0
                                            and cows are consistent regional distributional trend.                                                                                                                                                                                 tj   %D         CD @J       CD W       -t-        9 M W            M

                                                                                                                                                                                                                                                                      CL                                                                   0 M                Cr
                                                                                                                                                                                                                                                                                                                                           0 0

                                                                                                                                                                                                                                                                                                   I- OD 0 4-             @j Go      3
                                                                                                                                                                                                                                                                      0

                                    3.. Finally, along the West Sak Road, where habitats normally
                                            used by cows and calves have been traversed by a road                                                                                                                                                                                                                                                     En
                                                                                                                                                                                                                                                                      0
                                            corridor, thus eliminating the habitat bias to a large                                                                                                                                                                                                                                                    z

                                            degree. summer calf percentages have been the same or                                                                                                                                                                                                                                    0
                                                                                                                                                                                                                                                                                   Ln W W 4 Ln
                                                                                                                                                                                                                                                                                   J CD UD 4@                  tJ @J 0 ID            M

    					BEAUFORT SEA

    	Figure 6.  Major calving areas of Central Arctic caribou in 3
    of 4 yers (1970-1973 inclusive).  Dotted line
    denotes calving in at least one of four years  (After
    Gavin 1977).

    						14

    virtually the same as regional values in five of seven

    years following the development of the corridor (Table 2).

    	Notwithstanding Table 2, which eliminates a major

    habitat bias, calf percentages alone are a poor measure of

    impact along the TAPS corridor when one considers seasonal

    variations in caribou distribution in response to environmental

    influences such as snow cover, insect harassment, and

    differential habitat use by the sexes.

    	The major evidence presented that calving has been

    displaced from the Prudhoe Bay area are the low calf

    percentages recorded, the low number of calving groups found

    these during summer and the higher incidence of calving south

    of Prudhoe Bay (Whitten and Cameron 1983;  Smith and Cameron

    1983).  However, comparison of pre- and post-development

    calving distributions shows a similar distribution to that

    found in recent years (Sopuck and Jakimchuk 1986), with more

    calving south of Prudhoe Bay than in the Prudhoe Bay oilfield

    area even prior to extensive development (Figures 4 and 6).

    The apparent reason for this is the frequent, extensive

    flooding associated with sedge meadows in the Prudhoe Bay area.

    Late snow melt and flooding of lowland habitates in the coastal

    zone at calving has occured in 7 of the past 13 years where

    data are available (Table 3).  In years of delayed snow melt,

    calving farther inland has been consistently reported.  This

                                                                                                                                                        16

                                                                                                                     Table  3. pheonology of snowmelt and calving distributions in
                   Table 2.   A comparison of regional calf percentages and calf                                                 the central Arctic region, 1970-1986.
                              percentages observed along the West Sak (Spine) Road
                              during summer 1976-1984.
                                                                                                                            Snowmelt                 Comments on
                                                                                                                            Phenology                Calving
                             Spine Road           Regional                                                           Year   DurinQ Calvin2           Distribution              Source
                             (West Sak)      Calf Percentages                                                        t970   No data                  "Usual distribution"      Gavin  1977
                   Year   Percent Calves      Percent Calves             Source                                                                      (see Fig. 6)
                                                                                                                     t971   Deep snow coastal        Calving in foothills      Gavin  1977
                                                                                                                            plain
                                                                                                                     1972   Heavy snow               Low use of Coastal        Gavin  1977
                   1976         26                  25          Cameron  & Whitten 1979b                                                             Zone & Prudhoe Say
                                                                                                                     1973   Dry year                 Some inland calving       Gavin  1977
                   1979         25.0                25          Cameron  & Whitten 1980b                             1974   No data                  "Usual distribution"      Gavin  1977
                                                                                                                                                     (Fig. 6)
                   1980         20.0                21          Cameron  et al. 1981                                 1975   No data                  scattered calving. no
                                                                                                                                                     concentration areas
                   1981         18.0ab              27          Cameron  et al. 1983                                 1976   Heavy snow               "Usual distribution"      Gavin 1977
                                                                                                                                                     (Fig. 6)
                   1982         16.0            No  Data        Smith et al. 1984                                    1977                            "Usual distribution" Gavin 1977
                                                                                                                                                     (Fig. 6)
                   1983         17.5                2t          Smith et al. 1984                                    1978   Late snowmelt,
                                                                                                                            flooding
                   L964         22.3                23.2        Smith et al. 1984                                    1979   Dry - relatively         No data                   Cameron  et al.
                                                                                                                            snow-free                                          1981
                   aRepresents 14.966 total      caribou  seen  from the road in    1981                             1960   Late Snowmelt -          More inland caribou       Whitten  &
                    versus 4,552 seen in 1980.                                                                              extensive flooding                                 Cameron  1985
                                                                                                                     t9e,   Dry, snow-free           Little inland             Cameron  et al.
                   bof caribou observed crossing West Sak road and Kuparuk                                                  calving                                            L983
                    pipeline in 1981, calves were 25S of total caribou.                                              1982   Late snowmelt -          More calving              Whitten
                                                                                                                            extensive flooding       inland                    Cameron  1985
                                                                                                                     1983   Relatively dry           Usual (see Fig. 6)
                                                                                                                     1984   Relatively dry          'Usual (Fig. 6)            Sopuck &
                                                                                                                                                                               Jakimchuk 1986
                                                                                                                     1985   Relatively dry           Usual                     Sopuck &
                                                                                                                                                                               Jakimchuk 1986
                                                                                                                     1986   Late snowmelt            majority inland           Sopuck &
                                                                                                                                                     calving east of           Jakimchuk 19136
                                                                                                                                                     Sag River.

                                                    17

                  seems to be a reasonable explanation for      the consistent calving
                                                                                                                 low use for calving represents an,historical distribution
                  associated with the Franklin Bluffs area      south. of Prudhoe.Day
                  whtch,was documented prior to extensive oilfield devel      .opment at                         rather than a displaceme  Int of calving to other areas.

                  Prudhoe Bay.
                                                                                                                            I do not disagree that cows with neonates are
                              If we look at factors affecting pre- and post-                                     sensitive to disturbance.     There is ample evidence to support
                                                                                                                 this sensitivity not only for caribou but for other cervids and
                  calving distributions we find strong well-documented-ecological
                  reasons to explain observed distributions. when we test these                                  bovids as well. This sensitivity appears to be strongly
                                                                                                                 associated with a behavioral repertoire in response to
                  hypotheses by looking at known calving and post-calving areas
                                                                                                                 predation. I do not disagree, either, that developments         such
                  where development has occurred, such as the West Sak Road area
                  and Prudhoe Say, we find that the hypotheses pertaining        .to                             as road .9 with traffic and human activity,   .are disturbing   to
                                                                                                                 cows with calves, or that some types of barriers can physically
                  habitat use and their effects on distribution hold (Curatolo
                  1985;   Jakimchuk et al.. in press,     this paper).    The                                    exclude caribou from their ranges.      I do, however, distinguish
                  explanations for.apparent discrepancies between what occurs                                    hetween the  sensory disturbances associa   .ted with the Dalton   .
                                                                                                                 Highway which have been documented* and the notion of avoidance
                  along the TAPS corridor and regionally are in response to
                                                                                                                 or displacement along the TAPS corridor which implies       a
                  ecological factors.    This explains the apparerrt contradiction
                  of avoidance   of TAPS but no avoidance of the Sp   .ine Road d uring                          permanency that  is not justified by the evidence.       I  feel that
                                                                                                                 the pipeline itself is not a source of disturbance -        most of it
                  summer by the same caribou on the same summer range.
                                                                                                                 is buried in the Sag. River floodplain. Most of the         existing
                             I have concluded that absence does not equal                                        disturbance comes from the traffic and hu    .nting along   the Dalton
                  displacement.    I do not think that cow/calf groups avoid TAPS                                Highway.   But even here, except for   Ihunting mortality, I feel
                                                                                                                 that the disturbances are temporary and are not Instrumental in
                  but the major river valley associated with TAPS - a
                                                                                                                 altering either the behavior or distribution of caribou along
                  relationship which also holds regionally for other comparable
                                                                                                                 that corridor in any fundamental or permanent way. In short, I
                  major rivers such as the Canning and Colville. Similarly, I
                  think the evidence is strong that the Prudhoe Bay complex prior                                think that caribou are frequently disturbed by activity wi      .thin
                  to development was not an important calving area.        Its present                           the corridor but they do not avoid itfor this reason.

                                                 19
                           Evidence suggesting that disturbances to date are                              @xists between a viable caribou population and development, to
                 temporary and sensory in nature is available from a broader                              locument where development activities are incompatible, to
                 review of the growth.- distribution and movements of the Central                         identify the nature of the problem, and to develop m   eans of
                 Arctic herd (previous papers). There is no indicatio   In that                           effective initigation.

                 there has been any change in distribution, life cycle patterns

                 or the fundamental ecology of caribou resulting from   the

                 interaction with existinq oil development. On the contrary,

                 the herd has grown in size and has continued to use and occupy

                 habitats in the region in a manner consistent with

                 pre-development use. The best evidence for this is where pre-

                 development baseline data exist, such as the Kuparuk and Milne

                 Point developments. There are no overall effects on seasonal
       0
                 distribution, habitat use or numbers which can currently be

        A        attributed to petroleum development. The seasonal cycles of

                 caribou in the Central Arctic region continue despite the

                 development which only recently includes their-major pre-

                 development calving ranges.

                           As development continues and expands, it is important

                 to monitor and document interactions with caribou and to assess

                 their significance. If decisions are taken that any habitat

                 alteration is deleterious and this forms the basis for

                 permitting, it will be difficult to justify management oriented

                 research because of the a priori conclusion that all changes

                 are equally deletrious. The most important requirement for

                 future research, in my view, is to identify where compatibility

                                                    21
                                                                                                                                                     22

                 LITERATURE CITED
                                                                                                                  Child, K.N.    t973.   The react,ions of barren-ground      caribou
                 Cameron, R.D. and K.R.     Whitten.   1979a. Seasonal movemen    .t.s and                              (Ra:gi:::,tarandus granti) to simulated pipeline and pipe7
                       sexual segregation-of caribou determined by.aerial survey.                                       tin c       ing stru tures at Prudhoe.Bay, Alaska.        AlasI ka
                       J. Wildl. Manage. 43:626-633.                                                                    Coop. Wildl. Res. Un   .it, Univ. o .f Alaska, Fairba .nks.
                                                                                                                        45 pp.
                 Cameron, R.D. and K.R.     whitten.L979b.    Distribution and move-
                       ments of caribou    in relation to the Kuparuk Development                                 Curatolo, J.A.     1985.. Sexual segregation and haitat use by          the
                       Area.   First Int  erim Rep., Alask a Dep. Fish & Game,                                          central Arctic caribou herd during summer.        Pp. 193-198 in
                       Fairbanks.    32 pp.                                                                             T.C. Meredith and A.M. Martell, eds.       Caribou Management.
                                                                                                                        Census Techniques, Status in Eastern Canada. Proceedings
                 Cameron, R.D. and K.R. Whitten.       1980a.    Influ.ence of the                                      Second N. Am. Caribou Workshop, Val Morin, Ouebec.          17-20
                       Trans-Alaska Pipeline corridor on the local distribution                                         Octob.er 1984. McGill Subarctic Re.    search Paper No. 40.
                       of caribou. Pp. 475-484 in E. Reimers, E. Gaare and S..
                       Skjenneberg, eds.     ProceeTi-ngs of the Second International                             Gavin, A., 1977. Caribou migrations and patterns, Prudhoe Bay
                       Reindeer,'Caribou.Symposiu. R16ros, Norway.       Direktoratet                                   Region, Alaska's North Slope, 1969-1977@        Prep. for
                       for vilt og ferskvannsfisk, Trondheim. 799 pp.                                                   Atlantic Richfield C   .ompany. 57 pp.
                 Cameron,   R.D* and K.R. Whitten.     1980b.   Distribution and                                  Gavin, A. and D.W.,Chamberlain.       1979. Caribou migration and
                       movements of caribou in-relation to the-Kuparuk Develop-                                         population patterns in the-Prudhoe Bay region of Alaska's'
                       ment Area. Second Interim Rep., Alaska Dep. Fish & Game,                                         North Slope, 1969-1978.     Unpubl. Rep. prep. for ARCO
                       Fairbanks.    35 pp.                                                                             Alaska, Inc.    4 5 pp.@
                 Cameron, R.D.,   K.R. Whitten and    W.T. Smith.    1981.  Distri- .                             Jakimchuk, R.D., S.H. Ferguson and L.G. Sopuck.         In press.
                       bution and movements of caribou in relation to the Kuparuk                                       Differential habitat use and sexual segregation in the
                       Development Area. Third Interim Rep., Alaska.Dep. Fish                                           Central Arctic caribou herd.      Accepted by.Can.. J. Zool.,
                       Ga5e. Fairbanks. 37 pp.                                                                          Sept. 1968.
                 Cameron, R.D., K.R. Whitten and W.T.      Smith.   1983.    Responses                            Sopuck, L.G. and R.D. Jakimchuk.       1986. Caribou monitoring
                       of caribou to petroleum-relaied     development on Alaska's                                      studies in the.Central Arctic Region of Alaska, Final
                       Arctic Slope.    Alaska Dep. Fish   & Game, Fed. Aid in wildl.                                   Report.   Prepared by Renewable Resources Consulting
                       Restor., Progr. Rep.. Proj. W-21-2, Job 3.18R.         74 pp.                                    Services Ltd. for Alyeska Pipeline Service Company, ARCO
                                                                                                                        Alaska, Inc., Exxon Company, U.S.A., Standard Alaska
                 Cameron, R.D., K.R. Whitten and W.T.      Smith.   1985. Effects of                                    Production Company,.and BP Alaska Exploration, Inc.
                      .the Trans-Alaska Pipeline on the distribution and move-
                       ments of caribou.    Alaska Dep. Fish & Game. Fed. Aid in.                                 Smith, W.T. and R.D. Cameron.      1983.   Responses of caribou to
                       Wildl. Restor., Final Rep., Proj. W-17-7 through 11,                                             industrial development an Alaska's Arctic Slope. Act&
                       W@21-1 through 12, W22-1-4. Job. 3.18R.         24 pp.                                           Zool. Fennica 175:43-45.
                 Cameron, R.D., K.R. Whitten, W.T. Smith and D.D. Roby.           1979.                           Smith, W.T., R.D. Cameron and K.R. Whitten.         1084.   Distri-
                       Caribou distribution and group composition associated with                                       bution and movements of caribou in relation to the Kuparuk
                       construction of the Trans-Alaska Pipeline. Can. Field-                                           Development Area.    Alaska Dep. Fish & Game, Juneau.        Prog.
                       Nat. 93(2)sISS-162.                                                                              Rep., Fed. Aid in Wildl. Restor.. Proj. W-22-2, Job 3.30R.
                                                                                                                        17 pp-
                 Carruthers, D.R., R.D. Jakimchuk and      S. Ferguson. 1984. The
                       relationship between the Central Arctic caribou herd and                                   White, R.G.., B.R. Thomson, T. Skogland, S.J. Pearson, D.E.
                       the Trans-Alaska Pipeline.      Prep. by Renewable Resources                                     Russell, D.F. Holleman and J.R. Luick.        1975.   Ecology of
                       Consulting Services Ltd. for Alyeska Pipeline Service                                            caribou at,Prudhoe Bay, Alaska.      Pp. 151-212 in J. Brown,
                       Company, Anchorage. 207 pp.                                                                      ed. Ecological Investigations of the Tundra Brome in the
                                                                                                                        Prudhoe Say Region, Alaska. Biol. Paper, Univ. of Alaska.
                                                                                                                        Spec. Rep. No. 2.

                                                    23
                  Whitten, K.R. and R.D. Cameron.      1983.  Population dynamics of
                        the Central Arctic herd, 1975-1981. Acta Zool. Fennica
                        175.159-161.

                  Whitten, K.R. and   R.D. Cameron. 1985. Distribution of       caribou
                        calving in relation to the Prudhoe Bay oil field.       Pp. 35-
                        39 in A. Martell and D..Russell, eds. Proceedings       First
                        N. Wm-er. Caribou workshop,  Whitehorse, 1983. Can.     Wildl.
                        Serv. Spec.  Publ., Ottawa.   68 Pp

    Resource Development Council
      for Alaska, Inc.
    											_ _ _ "G" Street, Suite _ _ _, Anchorage, Alaska _ _ _ _ _-_ _ _ _
    											Box _ _ _ _ _ _, Anchorage, Alaska _ _ _ _ _-_ _ _ _ - _ _ _/27_ _ _ _

    February 5, 1987

    Secretary Donald Hodel
    Department of the Interior
    Washington DC 20240

    Dear Secretary Hodel:

    The Resource Development Council respectfully submits the
    enclosed comments on the Draft Legislative Environmentl
    Impact Statement for the Arctic National Wildlife Refuge
    Coastal Plain Resource Assessment.

    I have also enclosed resolutions in supoort of the
    preferred alternative from a variety of cities, boroughs
    and other concerned parties for the official record.

    We hope these comment sare of use to you and your staff
    as you rview the document and prepare a final report.
    Please call on me if we can be of assistance in any way.

    Sincerely,

    RESOURCE DEVELOPMENT COUNCIL
    for Alaska, Inc.

    Paula P. Easley
    Executive Director

    cc:  	Governor Steve Cowper
         	Senator Ted Stevens
    	Senator Frank Murkowski
    	Congressman Dony Young
    	Vern Wiggins, Alaska Land Use Council
    	Representative Sam Cotten, Alaska Legislature
    	Senatore Jack Coghill, Alaska Legislature
    	Janie Leask, Alaska Federation of Natives
    	Alaska Coalition for American Energy Security

    Resoure Development Council
    for Alaska, Inc.
    										_ _ _ "G" Street, Suite _ _ _, Anchorage, Alaska _ _ _ _ _- _ _ _ _
    										Box _ _ _ _ _ _, Anchorage, Alaska _ _ _ _ _-_ _ _ _ - _ _ _/_ _ _-_ _ _ _

    				Comments of Resource Development Council, Inc.,
    			of the Draft Arctic National Wildlife Refuge, Alaska,
    					Coastal Plan Resources Assessment

    						February 4, 1987

    						INTRODUCTION:

    	The Resource Development Council for Alaska, Inc.,

    (RDC) is a private statewide economic development

    organization committed to the orderly development of

    Alaska's resources.  The broadly-based membership of our

    Council comes from a wide range of economic, social,

    geographic and ethnic sectors of Alaska.  Our membership

    respresents individuals, companies, trade associations,

    native corporations, universities, chambers of commerce

    and municipalties throughout the state.

    	The Resource Development Council strongly supports

    the opening of the Coastal Plain of the Arctic National

    Wildlife Refuge to oil and gas exploration and

    development.  In light of the national interest,

    Alternative A, full leasing of the "1002" study area, is

    the only acceptable alternative.

    Public Comment

    	Although there has been some concern over whether or

    not public comment was required for preparation of the

                 Page 2                                                                                              Page
                 RUC ANWR Comments                                                                                   RDC A14WR  Commeiits

                                                                                                                     Uarrels  per day unless new domestic discoveries are found and
                 report, HUC believes, especially in light of the time extension
                                                                                                                     developed.    If new significant.discoveries are not developed, the
                 for written comments, the level of public participation in the
                                                                                                                     U.S. could find itself dependent upon'foreign sources for 75
                 review of the draft report has been adequate and fully meets all
                                                                                                                     percent of Its consumption within 15 years, double our present
                 legal requirements. RDC also believes that the public hearings
                                                                                                                     level of dependency. 'Since it takes up to 15 years to bring
                 in Anchorage, Kaktovik and Washington, D.C. were well
                                                                                                                     major Arctic oil fields into production, the immediate opening of
                 'publicized.    Because of the advanced notification, large numbers
                                                                                                                     the ANWR Coastal Plain for exploration and development is of
                 of people attended the     hearings.
                                                                                                                     extreme   Importance.

                 The National   Interest.                                                                                  With the free world's     .sources  of petroleum heavily

                                                                                                                     concentrated in the volatile Middle Cast, increased future
                      There are many good     *reasons why  the opening of eight percent
                                                                                                                     dependency on this region threatens our national Interest.              Saudi
                 of the refuge to oil    and  gas leasing   Is.In  the national Interest.
                                                                                                                     Arabia Itself holds about one-quarter of the world's reserves.

                                                                                                                     Nearly three-quarters of all reserves are found in the Middle
                      Development    of world-blase oil    deposits in the refuge
                                                                                                                     East. a region,of great instability. Given past experience, the
                 proposed for leasing would     promote economic development, reduce                                 U.S. is very vulnerable to supply disruptions          and subsequent
                 our dependence on foreign olL, foster orderly development In the
                                                                                                                     price escalation    due to   Its dependence on foreign sources of
                 absence of an energy crisis. increase revenues.from          taxed and                              oil.
                 royalties. strengthen national security, restrain the national
                 trade deficit   and create thousands of new jobs.                                                        This beat way   to assure    the t the United States will have

                                                                                                                     secure supplies of    oil is to   pursue   exploration and development
                      Although there Isplenty of oil on the         market today,                                    here at home.     And  the beat chance    to find a new world-class
                 domestic crudereserves are p      lummeting while consumption to
                                                                                                                     domestic  supply of   oil is in,   the Coastal Plain of ANWR.
                 rising.   Domestic crude production from existing fields Is

                 forecast  to decline from 8.9 million barrels per day In 19135 to
                                                                                                                          Many   Americans find it     hard to believe that we have lost the
                 slightly  over.6 million barrels per day in 1991. Current                                           advantages gained In conservation and are rapidly moving            back to
                 domestic  crude production has already fallen by 400,OOU barrels
                                                                                                                     a future of massive energy import dependence.           With the
                 ,per day. By the year 2UUU, production may plunge to 4 million

             Page 4
             RDC ANWR Comments                                                                            Pal"L
                                                                                                          1(DG ANWR (;01111r1Lr1Ls

             drastic drop in oil prices, compounded with Vie fall In domestic                             Economic Benefits
             production and the dramatic rise in consumption, the present oil
             glut will evaporate before the end of this decade. The drop in                                    Development and production of substantial oil reserves in
             oil prices has resulted In significant reductions In U.S.                                    the 1002 area would promote economic development not only in
             exploration, production and drilling activity, and there      is                             Alaska, but also in the contiguous at   ates.   Thousands of new jobs
             little that can be done to reverse this trend.                                               would be created as the demand for goods and services developed.

                                                                                                          Positive impacts would be felt well beyond the energy industry.
                  Until oil prices increase significantly, U.S. exploration
             will remain stagnant. Our dependence on imports will continue to                                  In Alaska, oil production in the refuge would provide a
             increase and our vulnerability to oil price shocks and oil                                   major new source of income to underwrite important state programs
             shortages will rise to excessively dangerous levels.                                         and promote economic growth.    Other States Would also benefit

                                                                                                          since much of the production and transportation facilities would
                  It is important that the U.S. have the foresight to develop                             be designed and constructed prior to being shipped north.
             potential ANWR oil and gas deposits soon to avoid a future energy
             crisis.   All the geologic factors favorable for significant oil                                  Uil and gas development In the 1002 area would also assist
             and gas discoveries exist in the 1002 area, which Is the most                                the nation In reducing the national trade deficit.       The deficit
             promising area for a major discovery of oil and gas in all                                   soared to record levels in November and appears to be to      Itally out
             Untested onshore areas of North America.                                                     of contr ol.  gvery barrel of oil the U.S. buys from foreign

                                                                                                          sources increases that deficit.     The. price that this nation pays
                  It Is particularly important    that Congress allow the siting                          for imported oil is the largest single factor in the deficit.         As
             In ANWH of oil and gas facilities    needed to support offshore oil                          much as $90 billion is spent each year onforeign oil.         With the
             and gas development occurring north of ANWR on state-owned                                   mounting national trade deficit, any improvement in the balance
             submerged lands and on the federal Outer Continental Shelf.        None                      of trade pictur a is beneficial.    Since every state Is partially
             of the alternatives In the report specifically states that                                   responsible for the deficit, each must do its share or more to
             support facilities would be permitted. This provision would       be                         produce resources that can help offset foreign imports.
             compatible with Alternative A, B, C and D, and should be added to

             these alternatives.

                Page 6                                                                                       Page 7
                RUC ANWR Comments                                                                            HDC ANWR Comments

                Oil and Gas Resources                                                                        considerable since many of the plays are stratigraphic in

                                                                                                             nature. In addition, minimum economic field size would decrease
                     Although there are some attractive offshore areas yet to be                             as infrastruture from larger fLelds.is developed.       For example.
                explored, the 1002 area is particularly promising among      onshore                         fields considered less than economically marginal by themselves
                areas because it contains extensions of other producing      trends.                         could come on line later as infrastructure is developed
                With all the geographic factors favorable for significant oil and                            throughout the area to tap larger fields.      Further, price
                .gas discoveries existing In the 1002 area, the Coastal Plain                                fluctuations could have a tremendous impact on the economic
                holds the greatest potential of containing super-gaint oil fields                            viability of any prospect.
                of all unexplored areas of the U.S.

                                                                                                                  The report Indicates that there Is only a 20 percent chance
                     According to the draft report, there is a 95 percent chance                             of finding economically recoverable oil.      This estimate is
                the 1U02 ar .ea contains more than 4.8.billion   barrels of oil.                             misleading to those who are not familiar with industry risk and
                There is a 5 percent chance    the area contains  more than 29.4                             success rdtlos. The 20 percent estimate actually represents a
                billion barrels of oil. Tne average range of      inplace estimates                          considerable Increase over typical industry success ratios and In
                yields a mean estimate of 13.8 billion barrels     of oil. The.                              fact establishes an excellent chance for finding major oil
                report also estimates that there is an average      economically                             deposits.

                recoverable resource estimate of 3.2 billion barrels of oil.

                                                                                                                    According to the Alaska Oil and Gas Association, only one
                     However, the report said that "the estimation of recoverable                            out of ten wells drilled encounters any hydrocarbons at all, and
                resource was limited to those prospects (all structural) which                               of those that do. only one out of five ever turns into a
                can be Identified and delineated with reasonable degree of                                   developable oil field. Out of 100 exploratory wells drilled,
                certainty, and which are physically large enough that they       could                       only ten would encounter oil. of those ten, only two will have
                reasonably be expected to contain commercia    I quantities of   oiL."                       discovered economically developable fields.       This represents a

                                                                                                             two percent chance of success compared to 20      percent. As a
                     Given this criteria, the Resource Uevelopment Council                                   result, 20 percent oads are ten times higher      than the industry's
                believes the report's reserve estimate should represent a                                    success rate in Alaska, a state that provides America with over
                minimum.   Recoverable  oil from strati-graphic traps could be                               20 percent of Its domestic production.

               Page 8                                                                                  Page
               RDC ANWR Comments                                                                       RDC ANWR Comweiits
                    Due to the complex geology of the IOU2 area, drilling will                         of the most-studied ecosystems in Worth America.    This fact
                                                                                                       should be clearly stated In the final report In light of charges
               definitely be required to define, the subsurface values. Drilling
                                                                                                       by non-deveLopment interests that very little study has occurred
               should begin immediately in order to inventory and confirm the
               suspected resources.                                                                    and that much more is needed before .development is allowed.

               North Slope Environment/Experience                                                          The Council strongly concurs with the statement that "most
                                                                                                       adverse effects would be minimized or eliminated through

                                                                                                       carefully applied mitigation, using the lessons learned and
                    The NEPA-mandated EIS process frequentlyforces now
               development projects to predict environmental consequences with                         technology acquired from development at Prudhoe Bay and from
                                                                                                       construction of the Trans-Alaska Pipeline System (TAPS)."
               little or no previous field experience to guide the predictions.

               For the ANWR Coastal Plain, the test case has already occurred
               over an 18-year period at nearby Prudhoe Bay.   The experience of                           It should be pointed out that the worst-case scenarios
                                                                                                       adopted by non-development Interests 15 years ago to prevent
               regulatory agencies combined v .Ith that of industry In the Arctic                      construction of TAPS and development at Prudhoe Bay have been
               environment provides convincing evidence that the 1002 area can
               be developed with minimal environmental impacts.                                        proven false.  Dire predictions pointing to the destruction of
                                                                                                       major caribou herds, waterfowl and loss of habitat have simply
                    The Resource Development Council agrees with the DEIS In                           not occurred. Today healthy caribou herds thrive In the midst    of
               that "the evidence generated during the 18 years of exploration                         development activities. The Central Arctic herd, whose summer
               and development at Prudhoe Bay Indicates minimal Impact on                              range includes Prudhoe Bay and KuparuK oil fields, has not only
                                                                                                       grown, but multiplied in size.
               wildlife resources. Hence, it is reasonable to assume that

               development can proceed on the coastal plain and generate similar
                                                                                                           Most of the high ly-specu Is tive environmental concerns that we
               minimal effects."
                                                                                                       hear today by those opposing development In the 1002 area are
                                                                                                       similar to those aired In the 1976s to discourage construction of
                    Development of Prudhoe Bay has enabled the industry and
               regulatory agencies to spend millions of dollars and hundreds of                        TAPS. The public should recognize that the dire predictions being
               man-years to research the interaction of fish and wildlife with                         made today are unwarranted and in fact have already peen proven
                                                                                                       false through environmentally-sound development at Prudhoe Bay.
               oil field development. As a result, the North Slope Is one

               Page 10                                                                                    Page 11
               RDC ANWR Comments                                                                          HOC ANWR Comments

               DevelopLaent Impacts                                                                            In defining management goals for a herd, a key ingredient Is

                                                                                                          the concept of habitat carrying capacity.     Neither the Central
                     The Resource Development Council believes that the small loss                        Arctic Herd nor the Porcupine Herd approach the carrying capacity
               of habitat represented by development in the 1002 area will not                            of their ranges based on food, calving    habitat, insect relief or
               impact growth or productivity of caribou. Habitat is not currently
                                                                                                          any other habitat basis.    It is an established fact that the total
               preventing the  grow th of the.Porcupine herd since the herd's large                       habitat has never  been fully occupied, and that caribou populations
               population has  remained far below the carrying capacity of the                            have maintained densities much lower than the maximum dictated by
               Coastal Plain. A small reduction in total range should not                                 habitat.
               significantly alter the,herd's population. Given existing
               technology, coupled with the potential size of any anticipated                                  Since habitat is not limiting growth     ample room exists to
               discovery, development In the refuge would comprise an extremely                           accommodate development interests in the 1002 area without
               small portion of the 1002 area, which itself represents only eight                         impacting the size or growth of the Porcupine herd.     This point
               percent of the refuge.                                                                     should be strongly emphasized in the net conclusions of the 1002

                                                                                                          report.
                     Since habitat is not limiting the. continued growth and

               survival of the herd, conclusions within the report regarding
                                                                                                               The report correctly points out in Chapter II that wide     annual
               displacement of maternal cows or bulls carry little significance.                          variations in calving distribution frequently occur due to weather
               As a result, loss of access to small portions of available habitat                         patterns and the timing of spring thaw. The acknowledged effect of
               due to oil field development will have minimal impact on the herd.                         weather erodes the core calving area concept and points out the

                                                                                                          wide annual variability and adaptability of caribou. In 1983 and
                     There has been some degree of displacement of caribou at                             1985, about 74 percent of the Porcupine herd calved in the 1002
               Prudhoe Bay due to habitat alterations.     However, habitat is not                        area.  In 1984, only 35 percent of the herd calved In the area.
               limiting caribou populations for any Alaskan herds.      Therefore, a                      These figures clearly show the adaptability of the.herd to yearly
               small degree of habitat alteration as a result of development on                           variations in weather conditions and point out that calving
               the Coastal Plain will have an insignificant Impact on the growth                          distributions do vary widely. This shows that caribou      have calved
               and productivity of the Porcupine caribou herd.                                            in other places outside the "core calving area" without harm.

               Page 12                                                                                 Page I i
               RDC ANWR Comments                                                                       HUC ANWH Comments

                                                                                                            Skoog (196@)  and Bergerud et. al.   (1984) believe that caribou
                    The "core calving area" for the Porcupine    herd has been
                                                                                                       are not habitat limited.    Shank (1979)  states'that "...northern
               arbitrarily defined as an area where high density calving has
                                                                                                       large mammals (excepting sheep) are most likely    not often resource
               ,occurred for at least 5 of the last 14 years.    High density calving
               has occurred in some of this area in 9 of the 14 years, which                           limited suggesting that at Least some degree of    distributional
               strongly indicates that calving has occurred out   .side the "core                      alteration could be accommodated without drastic demographic
               calving area* anywhere from 5 to 9.years. The facts show that                           consequences."

               caribou calve anywhere on the Coastal Plain, and In large areas
                                                                                                            Given the frequent variability of calving across the Coastal
               outside the plain.
                                                                                                       Plain and the flexibility of caribou In their habitat requirements.
                    What percentage of all calving areas   does  the "core calving                     and the fact that alterations can be accommo   .dated without drastic
                                                                                                       demograhic consequences, the Resource Development Council asks that
               aream represent? According to Table VI-5, the total "core calving
               area" Is 311,000 acres, while total concentrated calving occurs                         conclusions rega .rding the relative Importance of the Jago Highlands
                                                                                                       as a core-calving area be.de-emphasized throughout the report.
               over 2,117,000 acres. This shows that core calving represents 15

               percent of all concentrated calving areas, and would represent an
                                                                                                           .The Resource Development   Council believes that the "unique and
               even lower percentage If peripheral calving areas were included.
                                                                                                       Irreplaceable" nature required for designating habitat as Resource
               While the core area is Important to the herd. It Is not necessarily
                                                                                                       Category I does not pertain to caribou calving habitat as Indicated
               critical since the caribou have successfully calved over very large
               areas In the past.                                                                      in the report.   It has yet to be proved that the Porcupine herd has,
                                                                                                       a specific "core" calving area that is unique and irreplaceable.

                                                                                                       The herd's calving concentrations vary each year, some falling
                    However, It has been assumed that areas outside the."core
               calving area" have reduced habitat values or higher exposure to                         within the same.gerieral areas, while In other years separated by
                                                                                                       hundreds of miles.   Members of the herd calve in a range that
               predators. If this assumption were true, reduced productivity
                                                                                                       spreads over 200 miles in an east-west distance and over an area
               should be apparent from years that the herd calved in alternative
                                                                                                       exceeding 6,500 square miles, larger than the state of
               ranges.    Data show no sign of reduced productivity, but does
                                                                                                       Connecticut. In 1982, the majority of the herd calved east of the
               indicate that the herd has steadily grown since the early 1970s.
                                                                                                       Alaska border in Canada. In 1986, much of the herd calved outside
               The record also has shown that caribou have consistently shown
                                                                                                       the 1002 area. It is indeed   a misconception that a "core" calving
               flexibility In their habitat requirements.

               Page 14
                   ANWR Comments                                                                            Page 15
                                                                                                            RuC ANWR Comments

               area exists as a specific tract   of  land with fixed  boundaries, used                      prohit)ited 'the Central Arctic herd access to    coastal areas. The
               consistently and predictably.                                                                -favorable experience at Prudhoe Bay    should be included In the

                                                                                                            report.
                    The fact that the Porcupine herd has higher calving densities
               than the Central Arctic herd at Prudhoe Bay is not. su    Ifficient to                             On  page  six of the repore, paragraph five states that "changes
               argue that displacement would.likely cause adverse effects. As                               in wildlife habitat   and wilderness environment could Include
               mentLoned.earlier,.alternative calving habitat Is available in                               displacement   and reduction In the size of the Porcupine Caribou
               sufficient quantities..   The large area used by the Porcupine herd                          Herd (PCH).    The amount of reduction and its long-term significance'
               fat calving and Its historical use and    success In that habitat                            for herd viability Is !1JAL!!1X_A&               (Emphasis added)
                                                                                                                                               Sulltive."

               indicate this Is the case.

                                                                                                                  We suggest that many of the environments    .I cdnsequences.are
                    Therefore, any arguments against extrapolation of Central
                                                                                                            overstated and highly speculative-Many of the conclusions of
               Arctic' herd data to the Porcupine herd   ar a not valid when based   on                     severe Impacts.and concerns for caribou     populations, as presented
               the fact that the Porcupine herd may occupy habitat In higher                                in. tt-                                     -in. actualit   they are
                                                                                                                  a report, are state' as fact. when
               densities than the Central Arctic.herd. We ask that this point        be                     highly speculative and not   .supported by  what has taken pI
                                                                                                                                                                           ace at

               clearly made in the conclusion of the environmental      impacts for
                                                                                                            Prudhoe   Bay.
               Alternative A.

                                                                                                                  It Is important to note that    the stan dard used In the 1002
                    In regard to.Insect   relief. caribou demonstratelwide variation                        report is "worst case." 14SPA    as now a mended requires that effects
               in their selection and use of Insect relief habitat. Although many                           be "reasonably foreseeable."     The requirement to prepare a "worst
               groups move toward the Arctic Ocean, the report correctly Points
                                                                                                            case analysis" when faced with Incomplete or unavailable
               out that many also move to higher elevations     along the mountains.                        Information was    rescinded last year. Since most of the
               However. we are concerned that the report places undue emphasis on                           environmental consequences in the report are based on       a worst case
               the coastal Insect relief habitats    while failing to place enough                          analysis supported by inadequate     information.. a  major modification
               recognition  on the wide variations   or Insect relief habitats. It                          is in order.

               should also  be pointed out that the Prudhoe Bay development pads
               and roads have created new Insect relief habitat and have not                                      The Resource Development Council     strongly urges  the authors of

             Page 16                                                                                    Page 17
             RDC ANWR Comments                                                                          ROC ANWR Comments

             the report to reconsider the speculative "worst-case" statements.                          conclusions of partial displacement, it is important to point out
             Due to the "worst-case" bias, RUC asks that those impacts based on                         that a significant increase in animals occur@ed in the study area
             a highly-speculative nature be clarified as such throughout the                            during a period of maximum development.
             environmental consequences section. This will allow and hopefully
             ensure that those reading the report are aware of the                                           Other portions of this section should also be revised.       For
             highly-speculative nature of those conclusions.                                            example, Page 109, paragraph 6 states that "if caribou refuse to
                                                                                                        cross through any development areas. then 194,000 acres would be
                   We believe it is important to point out that the statement on                        unavailable as habitat.    That area encompasses 52 percent of total
             page 108, paragraph 7 is a major misrepresentation of a study's                            insect-reLief and over 80 percent of Coastal insect-relief
             conclusions. The statement reads:      "Based upon-the work of Dau   and                   habitats." The hypothesis that the Porcupine herd would be
             Cameron (1985), caribou are displaced approximately 2 miles out                            eliminated from virtually all Its coastal insect-relief is based on
             from development ... within this 2 mile area of influence are about                        a "worst-case" scenario that the herd would "refuse to cross
             357,000 acres of total core calving grounds in the 1002 area."                             through any development areas." There are no studies to support
                                                                                                        the hypothesis that a properly designed pipeline and road would
                   In reality, the relationship between calves and distances from                       present a total barrier to caribou movements.      Yet there are plenty
             the road Wilne Point) is statistically insignificant.       Dau and                        of examples of herds throughout the world regularly crossing
             Cameron did find fewer maternal groups near the road than away from                        through not only properly developed areas, but Inproperly designed
             it, but the partial displacement was for 2 kilometers, not 2                               pipelines.

             miles. In addition, their data show a high degree of annual
             variability. Their data also show that non-maternal caribou       were                           Regarding the statements within the report on oil spills, it
             not displaced by the road corridor and that "partial displacement"                         is Important to note that while the authors correctly state that
             was shown within a zone of 0-3 km.                                                         the cumulative effect of spills has not been signficant, they
                                                                                                        completely ignore the main reason for the lack of significant
                   Unfortunately, the USFWS uses these data to Imply that a                             impact.   Of the 82,216 gallons spilled In 1985, very little
             complete displacement of all caribou groups occurred out to 2                              actually reached the environment because the spills were cleaned up
             miles.  This is grossly Incorrect and we ask that this section be                          very efficiently. Unfortunately, the discussion leads one to
             revised to reflect proper study results.     Regardless of the                             assume that all 82,21b gallons went into the tundra.

                Page 18                                                                                    Page 19
                HOC ANWR Comments                                                                          ROC ANWR Comments

                      Most spills occur on snow-covered gravel production pads where                       The report currently fails to recognize that 500,000 acres of the

                they  are easy to spot and cleanup. Those which occur An the summer                        ANWR Coastal Plain is designated wilderness.      Even with full

                and off the gravel   pads are treated with sorbent pads.and                                leasingunder Alternative A, this section will remain untouched,
                rehabilitation and   revegetation, procedures.                                             thus preserving the complete spectrum of arctic ecosystems

                                                                                                           represented in the   Arctic Refuge.

                      Given Industry's  good record and the.fact that spills are

                routinely cleaned up before they harm the environment, we take                                   The USFWS, in.assessing   the environmental consequences   of

                exception  to statements such as the one on page 100, paragraph      6:                    possible  oil and gas development   In the 1U02 area, has focused its
                "The almost unavoidable minor oil leaks and spill...which would                            impact analyses on 1,086 of habl.tat.value and has quantified its
                contaminate the tundra and, possibly, the aquatic environment..."                          impact conclusions in terms of acres lost., Assuming a direct

                Spills are easily noticed on Lee and snow and rarely escape                                correlation between acres of habitat available and the population

                detection, even in quantities    of leas than one gallon. Amixture                         sizes of resident species, USFWS has translated its projections of
                of snow and oil can be easily   'scooped up by alanow  shovel or   front                   acres lost to  population reductions.
        2
                end loader.
        Cj
                                                                                                                 The Resource Development Council does not believe that this
                      The Council  urges the authors to either   delete or clarify the                     simplistic approach to bio   .logy justified primarily on the basis of

                statement within   the report that reads: "The   1002 area is the                          the USFWS Mitigation Policy was ever examined by the agency for Its
                most biologically productive,part of the Arctic Refuge for wildlife                        scientific validity in thearctic.      The mitigation policy is built

                and is the center of wildlife activity on the refuge." This                                on the management of   habitat as a means of managing the

                statement is contrary. to the wildlife population data cited in                            productivity of fish   and wildlife populations.

                preceding parts of the report which point out the relatively low
                abundance of wildlife species and the relatively short period of                                 However, we agree with   the Alaska Oil  and Gas Association that

                use of the 1002 area.                                                                      it is inappropriate to   use a  habitat-based  system to manage a

                                                                                                           Population when habitat   availability has not been shown to be a
                      In addition, we stress that   the authors acknowledge that the                       mechanism by which that   population is regulated.     This policy is

                30-mile section of the Coastal Plain from the 1002 area east to       the                  especially out of place    in the arctic where habitat has not been

                Canadian border and further    into Canada will remain as wilderness.                      shown to be a limiting factor for caribou.      Data clearly supports

               Page 20                                                                                    Page 21
               RUC ANWR Comments                                                                          RDG ANWH Gomments

               the finding tha,t hard size is regulated by direct mortality due to                        Itic., stronply endorses Alternative A, full leasiiig of the 1002
               predation.                                                                                 study area, as the most acceptable alternative consistent with the

                                                                                                          national interest.

                     The Resource Development Council believes that the current

               policy of focusing on habitat serves no biologically meaningful

               purpose. A biologically effective approach to assessing and

               mitigating effects of development on wildlife would be to first

               determine systematically how project activities and structures will

               adversely affect a population and then apply mitigation measures

               that would avoid or minimize disturbances to the population.

                     The USFWS Mitigation Policy should not be the foundation for

               impact analysis or mitigation requirements in the arctic. The
       -4      foundation for impact analysis and mitigation requirements should
      Ah
               be based on well@established principles of applied ecology and

               range science.

                     Some repondents have suggested that "more study" is required

               before Congress can make an Informed decision on whether to open

               the Coastal Plain. The draft report contains all the data

               necessary for Congress to make an informed decision. The call for
               "more study" is primarily an attempt by those who would like to

               delay the project forever.    Americans must understand that the

               Coastal Plain region is one of the most studied environments in the

               world.

                     In concluding, the Resource Development Council for Alaska,

                                           Submitted by: Assemblyman Kubitz

                                           Prepared by:     Assembly
                                                            Budget Analyst

                                           For Reading:     November 25, 1986

                                        AR No. 86-28
                                                        DA
                                                            TE
                                     ANCHORAGE, ALAS

            A RESOLUTION OF THE MUNICIPALITY OF ANCHORAGE SUPPORTING
            EXPLORATION IN THE ARCTIC NATIONAL WILDLIFE REFUGE (ANWR) COASTAL
            PLAIN

                      WHEREAS, most other potential Alaska basins have been
            tested with 4&sappelat-ing- results, and
                          varying
                      WHEREAS, the Arctic National    Wildlife Refuge has the
            highest potential of any unexplored region in the onshore United
            States, and

                      WHEREAS, the development of new       domestic hydrocarbon
            supplies is a crucial factor in the national    interest, and

                      WHEREAS, oil and gas activities       on the North Slope
            provide significant economic benefits to federal and state
            governments and to Alaskans in general, and

                      WHEREAS, it is a proven fact          that the petroleum
            industry can explore and develop while protecting fragile
            environments.

                      NOW THEREFORE,     the Anchorage      Municipal Assembly
            resolves that Alaska's elected federal officials should, in all
            due haste,    press forward *with appropriate legislation to
            facilitate the exploration and potential development of the
            Arctic National Wildlife Refuge Coastal Plain.

                      PASSED AND APPROVED by the Anchorage Assembly tt.is
              25th day of  November                 1986.

                                                 rMl

                      Clark
                                           4@e @irm

            EJG: vk
            A:EJG046a.TXT

    					AMBLER CITY COUNCIL

    			RESOULTION ON THE A_ _ _ COASTAL  PLA_ _

    				RESOULTION _ 0-_7

    WHEREAS,	Alaska's Arctic National Wildlife Refuge includes more
    		than 19 million acres of land, amounting to approxima-
    		ately five percent of the entire state l_ _ _ _ _ _ _, and

    WHEREAS,	the Coastal Plain is approximately eight percent of the
    		refuge _ is considered to be _ _ _ _ pr_ pest_ _ _ for
    		the discovery of large quantities of oil and gas; and

    WHEREAS,	Congress _ _ reserved the discretion to decide if the
    		1.5 million acres will be opened further exploration,
    		development and production; and

    WHEREAS, 	the petroleum industry has consistently demonstrated its
    		ability to operate in conditions similar to those found
    		on the coastal plain in a safe, responsible manner
    		without significant adverse environmental impacts, and

    WHEREAS,	the United States must prepare to develop domestic
    		petroleom resources if it is to preclude overwhelming
    		dependence on foreign petroleom sources in the 21st
    		century; and

    WHEREAS,	the value and development potential of state-owned
    		tidelands and federally-owned OCS lands offshore of the
    		ANWR Coastal Plain would be enhanced by a Congressional
    		decision to open the coastal plain to further
    		exploration, development and production; and

    WHEREAS,	facilities developed to transport petroleom resources
    		on the coastal plain to Pump Station One may allow
    		marginal discoveries be_ _ _ _ _ the ANWR Coastal Plain and
    		Prudue Bay to be developed; and

    WHEREAS,	national energy security depends on the development of
    		domestic oil and gas resouces to replace depleted U.S.
    		reserves; and

    WHEREAS,	the nation stands to derive revenues including portions
    		of bonuses, royalties and rents from oil and gas
    		reserves; and

    WHEREAS,	opening the ANWR Coastal Plain to further exploration,
    		develop_ _ _ _ and production will generate increased
    		employment and business _ _ _ortunities for all Alaskans
    		and all Americans;

    THEREFORE BE IT RESOLVED THAT City Council of Ambler, Alaska
    strongly urges the Congress of the United States to open the ANWR
    Coastal Plain to environmentally responsible oil and gas

    						1

    exploration, development and production.

    PASSED AND APPROVED this 11th day of December, 198_, by
    a majority vote of the City Council of A_bler, Alaska.

    ATTEST:

    		clerk								Mayor

    			Brevig Mission City Council
    				General Delivery
    			Brevig Mission, Alaska 99785
    				907-642-3851

    	RESOLUTION OF THE ANWR COASTAL PLAIN

    		Resoltion 87-01

    WHEREAS,	Alaska's artic National Wildlife Refuge includes more
    		than _ _ million acres of land, amounting to approxia-
    		tely five percent of the entire  _ _ _ _ _ _ _ __ _ _ , _ _

    WHEREAS,	the Coastal Plain is approximately eight percent of the
    		refuge, it is considered to be highly prospective for
    		the discovery of large quantities of oil and gas; and

    WHEREAS,	Congress has reserved the discretion to decide if the
    		1.5 million acres will be opened to further exploration,
    		development and production; and

    WHEREAS,	the petroleum industry has consistently demonstrated its
    		ability to operate in conditions similar to those found
    		on the coastal plain in a safe, responsible manner
    		without significant adverse environmental impacts, and

    WHEREAS,	the United States must prepare to develop domestic
    		petroleum resources if it is to preclude overwhelming
    		dependence on foreign petroleum sources in the 21st
    		century; and

    WHEREAS,	the value and development potential of state-owned
    		tidelands and federally-owned _ _ _ lands offshore of the
    		_ _ _ _ Coastal Plain would be enhanced by a Congressional
    		decision to open the coastal plain to further
    		exploration, development and production; and

    WHEREAS,	facilities developed to transport petroleum resources
    		on the coastal plain to Pump Station One may allow
    		marginal discoveries between the ANWR Coastal Plain and
    		Prudhoe Bay to be developed; and

    WHEREAS,	national energy security depends on the development of
    		domestic oil and gas resources to replace depleted U.S.
    		reserves; and

    WHEREAS,	the nation stands to drive revenues including protions
    		of bonuses, royalties and rents from oil and gas develope-
    		ment; and

    WHEREAS,	opening the ANWR Coastal Plain to further exploration,
    		developement and production will generate increased
    		employment and business opportunities for all Alaskans
    		and all Americans;

    THEREFORE BE IT RESOLVED THAT Brevig Mission City Council strongly

    							_

    urges the Congress of the United States to open the _ _ _ _ Coastal
    Plain to environmentally responsible oil and gas exploration,
    development and production.

    Walter Seetot, Mayor

    					Leonard _. _lann_, Vice Mayor

    					Rita Clano_, Secretary

    					Elmer Seetot, _r., Treasurer

    					Leonard Adam, Member

    					Elmer Clanna, Member

    Dated this 9th day of January, 1987,

    Attest:

    			City Clerk

    						CITY OF ELIM
    						Resolution 87-2

    A Resolution on the ANWR Coastal Plain.

    WHEREAS,	Alaska's Arctic National Wildlife Refuge includes
    		more than 19 million acres of land, amounting to
    		approximately five percent of the entire state
    		landmass; and

    WHEREAS,	the Coastal Plain is approximately eight percent
    		of the refuge, it is considering to be highly
    		prospective for the discovery of large quantities
    		of oil and gas; and

    WHEREAS,	Congress has reserved the discretion to decide if
    		the 1.5 million acres will be opened to further
    		exploration, development and production; and

    WHEREAS,	the petroleum industry has consistantly demonstra-
    		ted its ability to operate in conditions similar
    		to those found on the coastal plain in a safe,
    		responsible manner without significant adverse
    		environmental impacts, and

    WHEREAS,	the United States must prepare to develop domestic
    		petroleum resources if it is to preclude over-
    		whelming dependence on foreign petroleum sources
    		in the 21st century; and

    WHEREAS,	the value and development potential of state-owned
    		tidelands and federally-owned OCS lands offshore
    		of the ANWR Coastal Plain would be enhanced by a
    		Congressional decision to open the coastal plain
    		to further exploration, development, and produc-
    		tion; and

    WHEREAS,	facilities developed to transport petroleum
    		resources on the coastal plain to Pump Station One
    		may allow marginal discoveries between the ANWR
    		Coastal Plain and Prudhoe Bay to be developed; and

    WHEREAS,	national energy security depends on the develop-
    		ment of domestic oil and gas resources to replace
    		depleted U.S. reserves; and

    WHEREAS,	the nation stands to darive revenues including
    		portions of bonuses, royalties and rents from oil
    		and gas developement; and

    WHEREAS,	opening the ANWR Coastal Plain to further explora-
    		tion, development and production will generate
    		increased employment and business opportunities
    		for all Alaskans and all Americans;

    NOW THEREFORE BE IT RESOLVED THAT Elin City Council strongly
    urges the Congress of the United Sates to open the ANWR
    Coastal Plain to environmentally responsible oil and gas
    exploration, development and production.

    PASSES AND APPROVED by a DULY CONSTITUTED _ UORUM of the
    ELIM CITY COUNCIL this 5th day of January 1987.

    					Frederick Brailey, Mayor

    	ATTEST:

    		Josie Makarak, City Clerk

                                               CITY OF, HAINES, ALASKA                                                           BE IT RESOLVED BY THE COUNCIL OF THE CITY OF HAINES, ALASKA, strongly
                                                                                                                                 urges the Congress of the United States to open the ANWR oil range to
                                               RESOLUTION NO. 86/81-9                                                            environmentally responsible oil and gas exploration.
                                    A RESOLUTION ON THE ALASKA NATIONAL WILDLIFE REFUGE                                          PASSED AND APPROVED THIS IST DAY OF OCTOBER. 1986.
                                    COASTAL PLAIN.

                    WHEREAS,   Alaska's Arctic National Wildlife Refuge includes more     than 19
                               million acres of land. amounting to approximately five    percent                                                                         pr.      apham, Mayor
                               of the entire state landmass, and

                    WHEREAS,   the Coastal Plain is approximately eight percent of the                                           ATTEST:
                               refuge, it Is considered to be highly prospective for the
                               discovery of large quantities of oil and gas; and

                    WHEREAS,   Con
                                  1ress has reserved the discretion to decide if    the 1.5
                               mi ion acres will be opened to further exploration, develop-                                      Adren 6111 land, Lilly, C lerk
                               ment and production; and
                    WHEREAS.   the petroleum industry has consistently demonstrated its                                          S E A L:
                               ability to operate in conditions similar to those found on the
                               oil range in a safe, responsible manner without significant
                               adverse environmental impacts; and
                    WHEREAS,   the United States' must prepare to develop domestic petroleum
                               resources if it.is to preclude overwhelming dependence on
                               Joreign petroleum sources in the 21st century; and
                    WHEREAS,   the value and development potential of state-owned    tidelands
                               and federally-owned OCS lands offshore of the ANWR     Coastal
                               Plain would be enhanced by a Congressional decision to open
                               the oil range to further explorationj development and produc-
                               tion; and

                    WHEREAS,   facilities developed to transport petroleum resources on the
                               oil range to Pump Station One may allow marginal discoveries
                               between the ANWR oil range and Prudhoe Bay to be developed;
                               and
                    WHEREAS,   natioZI] :71rgy security depends on the development of
                               domes c      and gas resources to replace depleted U.S.
                               reserves; and

                    WHEREAS,   the nation stands to derive revenues Including   portions of
                               bonuses, royalties and rents from oil and gas development; and
                    WHEREAS,   opening the AKWR oil range to further exploration, development
                               and production will enerate increased employment and business
                               opportunities for a]? Americans;
                                                                                                                                                                     6@pr ;;a P

                                                         Introduced by: Mayor/Glick
                                                         Date: Nov. 18, 1986
                                                         Vote:           13 Yes, I No
                                                         Action:              Adopted
                                                                                                            NOW THEREFORE, BE IT RESOLVED    BY THE ASSEMBLY OF THE KENAI
                                                                                                       PENINSULA BOROUGH:
                              KENAI PENINSULA BOROUGH
                                                                                                            Section 1.     That the Kenai     Peninsula Borough Assembly
                                 RESOLUTION 86-160                                                     stron-gry -urges the Congress of the United States to open the ANWR
                                                                                                       Coastal Plain to environmentally responsible oil and gas explora-
                                                                                                       tion, development and production.
         URGING CONGRESS TO OPEN THE ARCTIC NATIONAL WILDLIFE       REFUGE TO
         OIL AND GAS EXPLORATION AND DEVELOPMENT.                                                           Section 2.    That borough clerk, shall send copies of this
                                                                                                       resolu-tro-n---to-bonald P. Hodel, U.S. Secretary of the Interior; to
              WHEREAS, Alaska's Arctic National Wildlife Refuge includes                               Governor Cowper; U.S. Senators Frank Murkowski and Ted Stevens;
         more than 19 million acres of land, amounting to approximately                                and to U.S. Representative Don Young.
         five percent of the entire state landmass; and                                                     ADOPTED By THE ASSEMBLY OF    .THE KENAI PENINSULA BOROUGH ON
              WHEREAS, the Coastal Plain is approximately eight percent of                             THIS   2nd  DAY OF      December              1986.
         the refuge and is considered to be highly prospective for the
         discovery of large quantities of oil and gasi and
              WHEREAS Congress has reserved the discretion to decide if                                                                            'Al@
         the 1.5 , miliion acres will be opened to further exploration,                                                           onathan W. Sewall-, Assembly FresIdent
         development and production; and

              WHEREAS, the petroleum industry has consistentl demonstrat-                              ATTEST:
         ed its ability to operate in  'conditions similar to tKose found on
         the Coastal Plain in a safe. responsible manner without, signif i-
         cant adverse environmental impactss and                                                    (12r@
              WHEREAS, the United States must develop additional domestic                               orough ULerk
         petroleum resource 'a if it is to preclude overwhelming dependence
         on foreign petroleum sources in the 21st century; and
              WHEREAS, the value and development potential of state-owned
         tidelands and federally-owned OCS lands offshore of the ANWR
         Coastal Plain would be enhanced by a congressional decision to
         open the Coastal Plain to further exploration, development and
         production; and

              WHEREAS, facilities developed to transport petroleum re-
         sources on the Coastal Plain to the Trans-Alaska Pipeline may
         allow marginal discoveries between the ANWR Coastal Plain and
         Prudhoe Bay to be developed; and
              WHEREAS, national energy security depends on the development
         of domestic oil and gas resources to replace depleted U.S.
         reserves; and

              WHEREAS, the state of Alaska stands to derive revenues
         includin portions of bonuses, royalties and rents from oil and
         gas development on the ANWR Coastal Plaini and

              WHEREAS, opening the ANWR Coastal Plain to further explora-
         tion, development and production will generate increased employ-
         ment and business opportunities for all Alaskans and Americans;

                                                     Kenai Peninsula Borough                                                                       Kenai Peninsula Borough
                                                     Resolution 86-160                                                                             Resolution 86-160
                                                     Page 1 of 2 Pages                                                                             Page 2 of 2 Pages

    					CITY OF KENAI
    				"Oil Capital of Alaska"
    			_1_ FIDALGO  KENAI, ALASKA 99611
    				TELEPHONE 2_3-75_ _

    December 23, 1986

    TO:  	All Concerned

    FROM:	John Williams
    	Mayor

    I felt there is an urgent need to advise you of our position
    concerning ANWR, and have decided to include you on a
    personal mailing of our resolution.  We are all aware of the
    fact that ANWR may produce the next economic generations for
    Alaska and with that in mind I am sure I can depend on each
    of you to stay abreast of the developments affecting ANWR as
    tehy occur.

    JW:jw

    						Suggest by Mayor Williams

    				RESOULTION 86-120

    A RESOLUTION OF THE COUNCIL OF THE CITY OF KENAI, ALASKA,
    URGING CONGRESS TO OPEN ANWR COASTAL PLAIN TO OIL AND GAS
    DEVELOPMENT

    WHEREAS,  	Alaska's Arctic National Wildlife Refuge includes
    more than 19 Milion acres of land, amounting to
    approximately 5% of the entire State landmass, and

    WHEREAS,	the Coastal Plain is approximately 8% of the
    refuge, it is considered to be highly prosepctive for the
    discovery of large quantities of oil and gas, and

    WHEREAS,	national energy security depends on the development
    of domestic oil and gas resources to replace depleted U.S.
    reserves, and

    WHEREAS, 	the nation stands to derive revenues including
    portions of bonuses, royalties and rents from oil and gas
    development, and

    WHEREAS,	opening the ANWR Coastal Plain to further
    exploration, development and production will generate
    increased employment and business opportunities for all
    Alaskans and all Americans.

    THEREFORE BE IT RESOLVED BY THE COUNCIL OF THE CITY OF
    KENAI, ALASKA that the Council strongly urges the Congress
    of the United States to open the ANWR Coastal Plain to
    environmentally responsible oil and gas exploration,
    development and production.

    PASSED BY THE COUNCIL OF THE CITY OF KENAI, ALASKA this 17th
    day of December, 1986.

    					JOHN J. WILLIAMS, MAYOR

    ATTEST:

    Janet Whelan, City Clerk

                                             CITT OF KOTZEBUE

                                             nsoLUnON 86-37
                       A resolution urging the Congress of the United States          to                                          exploWHEREAS. opening the ANWR Coastal P       lain to further
                       open the ANWR Coastal Plain to environmentally responsible                                                      ration,    development    and    production will     generate
                                                                                                                                  Increased employment and business opportunities for all
                       oil and gas exploration, development and production.                                                       Alaskans and all Americans;
                            WHEREAS, Alaska's Arctic National        Wildlife     Refuge                                               THEREFORE BE IT RESOLVED THAT the City Council of the
                       Includes more than 19 million acres of land, amounting to                                                  City of Kotzebue      strongly urges the Congress of the United
                       approximately five percent of the entire state landmass, and                                               States to open the AWR Coastal Plain to environmentally
                                                                                                                                  responsible    oil   and    gas exploration, development and
                            WHEREAS. the Coastal Plain is approximately            eight                                          productiion.
                       percent of    the  refuge, it    is considered to be highly
                       prospective for the discovery of large quantities of oil and                                               Passed and approved   this /0    day of Dqe eeo% b 4e@  -,1986.
                       gas; and

                            WHEREAS, Congress has reserved the discretion to decide
                       If   the   1.5 million acres will be opened to further
                       exploration, development and production; and
                                                                                                                                                                  Mayor. City or Korzebuek-,/

                            WHEREAS, the petroleum       Industry   has    consistantly                                           A T T E S T:
                       demonstrated its ability to operate In conditions similar to
                       those found on the coastal plain In a safe, responsible
                       manner without    significant adverse environmental Impacts;
                       and                                                                                                            kaldo'-r'-
                            WHEREAS, the United States Must prepare to develop                                                    Cit y Clerk, City of Kotzebue
                       domestic   petroleum    resources    It   It   is to preclude
                       overwhelming dependence on foreign petroleum sources In the
                       21st century; and

                            WHEREAS,   the  value and      development  potential     of
                       state-owned tidelands and federally-owned OCS lands offshore
                       of the ANWR Coastal Plain would          be   enhanced    by    a
                       Congressional decision to open the coastal plain to further
                       exploration, development and production; and

                            WHEREAS, facilities developed to transport petroleum
                       resources on the coastal plain to Pump Station one may allow
                       marginal discoveries between the ANWR Coastal Plain and
                       Prudhoe Bay to be developed; and

                            WHEREAS, national energy security depends         on     the
                       development of    domestic all and gas resources to replace
                       depleted U.S. reserves; and

                            WHEREAS. the State, Regional and village corporations
                       stand to derive revenues Including portions of bonuses.
                       royalties and    rents from oil and gas development from
                       potential land swaps; and

                                                                                        ijjo

               CITY COUNCIL OF MOUNTAIN VILLAGE                                                            THEREFORE BE IT RESOLV  .ED THAT
                                           P.O. BOX 32085                                                  strongly urges the Congress of the 4Jnited Statift to open the ANWR
                                    MOUNTAIN VILLAGE. ALASKA "632                                          Coastal Plain to environmentally responsible oil and gas
                                    (907) 591-2929 or (907) 591-2232                                       exploration, development and production.

                                     RESOLUTION 86 - 014

              WHEREAS,   Alaska's Arctic National Wildelife Refuge includes more
                         than 19 millian acres of land, amounting to approximately                         ATTEST:
                         five percent of the entire state landmass, and;                                             City Clerk                                MaydNr

              WHEREAS,   the Coastal Plain is approximately eight percent of the
                         refuge, it is considered to be highly prospective for
                         the discovery of large quantities of oil and gas, and,

              WHEREAS,   Congress has reserved the discretion to decide if the
                         1.5 million acres will be opened to further exploration,
                         development and production, and;

              WHEREAS,   the petroleum industry has consistently demonstrated its
                         ability to operate in conditions similar to those found
                         on the coastal plain in a safe, responsible manner
                         without significant adverse environmental impacts,      and;

              WHEREAS,   the United States must prepare to develop domestic
                         petroleum resources if it is to preclude overwhelming
                         dependence on foreign petroleum sources in the 21st
                         century, and;

              WHEREAS,   the value and  development potential of state-owned
                         tidelands  and federally-owned OCS lands offshore of the
                         ANWR Coastal Plain would be enhanced by a Congressional
                         decision to open the coastal plain to further explora-
                         tion, development and production, and;

              WHEREAS,   facilities developed to transport petroleum resources
                         on the coastal plain to Pump Station One may allow
                         marginal discoveries between the ANWR Coastal Plain and
                         Prudhoe Bay to be developed, and;

              WHEREAS,   national energy security depends on the development of
                         domestic oil and gas resources to replace depleted U.S.
                         reserves, and;

              WHEREAS,   the nation stands to derive revenues including portions
                         of bonuses, royalties and rents from oil and gas
                         development, and;

              WHEREAS,   opening the ANWR Coastal Plain to further exploration,
                         development and production will generate increased
                         employment and business opportunities for all Alaskans
                         and all Americans;

              R E C E    0                  Resolution No. 87-01                                                              Resolution No. 87-01
                                                                                                                              PAGE TWO
                  RESOLUTION ON THE ARCTIC NATIONAL WILDLIFE REFUGE (ANWR) COASTAL PLAIN.

                  WHEREAS, Alaska's Arctic National Wildlife Refuge includes more than 19
                           million acres of land, amounting to approximately five percent
                           of the entire state landmass; and                                                                                                            Member

                  WHEREAS, the Coastal Plain is approximately eight percent. of the refuge,
                           it is considered to be highly prospective for the discovery of                                     ATTEST:        e;
                           large quantities of oil and gas; and                                                                                                         Member

                  WHEREAS, Congress has reserved the discretion to decide if the 1.5 million
                           acres will be opened to further exploration, development and
                           production; and                                                                                                                              Membir

                  WHEREAS, the petroleum industry has consistently demonstrated Its ability
                           to oper@te in conditions similar to those found on the coastal
                           plain in a safe, responsible manner without significant adverse                                                                              Member
                           environmental impacts; and

                  WHEREAS, the.United States must prepare to.develop domestic petroleum
                           resources if It is to preclude overwhelming dependence on foreign                                                                            Member
                           petroleum sources-in the 21st century; and

                  WHEREAS, the value and development potential of state-owned tidelands and
                           fedeially-owned OCS lands offshore Of the ANWR Coastal Plain would
                           be enhanced by a Congressional decision to open the coastal plain
                           to further exploration, development and production, and

                  WHEREAS, facilities developed.to transport petroleum resources on    the coastal
                           plain to Pump Station One may allow marginal discoveries    between
                           the ANWR Coastal Plain and Prudhoe Bay to be developed;     and

                  WHEREAS, national energy security depends on the development of domestic Oil
                           and gas resources to replace depleted U.S. reserves; and

                  WHEREAS, the nation stands to derive revenues including portions of bonuses.
                           royalties and rents from Oil and gas development; and

                  WHEREAS, opening the ANWR Coastal Plain to further exploration, development
                           and production will generate increased employment and business
                           opportunities for all Alaskans and sit Americans.

                  THEREFORE BE IT RESOLVED, that the City of Nulato strongly   urges the Congress
                           of the United States to open the ANWR Coastal Plain to environmentally
                           responsible oil and gas exploration, development and production.

                  DATE:                _,L,0 dff
                                                           MavAor

                                                           Vice-Mayor

                                                                                                                                                                                    @j- -
                                                                                                                                                                                    -N ii

                                       CITY OF OUZINKIE                                                                 RESOLUTION ON THE ANWR COASTAL PLAIN

                                       RESOLUTION 86-15
                            RESOLUTION ON.THE ANWR COASTAL PLAIN                                            WHEREAS,  Alaska's Artic National Wildlife Reiuge includes more
                                                                                                                      than 19 million of land, amounting to approximately
                                                                                                                      five percent of the entire state.landmass, and
               WHEREASO   Alaska's Arctic National Wildlife Refuge Includes                                 WHEREAS,  the Coastal Plain is approximat  -sly eight percent of the
                          more than 19 million acres of land, amounting to                                            refuge, it is considered to be highly prospective for
                          approximately five percent of the entire state                                              the discovery of large quantities of oil and gas; and
                          landmass, and
               WHEREAS,   the Coastal Plain Is &ppr oximately eight percent                                 WHEREAS,  Congress has reserved the discretion to decide if the
                                                                                                                      1.5 million acres will be opened to further exploration,
                          of the refuge, It Is considered to be highly                                                development and production; and
                          prospective for the discovery of large quantities
                          of oil and gas; and                                                               WHEREAS,  the petroleum industry has consistently demonstrated its
                                                                                                                      ablifty. to operate in conditions similar to those found
               WHEREAS,   Congress has reser@ved th# discretion to decide If                                          on the coastal plain in a safe, resopnsible manner
                          the 1.5 million acres will be opened to further                                             without significant adverse enviromental impacts, and
                          exploration, development and production; and
                                                                                                            WHEREAS,  the United States must prepare to develop domestic
               WHEREAS,   the petroleum Industry has consistently                                                      petroleum resources if it is to preclude overwhelming
                          demonstrated Its ability to operate In conditions                                            dependence on foreign petroleum sources in the 21st
                          similar to those found on the oil range In a safe,                                           centry; and
                          responsible manner without significant adverse
                          onvironnmtntal.impactsi and                                                       WHEREAS,  the value and development potential of state-owned
                                                                                                                      tidelands and federally-owned OCS lands, offshore of the
               WHEREAS9   the United States must prepare to develop                                                   ANWR Coastal Plain would be enhanced by a Congressional
                          Petroleum resources if It Is to preclude                                                    decision to open the coastal plain to further
                          whelming dependence on foreign pertoltum sources                                            exploration, developmentin-d productiont and
                          In t.he 21st century; and                                                         WHEREAS,  facilities develop to transport petroleum resources
               WHEREAS,   the value and development potential of state-owned                                          on the coastal plain to Pump Station One may allow
                                                                                                                      marginal discoveries between the ANWR Coastal Plain and
                          tidelands and federally-owntd OCS lands offshore                                            Prudhoe Bay to be developed; and
                          of the ANWR Coastal Plain would be enhanced by a
                          Congressional decision to open the oil range to                                   WHEREAS,  national energy security depends on the development of
                          further exploration, development and productionj                                            domestic oil and gas resources to replace depleted U.S.
                          and                                                                                         reservesy and
               WHEREAS,   facilities developed to transport petroleum                                       WHEREAS,  the nation stands to derive revenues to including portions
                          resources on the oil range to Pump Station One may                                          of bonuses, royalties and rents from oil and gas
                          allow marginal discoveries between the ANWR oil                                             developement; and
                          range and Prudhoe Say to be developed; and                                        WHEREAS,  opening the ANWR coastal Plain to further exploration,
                                                                                                                      development and production will generate increased
               WHEREAS,   national energy security depend% on the                                                     employment and business opportunities for all Al kans
                          development of domestic oil and gas resources to                                            ana all Americans;                  ()ftw Nry0=5
                          replace depleted U.S. reserves; and                                                                                       ' 0 (
                                                                                                            THEREFORE BE IT RESOLVED THAT
               WHEREAS,   the nation stands to derive revenues Including                                   @strongly urges the Congress 07-the UNited States to open     the ANWR
                          portions of bonuses, royalties and rents from oil                                 Coastal Plain to environmentlly responsible oil and gas
                          and gas dovolopmentl and                                                          exploration, development and production.
               WHEREAS,   opening the ANWR oil range to further exploration,
                          development and production will generate increased
                          employment and business opportunities for all
                          Americans;

                                  CITY OF PORT HEIDEN

                                    Resolution 86-45

                         RESOLUTION ON THE AHWR COASTAL PLAIN

           WHEREAS,  Alaska's Arctic Vational Wildlife Refuge includes more
                     than 19 million acres of land, amounting to approxima-
                     tely five percent of the entire state landmass, and

           WHEREAS,  the Coastal Plain is approximately eight percent of the
                     refu e, it is considered to be highly prospective for
                     the 31scovery of large quantities of oil and gas; and

           WMERFAR,  Congress has rpserveO the  dfscretton to -jecide if the
                     1.5 million acres will be  opened to further exploration,
                     development and production; and

           4HERZAS,  the petroleum industry has consistently demonstrated
                     its abilit to operate in conditions similar to those
                     .found on tKe oil range in a safe, responsible manner
                     without significant adverse environmental impacts; and

           WHEREAS,  the United States must prepare to develop domestic
                     petroleum resources if it is to preclude overwhelming
                     dependence on foreign petroleum sources in the 21st
                     century; and

           W4EREAS,  the value and development potential   of state-owned
                     tidelands and federally-owned OCS lands offshore of the
                     ANWR Coastal Plain would be enhanced by a Congressional
                     decision to open the oil range to further exploration,
                     development and production; and

           WHEREAS,  facilities  developed to transport petroleum resources
                     on the oil range to Pump Station One may allow marginal
                     discoveries between the ANWR oil range and Prudhoe Pay
                     to be developed; and
           WHEREAS,  national :njrgy security depends on the development of
                     domestic i and gas resources to replace depleted U.S.
                     reserves; and

           WHEREAS,  opening the ANWR oil range to further exploration,
                     development and production will generate incresased
                     employment and business opportunities for all
                     Americans:

           THEREFORE BE IT RESOLVED THAT the Port Heiden City Council strongly
           urges the Conress of the United States to open the ANWR oil range
           to environmentally responsible oil and gas exploration, development.
           and production.
           PASSED and APPROVED by the PORT HEIDEN CITY COUNCIL this /L day
           of              1986

                                            Hayor

           Xt-tested by Clerk

                                               CITY OF SOLDOTNA

                                               RESOLUTION 86-49
                                            (Introduced by City Manager)
                  A RESOLUTION URGING CONGRESS TO OPEN A PORTION OF THE ARCTIC
                   NATIONAL WILDLIFE REFUGE TO OIL & GAS EXPLORATION AND DEVELOPMENT

                   WHEREAS, the the Arctic National Wildlife Refuge contains about 1.5
                   million acres of coastal land between Prudhoe Beg and the Canadian Border
                   which represents the largest and, perhaps, lost remaining on-shore deposit
                   of oil in the United States; and,
                   WHEREAS this land Is a part of a     19 million acre parcel of the Arctic
                   National Wildlife Refuge of which    17.4 million acres has already been
                   closed to the development of natural resources; and,
                   WHEREAS, the U.S. Congress to expected to decide whether this coastal
                   plain should be opened to all and gas exploration or whether it should be
                   fully pledged and set aside as a national wildlife refuge; and,
                   WHEREAS the Soldotne City Council desires to lot its opinions be known
                   prior to the Congressional debate an this issue;
                   NOW, THEREFORE, BE IT  RESOLVED BY THE COUNCIL OF THE CITY OF
                   SOLDOTNA, ALASKA AS FOLLOWS:
                   Section 1. A finding is mode that sufficient acreage of the State of Alaska
                   has been already been pledged to wildlife preservation and that the
                   remainder should be opened to resource development to further enhance.
                   the economy of this state and the nation.
                   Section 2.     Congress is  urged I open the coastal plain of the Arctic
                   National Wildlife Refuge, for environmentally responsible oil and gas
                   exporation and production.
                   Section 3.  The City Clark directed to send a copyof this Resolution to
                   Alaska's Congressional Delegation and the Resource Development Council
                   for Alaska Inc.to facilitate a demonstration of state wide concensus on
                   this issue by  responsible Alaska organizations.

                   ADOPTED this -1st- of October, 1986.

                                                                     Mayor

                   ATTEST:

                              City Clerk

                                        CITY OF WRANGELL, ALASKA

                                        RESOLUTION NO.09-86-258

                          A RESOLUTION  OF THE COUNCIL OF THE  CITY OF WRANGELL,
                          ALASKA, URGING THE CONGRESS OF THE   UNITED STATES TO
                          OPEN THE ARCTIC NATIONAL WILDLIFE REFUGE OIL RANGE
                          TO ENVIRONMENTALLY RESPONSIBLE OIL AND GAS EXPLORA-
                          TION, DEVELOPMENT AND PRODUCTION.

                WHEREAS, Alaska's Arctic National Wildlife Refuge (ANWR) includes
          more than 19 million acres of land, amounting to approximately five
          percent of the entire state landmass; and

                WHEREAS, the Coastal Plain is approximately eight percent of the
          refuge, it is considered to be highly prospective for the discovery of
          large quantities of oil and gas; and

                WHEREAS, the petroleum industry has consistently demonstrated its
          ability to operate in conditions similar to those found on the oil range
          in a safe, responsible manner without significant adverse environmental
          impacts; and

                WHEREAS, the United States must prepare to develop domestic petro-
          leum resources if it is to preclude overwhelming dependence on foreign
          petroleum sources in the 21st century; and

                WHEREAS, the value and development potential of state-owned tidelands
          and federally-owned OCS lands offshore of the ANWR Coastal Plain would be
          enhanced by a Congressional decision to open the oil range to further
          exploration, development and production; and

                WHEREAS, the facilities developed to transport petroleum resources
          on the oil range to Pump Station One may allow-marginal discoveries,be-
          tween the ANWR oil range and Prudhoe Bay to be developed; and

                WHEREAS, National energy security depends on the development of
          domestic oil and gas resources to replace depleted U. S. Reserves; and

                WHEREAS, tho nation stands to derive revenues including portions of
          bonuses, royalties and rents from oil and gas development; and

                WHEREAS, opening the ANWR oil range to further exploration, develop-
          ment and production will generate increased employment and business
          opportunities for all Americans;

          NOW, THEREFORE BE IT RESOLVED BY THE COUNCIL OF THE CITY OF WRANGELL,
          ALASKA , strongly urges the Congress of the United States    to open the
          ANWR oil range to environmentally responsible oil and gas exploration,
          development production.

          PASSED AND APPROVED-       SEPTEMBER 23                        1986

                      4                                    A a- "OR
                               ZI , ..                    tna nd
          ATTEST@7;Y                                    A tt., e...Onej Med Is
                                                       VMCL
                          CITY CLERK

                                                     r,ty a2rk
                                                     C1* d tro"EA Alan

                                                                                                                                       WHEREAS, Alaska's Arctic NatiLml Wildlife Refuge inciudes MULe UkM1
                                                                                                                            18 million acres of land, amounting to approximately five percent of the
                                                                                                                            entire state landmass; and

                                                                                                                                       WHEREAS, approximately eight percent of the refuge, known as the
                                                                                                                            ANWR oil range, is considered to be highly prospective for the discovery of
                                                                                                                            large quantities of oil and gas; and
                                               CITY OF VALDEZ, ALASKA                                                                  WHEREAS, Congress must decide in the near future if the 1.5 million
                                                RESOLL)TICN NO. 8634                                                        acre oil range will be opened to further exploration, development and
                                                                                                                            productiont and

                           A RESOLUTION URGING CONGRESS TO OPEN THE ANKR OIL RANGE                                                     WHEREAS, the petroleum industry has consistently demonstrated its
                           TO ENVIFCMENIAMY RESPONSIBLE OM AND GAS ECFWWICN,                                                ability to operate in conditions similar to those found on the oil range in a
                                                                                                                            safe, responsible manner without significant adverse environmental impacts,
                                                                                                                            and
                           WHEREAS, Alaska's Arctic National Wildlife Refuge includes more than
                 18 million acres of land, amounting to approximately five percent of the                                              WHEREAS, the United States must prepare to develop domestic
                 entire state landmass; and                                                                                 petroleum resources if it is to preclude overwhelming dependence on foreign
                           WHEREAS, approximately eight percent of the refuge, k        .nown as the                        petroleum  a otir ces in the twenty@first centurys and
                 ANWR oil range, is considered to be highly prospective for the discovery of                                           WHEREAS, the value and development potential of state-owned
                 Large quantities of oil and gas; and                                                                       tidelands and federally-owned OCS lands offshore of the ANWR oil range are
                                                                                                                            dependent upon a Congressional decision to open the oil range to further
                           WHEREAS, Congress must decide in the near future if the 1.5 million                              exploration, development and productionj and
                 acre oil, range will be opened to further exploration, development and
                 production; and                                                                                                       WHEREAS, facilities developed to      transport petroleum resources on
                                                                                                                            the oil range to Pump Station One may allow      marginal discoveries between the
                           WHEREAS, the petroleum Industry has consistently demonstrated Its                                ANMR oil range and Prudhoe Bay to be developed; and
                 ability  to operate in conditions similar to those found on the oil range in a
                 safe, responsible manner without significant adverse environmental impacts;                                           WHEREAS, national energy security depends on the         development of
                 and
         (D                                                                                                                 domestic oil and gas resources to replace depleted U.S. reservest and
                           WHEREAS, the United States must prepare to develop domestic                                                 WHEREAS, the nation stands to derive revenues including portions of
                 petroleum resources if it is to preclude overwhelming dependence on foreign                                bonuses, royalties and rents from oil and gas developments- and
                 petroleum sources in the twenty-first century; and
                                                                                                                                       WHEREAS, opening the ANWR oil range to further exploration,
                           WHEREAS, the value and development potential of state-owned                                      development and production will generate increased employment and business
                 tidelands and federally-owned OCS lands offshore of the ANWR oi I range are                                opportunities for all Americans.
                 dependent upon a Congressional decision to open the oil range to further
                 exploration, development and production; and                                                                          NOW, THEREFORE, BE IT RESOLVED By THE CITY COUNCIL OF THE CITY OF
                                                                                                                            VALDEZ, ALASKA, that the City of Valdez strongly urges the Congress of the
                           WHEREAS, facilities developed to     transport petroleum resources on                            United States to open the ANWR oil range to environmentally responsible oil
                 the oil range to Pump Station one my allow      marginal discoveries between the                           and gas exploration, development and productiam.
                 ANWR oi I range and Prudhoe Bay to be developed; and
                                                                                                                                                                    CITY OF VALDEZ, ALASKA
                           WHEREAS. national energy security depends on the development of
                 domestic oil and, gas resources to replace depleted ELS. reservest and

                           WHEREAS, the nation stands to derive revenues including portions of
                 bonuses, royalties and rents from oil and gas development; and                                                                                     JC11h%4)even1r,- Mayor
                                                                                                                            ATTEST:
                           WHEREAS, opening the ANWR oil range to further exploration,
                 development and production will generate increased employment and business
                 opportunities for all Americans.
                                                                                                                                            P44
                           NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF                                Jim weplon, city Manager/city clerF
                 VALDEZ, ALASKA, that the City of Valdez strongly urges the Congress of the
                 United States to open the ANM oil range to environmentally responsible oil
                 and gas exploration, development and producticm

                                                        Crff OF VALDEZ, ALASKA

                                     ALASKA STATE CHAMBER OF COMMERCE

                                                 RESOLUTION

                                           Adopted October ). 1986
                                              Fairbanks, Alaska

                 WHEREAS, the Arctic National Wildlife Refuge (ANWR)includes more      than
                 18 million acres of land; and

                 WHEREAS, approximately 8% of the refuge known as the coastal plain is considered
                 highly prospective for the discovery of large quantities of oil: and
                 WHEREAS, Alaska's petroleum industry during the past 15 years has demonstrated
                 its ability to operate on the North Slope In a safe, responsible manner without
                 adverse environmental impact; and

                 WHEREAS, development of the oil and gas resources would benefit the State of
                 Alaska by job creation, royalty and tax income; and.

                 WHEREAS, the United States must develop domestic petroleum resources for
                 national security reason;

                 THEREFORE be it resolved that the Alaska State Chamber of Commerce urges the
                 100th Congress of the United States to open the coastal plain of the Arctic
                 National Wildlife Refuge to envirironmentally responsible oil and gas exploration,
                 development and production.

                 Jim Rynearson, Chairman                       George Krunz, President

                 October 1, 1986                                October 1, 1966

                                                                                           UTION 86-09
                                                                                        wR COASTAL PLAIN
                                                                                       Page Two

                                  A
                                                                                       THEREFORE BE IT RESOLVED THAT the Anchorage Chamber of Commerce strongly
                                  AnchordV-Slaroj'llicAlardt                           urges the Congress of the United States to open the ANWR Coastal Plain to
                                  Chamber of Commerce                                  environmentally responsible oil and gas exploration, development and pro-
                                  RESOLUTION 86-09                                     duction.
                                ANWR COASTAL IPLAIN                                    APPROVED BY H      h      Chamber of Commerce Board of Directors this-.a/
                                                                                       day of                            1986.
              Alaska's Arctic National Wildlife Refuge includes more than 19
              million acres of land, amounting to approximately five percent
              of the entire state landmass, and

              the Coastal Plain is approximately-eight percent of the  refuge,
              it is considered to be highly prospective for the discovery of
              large quantities of oil and gas, and
                                                                                       Ken a hoon                                  Wayne     Beckwith
              Congress has reserved the discretion to decide if the 1.5 million        President                                   Executive Vice President
              acres will be opened to further exploration, development and
              production, and
        92,   the Petroleum industry has onsistently demonstrated its ability
                                        I c
        ca    to 0-perate in conditions similar to those found on the coastal
        (D    plain in a safe, responsible manner without significant adverse
              environmental impacts, and

              the United States must prepare to develop domestic petroleum
              resources if it is to precluSe overwhelming dependence on foreign
              petroleum sources in the 21rt century, and
              the value and development potential of state-owned tidelands and
              federally-owned OCS lands offshore of the ANVIR Coastal Plain would
              be enhanced k;y a Congressional decision to open the coastal plain
              to further exploration, development and production, and

              facilities developed to transport petroleum resources on the coastal
              plain to Pump Station one may allow marginal discoveries between the
              ANWR Coastal Plain and Prudhoe Bay to be developed, and
              national energy security depends on the development of domestic oil
              and gas resources to replace depleted U.S. reserves, and

              the nation stands to derive revenues including portions of bonuses,
              royalties and rents from oil and gas development, and

              opening the ANwR coastal Plain to further exploration, development
              and production will generate increased employment and business
              opportunities for all Alaskans and all Americans;
                                                                                          Lc-al

                         415 F Street. Andiaraize. Ala%k-a 99501-2254 (q071!72-2.*n;

                                         COMMON SENSE FOR ALASKA
                                             P.O. BOX 202087
                                       ANCHORAGE, AK    99520-2087

                                    RESOLUTION ON THE ANWR OIL RANGE

          WHEREAS,   Alaska's Arctic  National Wildlife refuge includes more-than 18.
                     million acres of land, amounting to approximately five percent
                     of the entire state landmass; and

          WHEREAS,   approximately eight percent of the refuge, known as the ANWR
                     oil range, is.considered to be highly prospective for the dis-
                     covery of large quantities of oil and gas; and
          WHEREAS,   the petroleum industry has consistently demonstrated its
                     desire and ability to operate in conditions similar to those
                     found on the oil range in a safe, responsible manner without
                     significant adverse environmental impacts; and

          WHEREAS,   the United States must prepare to develop domestic petroleum
                     resources If it is to preclude overwhelming dependence on for-
                     eign petroleum sources in the 21st century; and

          WHEREAS,   national energy security depends on the development of domestic
                     oil and gas resources to replace depleted U.S. reserves; and

          WHEREAS,   Common Sense for Alaska   Inc., in its February 1986 report,
                     Coming to Grips with Runaway State Spending, recommended optim-
                     Tz-ing the state's nit_u_raT_res7u_rces assets by, "Maximizing land
                     use through multiple use classifications   ..... eliminating road
                     blocks, whether in permitting, regulatory control    or   taxation";
                     and

          WHEREAS,   the Congress of the United States must take the necessary legis-
                     lative action to permit access, exploration and subsequent dev-
                     elopment of the Arctic National Wildlife Refuge.

          Now, therefore, be it resolved that Common Sense for Alaska, Inc., whose
          'goals include fiscal responsibility in gover@ment, and private sector vs.
          public sector emphases on economic development, strongly urges the Congress
          of the United States to open the ANWR oil range to environmentally respon-
          .sible oil and gas exploration, development and production.

                                                            Jack Hayes
                                                            President
                                                            Common Sense for Alaska, Inc.

                                                                      RECEIVED DEr. I f 19,36

                                           THE GRANGE

                               AMERICA'$ FAMILY COMMUNITY FRATERNITY
                                       NorthlanTROneer Grange No. I
                                       P.O. Box 2304
                                       Palmer, Alaska

              December 8, 1986

              Robert M. Frederick, Legislative Director
              National Grange
              1616 H Street N.W.
              Washington, D.C. 20006

              Dear Mr. Frederick;
              The Nortbland Pioneer Grange No. I discussed the need for a congressional
              decision regarding oil exploration in Alaska's Arctic National Wildlife Refuge
              at our meeting an November 20, 1986.

              Our Grange agreed to support a resolution drafted by the Resource Development
              Council for Alaska, Inc. in regard to ANWR. It is the opinion of the Northland
              Pioneer Grange that additional exploration and knowledge of petroleum reserves
              is of great value to Alaska and the entire U.S.* I don't have the latest book
              of the National Grange Legislative Policies but in several previous ones the
              National Grange has supported the development of domestic energy reserves in a
              manner that would minimize any impact an the environment.    The enclosed ADC
              resolution seems consistent with the National Granges sitand on energy and
              Alaska would appreciate any support that could be generated in regard to
              getting the Congress to approve further exploration in the 1.5 million acres
              of ANWR proposed for exploration.   The Alaska congressional delegation would
              be helpful in supplying any information you may be interested in.

              Thank you very much for any support you.can generate.

              Sincerely,

              Siimend H. Restad, Master for 1987

              Enclosure

              .cc:   Resource Development Council for Alaska. Inc.
                     file

                                       GREATER KETCHIKAM C[WWER OF CCMMERCE
                                                  Resolution on the
                                       ANWR (ARMC.NATIONAL WILDLIFE RMM)

                 WHERM:       Alaska's Arctic National Wildlife Refuge includes more than     18 million
            acres of land,    amounting to approximately 5% of the entire state land mass; and

                 WHEREAS:     Approximately 8% of the refuge, known as the ANWR oil range, is considered
            to be highly      prospective for the discovery of large quantities of oil and gas; and

                 WHERM:       Congress mist decide ir% the near future if the 1.5 million acre oil range
            will be opened    to further explorIation, development and production; and

                 WHEREAS:     The petroleum industry has consistently demonstrated its ability to operate
            in conditions     similar to those found an the oil range in a safe, responsible manner
            without significant adverse environmental impacts; and

                 WHERM:       The United States of America must prepare to develop domestic petroleum
            resources if it   is to preclude overwhelming dependence on foreign petroleum sources in the
            21st Century; and

                 WHEREAS: The value and development potential of state-owned tidelands and federally-
            owned OCS lands offshore of the ANWR oil range are dependent upon a Congressional decision
            to open the oil range to further exploration, development and production; and

                 WHEREAS: Facilities developed to transport petroleum resources an the oil range to
            Pump Station One may allow marginal discoveries between the ANWR oil range and Prudhoe Bay
            to be developed; and

                 WHEREAS: National energy security depends on the development of domestic oil and gas
            resources to replace depleted U.S. reserves; and

                 WHEREAS:     The nation stands to derive revenues including portions       .of bonuses,
            royalties and rents from oil and gas development; and

                 WHEREAS:     Opening the ANWR oil range to further exploration, development and
            production will generate increased eMloyment and        business opportunities for all
            Americans:

                 THEREFORE, BE IT RESOLVED THAT the Greater Ketchikan Chamber of Commerce strongly
            urges the Congress of the United States of America to open the ANWR oil range to environ-
            mentally responsible oil and gas exploration, development and production.

                 DATED at KErCHIKAN, ALASKA this 18th day of                1986.

            JolvCYark
            President
            Greater Ketchikan Chamber of Commerce
            P.O. Box 5957
            Ketchikan, AK 99901
                                                                               Aim

                                                      e 00e

                                                                 E CHAMBFR

                                                                                                             Page  Two
                                                                                                             ANUR  Resolution

                                               ADOPTED

                                               by the
                                         BOARD OF TRUSTEES                                                   National Security and economic stabi  Ility depend on sufficient  ongoing
                                                                                                             quantities of domestic oil production.- Increased domestic oil product
                                               of the                                                        can minimize the possibility of economic disruption due to dependence on
                                                                                                             foreign oil and help towards decreasing the notion's trade-deficit.
                               GREATER SEATTLE CHAMBER OF  COMMERCE                                          Presently. one-third of the trade deficit is caused by the purchase of
                                                                                                             foreign oil and according to the Department of the Interior's report.
                                         January 13, 1986                                                    contributions from the Coastal Plain would save $8.1 billion in the year
                                                                                                             2005 on the cost of imported oil.

                                                                                                             In addition to the national Interest in providing for future energy
            The Greater Seattle Chamber of Commerce   supports opening the  Arctic                           needs. the opening of the Coastal Plain could represent billions of
            National Wildlife Refuge's Coastal Plain to environmentally responsible                          dollars in business opportunities for the private sector.
            oil and gas exploration, development and production.
                                                                                                             During the past fifteen years. Alaska's petroleum industry has
            BACKGROUND                                                                                       demonstrated its ability to operate on the North Slope in a safe,
                                                                                                                   nelhi . ...... .4 V hn...
                                                                                                             respo                        .'g-'*!cant adverse environmental impact.
            When Congress passed the Alaska National Interest Lands Conservation Act
            of 1980, it in effect "locked up"   8pproximately 19 million acres of land                       This decision has come after reading the material available. Inviting
            now known as the Arctic National W,   16 life Refuge (ANWR) by designating                       and hearing the Resource Development Council :Inc. present the case for
            It a'wilderness area. At the sametime- Congress commissioned the                                 opening the Coastal Plain to oil and gas exploration and development,
            Department of Interior to evaluate the i.5 million acre Coastal Plain                            inviting and hearing the Sierra Club present the case for closing the
            for Its oil and gas potential and for the effect of oil and gas                                  Coastal Plain to oil and gas exploration. and reading the United States
            exploration and development on the environment. The five year study was                          Department of Interior's report concerning the Coastal Plain of ANWR.
            released November 24, 1986..recommending Congress enact legislation
            making the Coastal Plain available for oil and gas leasing andauthorize                          Opening ANUR's coastal plain to oil and gas exploration and development
            the Secretary of the Interior to impose appropriate measures to protect                          is supported by the U.S. Department of the Interior, the U S. Department
            .refuge resources. The Coastal Plain is regarded by geologists is the                            of Fish and Wildlife. Alaska Oil and Gas Exploration. Alasia State
            most promising area for major discoveries of.oll and gas In North                                Cna'mber of Commerce. Resource Development Council for Alaska, Inc..
            America.   Published estimates indicate potential reserves which could   be                      Arctic Slope Regional Native Corporation, and the Interstate Oil Compact
            as great as Prudhoe Bay and the Kuparuk fields.     (Prudhoe Bay oil                             Commission.
            @eserves are declining.   Lead times from discovery to.first production
            are long In Alaska--at least 10-15 years.)
            During the coming months.  the U.S. Co ngress will decide whether the
            Coastal. Plain.Should be opened.to oil and*gas exploration, development
            and production or preserved as a wilderness area. Opening the Arctic
            National Wildlife Refuge Coastal Plain to.onviro"mentally responsible
            oil and gas development is not just a state of Alaska issue.; It is a
            national issue that must be decided In Washington. D.C.. and the outcome
            could have substantial economic impact.

                                                           INT or-W U@_ Y. 5 @Z

                                                                                                          ANWR s Coastal Plain
            Page Three
            ANWR Resolution

            OPPOSITION

            The decisions to be made about opening the ANWR Coastal Plain to
            explorat0 ry drilling and potential petroleum development are
            controversial. The Sierra Club. Defenders of Wildlife. The Natural                                                           ARCTIC
            Resources Defense council. the Trustees for Alaska, and the Northern                                                                NATIONAL
            Alaska Environmental Center feel that if oil is found, pressure will
            build to develop the rest of the refuge. These organizations say that                                                                         WILDLIFE
            exploration on the 1.5 million-acre   refuge would disrupt the porcupine.
            caribou herd estimated at between 160,000 and 200.000. This area Is
            where they Dreed and calve. Opponents fear the herd will diminish if                                                                                    REFUGE
            their Calving grounds are developed and want the Coastal Plain added to
            the 19 million acre wildlife refuge and preserved as an untouched area
            for arc,Ic wildlife.

            Opponents Claim the situation of the central herd is different from the
            porcupine herd. so it is not possible to make good extrapolations about
            what might happen to the herd if ANWR is opened for oil and gas
            exploration.   The secretary's reports state that the Central Arctic
            caribou herds have increased from 3,000 in 1972 to over 13,000 in 1986.
            While Circumstances are somewhat different between Prudhoe Bay and the
            Coastal Plain, this evidence of responsible oil development Concurrent
            with increased wildlife activity at Prudhoe Bay leads them to be quite
            optimiStic about oil development In the Coastal Plain without
            significant negative effects on the wildlife resources.                                                ALASKA
            IMPLENENTATION

            Upon approval of the recommendation, communication will be forwarded to
            each member of Washington's congressional delegation urging their
            support of the opening of the coastal plain of Alaska's Arctic National
            Wildlife Refuge to environmentally responsible of) and gas exploration,                                  01
            development and production.                                                                            CP

                                                                                                                                               ARCTIC NATIONAL WILDLIFE REFUGE
                                                                                                                                               (ANWR) - 19 Million Actilis

                                                                                                                                               ANWR COASTAL PLAIN
                                                                                                                                               Section 1002 Study Aina - 15 Million Acies
                                                                                                                                               KAKTOVIK INUPIAT CORPORATIONIARCTIC SLOPE
                                                                                                                                               REGIONAL CORPORATION LANDS

                                                           RL(;LIVL-U ULL I   Mb

                                                                                                                            RESOLUTION ON THE ANWR OIL RANGE

                                                      December 10, 1986                                   WHEREAS,  Alaska's Arctic   National Wildlife Refuge includes more
                                                                                                                    than 18 million   acres of land, amounting to approximate-
                                                                                                                    ly five percent   (5%) of the entire state landmass; and
                                                                                                          WHEREAS,  approximately eight percent (8%) of the refuge, known as
                                                                                                                    the ANWR oil range, is considered to be highly prospec-
                Throughout 1986, the Port of Tacoma    has taken major    steps                                     tive for the discovery of large quantities of oil and
                to increase its visibility and involvement with Alaska.                                             gas, and
                With both Sea-Land and Totem Ocean Trailer Express (TOTE)
                serving the Alaska trade from Tacoma (along with TOTE's new                               WHEREAS,  Congress  must decide in the near future if the 1.5 mil-
                barge service, Alaska Barge Lines) the Port of Tacoma has                                           lion acre oil range will be opened to further explora-w
                become the New Gateway to Alaska, handling over 65% of all                                          tion, development and production; and
                waterborne commerce to the State.
                                                                                                          WHEREAS,  the petroleum industry has consistently demonstrated its
                However, our interest and commitment to Alaska go fir                                               ability to operate in conditions similar to those found
                beyond our shipping lines. We realize that the economies                                            on the oil range in a safe responsible manner without
                and futures of Washington and Alaska have.a great deal in                                           significant adverse environmental impacts;4nd
                common. That's why we established a "Partner Port"
                relationship with the Port of Anchorage in September.                                     WHEREAS,  the United States must prepare to develop domestic pe-
                That's why a team of Port Commissioners and staff attended                                          troleum resources if it is to preclude overwhelming
                the Alaska State Chamber of Commerce Convention in Fair-                                            dependence.on foreign petroleum sources in the 21st cen-
                banks in October. We were there to talk, and we were there                                          tury; and
                to listen. And the clear message we received, time and
                time again, was that the Arctic National Wildlife Refuge                                  WHEREAS,  the value and development potential of state-owned tide@
       9.
       ZS       (ANWR) issue would be a key political issue for not onl                                             lands and federally-owned OCS lands offshore of the ANWR
                Alaska, but also for the entire United States during 19
        -4                                                                    187.                                  oil range.are dependent upon a Congressional decision to
                                                                                                                    open the oil range to further exploration, development
                I am pleased to tell you that on December     1, 1986, the    Port                                  and production; and.
                of Tacoma Commission officially adopted a      resolution'urging
                Congress to open up the coastal plain of ANWR to environ-                                 WHEREAS,  facilities developed to transport petroleum resources on
                mentally responsible oil and gas exploration, development                                           the oil range to Pump Station One may allow marginal
                and production.                                                                                     discoveries between the ANWR oil range and Prudhoe Bay
                We have a Iready started working w  .IIth our local media to                                        to be developed; and
                educate them on  this important matter, and we are also                                   WHEREAS,  national energy security depends.on'the development of
                working to let our elected, officials in Washington State                                           domestic oil and gas resources to replace depleted U.S.
                know just how important this issue is for the future of our                                         reservesi, and
                State. We will be expanding these efforts duriity 1S87.
                                                                                                          WHEREAS,  the nation stands to derive revenues including portions
                I believe the ANWR issue helps illustrate how closely the                                           of bonuses, royalties and rents from oil and gas
                future of Alaska and Washington are tied together, and                                              development; and
                gives us an excellent opportunity     to work together,to
                improve that future.                                                                      WHEREAS,  the Port  .of Tacoma Is the.New.Gateway to Alaska, ban-
                                                      S c                                                           dling over 65% of all waterborne commerce to Alaska; and
                                                                                                          WHEREAS,  the Port of Tacoma is a Partner Port of the Port of An-
                                                                                                                    chorage, and is working to cooperate on areas of mutual
                                                       d Koo                                                        interest; and
                                                      Director, Part Relations
                                                                                                          WHEREAS,  the continued economic growth and development of Alaska
                                                                                                                    is important to the continued growth and development of
                                                                                                                    Tacoma and Washington State; and
                                                  4d *KooL

                                                                              Ae
                PQ Oak 1837 - TacWa WadwQWn 98401 TdM*- 9M 3EMS841 rM 910-441-2646'TL x 32-7473
                              G E w:,@ J,.-,, i- Fatul,cn - J,)-; EJ

             Resolution on the ANTR Oil Range
             December 1, 1986 Port of Tacoma Commission Meeting
             Page Two

             WHEREAS, numerous businesses in the Tacoma-Pierce County area
                      have major markets in Alaska; and
             WHEREAS, the Port of Tacoma has ample area available for module
                      construction work; and

             WHEREAS, opening the ANWR oil range to further exploration,
                      ,development and production is expected to generate con-
                      struction, shipping and business opportunities for the
                      Port of Tacoma, the entire Tacoma-Pierce County region,
                      and the State of Washington;
             BE IT THEREFORE RESOLVED THAT THE PORT OF TACOMA COMMIS  'SIONERS
             strongly urge the Congress of the United States to open the ANWR
             oil range to environmentally responsible oil and gas exploration,
             development and production.
             ADOPTED by the Commission of the Port of Tacoma at its regular
             meeting held on the lst day of December, 1986, a majority of the
             members of the Port Commission being present and attested-by its
             Secretary under the official seal of said Commission in authen-
             tication of its passage this lst day of December, 1986.

             President of-the Port Commission,
             Port of Tacoma

             ATTEST:

             Secretary of the Port Commission,
             Port of TAcoma
                                               swoYad4we M&ww

                                                                                                                                   Page two

                                                                                                                                   The four issues identified in the early debate have these comments:

                                                                                                                                             National security and economic stability depend on sufficient
                     December, 1986                                                                                                          ongoing quantities of domestic oil production.     Remember the
                                                                                                                                             0
                                                                                                                                             11 embargo? The whole oil Industry has had an impact on
                                                                                                                                             1
                                                                                                                                             the Port of Tacoma, in employing plumbers. pipefitters, long-
                                                                                                                                             shoremen and others involved in shipments to Alaska.
                     Resolution
                     to the                                                                                                                  ANWR's oil potential is huge. The Coastal Plain is America's
                     Board of Directors                                                                                                      best prospect for new discoveries of domestic petroleum to
                     of the                                                                                                                  replace dwindling supplies.
                     ,Tacoma-Pierce County Chamber of Commercp
                                                                                                                                             The environmental record in Arctic Alaska provides positive
                     from the
                     Alaska Committee                                                                                                        proof than sensible development can coexist harmoniously with
                                                                                                                                             wildlife. The Issues have been identifiedand successfully
                                                                                                                                             dealt with in the development of Prudhoe Bay end the constr-
                     SUBJECT: Arctic National Wildlife Refuge     (ANXR) Oil    Gas Exploration,                                             uction of the Trans-Alaska pipcline.
                     etc.                                                                                                                    The caribou of the Central Arctic Herd calve and spend their
                     POLiCY: The Chamber supports opening the     AN47 Coastal Plain to environ-                                             summers on the coastal plain of Alaska--in the Kuparuk and Milne
                     mentally responsible oil and gas exploration. development and production.                                               Point (Prudhoe Bay) oil fields. There's every reason to believe
                                                                                                                                             the Porcupine Caribou Herd, whose summer range Includes the
                     BACKGROUND: Virtually every state has experienced.the economic benefits                                                 Coastal Plain of ANWR, would likewise adapt and prosper.
                     of oil production from Alaska's North Slope, especially Washington and                                        IMPLEMENTATION: Inform our Congressional delegation of the Chamber
                     particularly Tacoma. But future jobs will depend on new discoveries of
                     oil, since the major planned facilities are now In place. -In addition                                        position and our reasons for that position.      Work to develop media reco-
                     to the money federal government receives fro-_ petroleum lease bonuses.                                       gintion of the importance of ANWR development on the local economy. Work
                     rentals, rov tie  s and excise and income taxeSe the all industry                                             to develop coalitions for support of ANWR development.
                     has spent moa!
                                 r than $25 billion in North Slope development In goods
                     and services purchased In all 50 states during the last five years.

                     Specific benefits to Tacoma from further oil exploration and development
                     include:

                           - Increased tonnage through the Port ofTacoma, and therefore
                             revenues to the Port. TOTE and Sea@Land together ship over
                             65 percent of all waterborne freight to Alaska.

                           - Manufacturing and construction of modules used     in oil re-
                             covery would provide jobs at Parsons In Tacoma. Parsons
                             supplied the North Slope modules during Prudhoe Bay dev-
                             elopment. The last major steplift left this summer (1986).

                           - Indirect benefits through employment and manufacture
                             of secondary products used for oilrecovery.

                     The ANWR Coastal Plain is 8 percent of more than 18 million      acres
                     of wildlife refuge.

                     Congress this year will decide whether It is in the national interest
                     to open the Coastal Plain to exploration or to close off the      area as
                     wilderness. Representative Harris Udell (D@A2) has promised       to intro-
                     duce legislation to designate ANWR as protected wilderness.       A Depart-
                     ment of Interior study released November 23. 1986, termed the Coastal
                     Plain "the most outstanding frontier oil sne gas area in the U.S."

                              RESOLUTION ON THE ANWR OIL RANGE

            WHEREAS,  Alaska's Arctic National Wildlife Refuge   includes more
                      than 18 million acres of land, amounting   to approximately
                      five percent of the entire state landmass; and

            WHEREAS,  approximately eight percent of the refuge, known as the
                      ANWR oil range, is considered to be highly prospective for
                      the discovery of large quantities of oil and gas: and

            WHEREAS,  Congress must decide in the near future if the 1.5 million
                      acre oil range will be opened to further exploration,
                      development and production; and
            WHEREAS,  the petroleum industry has consistently demonstrated its
                      ability to operate in conditions similar to those found.on
                      the oil range in a safe, responsible manner without
                      significant adverse environmental impactsl and

            WHEREAS,  the United States must prepare to.develop domestic
                      petroleum resources if it is to preclude overwhelming
                      dependence on foreign petroleum sources in the 21st
                      century; and
            WHEREAS,  the value and development potential of state-owned
                      tidelands and federally-owned OCS lands offshore of the
                      ANWR oil range are dependent upon a Congressional decision
                      to open the oil range to further exploration, development
                      and production; and

            WHEREAS,  facilities developed to transport petroleum resources on
                      the oil range to Pump Station One may allow marginal
                      discoveries between the ANWR oil range and Prudhoe Bay to
                      be developedl and
            WHEREAS,  national energy security depends on the development of
                      domestic oil and gas resources to replace depleted U.S.
                      reservesi and
            WHEREAS,  the nation stands to derive revenues including portions of
                      bonuses, royalties and rents from oil and gas development;
                      and

            WHEREAS,  opening the ANWR oil range to further exploration,
                      development and production will generate increased
                      employment and business opportunities for all Americans;

            THEREFORE BE IT RESOLVED THAT Seward Chamber of Commrce       strongly
            urges the Congress of the United States to open the ANWR oil range
            to environmentally responsible oil and gas exploration, development
            and production.

                     OF #.'.%
                        V..  LLS. Chamber of Commerce
                             1615H SL,NW
                             VftWngftn. 13C 20062

                             News Deptutnerd (202) 463-5682

               FOR IMMEDIATE RELASE                                 Contact: Frank Benson

                             U.S. CHN4BER'S  BOARD URGE$ CONGRESS TO PERMIT
                             EXPLORATION OF  ALASKAN ARCTIC WILDLIFE REFUGE

                        WASHINGTON, Nov. 13  -- Publicly owned lands that may be among
               the nation's richest sources  of oil and natural gas should receive
               Congressional exploration approval, and efforts to close off the area
               permanently to future exploration and development should be rebuffed. the
               U.S. Chamber of Commerce stated today.
                        The Chamber's policy-setting board of directors, at Its
               regularly scheduled fall meting here this week, called for Congress to
               enact legislation to determine the extent of reserves in Alaska's Arctic
               National Wildlife Refuge (ANWR). Such lands were withdrawn from
               exploration and development with enactment of the 1980 Alaska National
               Interest Lands Conservation Act, which provided that Congress must
               specifically authorize any drilling in ANWR's coastal plains.
          L
                        That area may contain more oil and gas reserves than Alaska's
               Prudhoe Bay area, and many consider the coastal plain as containing one
               of the nation's most promising areas for new domestic reserves of crude
               oil. In light of such a potential, the Chamber's.board decided, Congress
               should authorize exploratory efforts to ascertain the extent of the
               rescrves 3nd should reject efforts to declare the entire coastal plain as
               wilderness and permanently off-limits for any exploratory or producing
               efforts.
                        Acting on recommendation of the business federation's 22-nember
               Natural Resources Committee, the Chamber's board declared that finding
              .new domestic reserves of oil and natural gas is critical to reducing the
               nation's dependency on imports -- up 37 percent from last year -- and to
               curbing the country's foreign trade deficit of which one-third represents
               payments for foreign oil products.

                                                  fit##
                                                                                     86-204

    					Alaska State Legislature

    						Senate

    September 30, 1986

    Ms. Joy Clark, President
    Greater Ketchikan Chamber of Commerce
    Box 5957
    Ketchikan, Alaska 99901

    Dear Joy:

    When Paula and I returned from a legistlative conference the
    latter part of last week, I found your ANWR resolution.
    Coincidentally, at the Western Legislatvie Conference meeting.
    I cosponsored a similar resolution which passed the conference
    rather handily at its business meeting.

    Your might consider having me (or Lloyd Jones, as the case may
    be), try to pass a similar resoultion through the State
    Legislature comes January.

    Regards,

    Robert H. Ziegler, Sr.

    DO YOU WANT TO MAKE PUBLIC COMMENTS?

    If you would like to speak at the hearing today, please fill in the blanks
    below and turn it in to one of the Fish and Wildlife Staff members present.
    You need not complete this sheet to submit written comments.  Thank you.

    Please print

    Name

    Mailing Address

    Check appropriate box below:

    	I am here to offer my own views.
    			or
    	I am speaking for Resource Development Council
                            (please enter name of organization you represent)

    Resource Development Council
    for Alaska, Inc.

    											207 "G" Street, Suite _ 0_, Anchorage, Alaska 9950_-_ _ _ _
    											Box 108516, Anchorage, Alask 395_ _-_ _ _ _ - 907/276-_ _ _ _

    					DRAFT TESTIMONY OF THE RESOURCE DEVELOPMENT COUNCIL

    						ENVIRONMENTAL IMPACT STATEMENT
    					"ARCTIC NATIONAL WILDLIFE REFUGE, ALASKA,
    						COASTAL PLAIN RESOURCE ASSESSMENT"

    							ANCHORAGE, ALASKA
    							JANUARY 5, 1987

    GOOD MORNING.  I AM BOYD BROWNFIELD, PRESIDENT OF THE RESOURCE

    DEVELOPMENT COUNCIL FOR ALASKA, INC. (RDC).  RDC IS A PRIVATE

    STATEWIDE ECONOMIC DEVELOPMENT ORGANIZATION COMMITTED TO THE

    ORDERLY DEVELOPMENT OF ALASKA'S RESOURCES.  THE BROADLY BASED

    MEMBERSHIP OF OUR COUNCIL COMES FROM A WIDE RANGE OF ECONOMIC,

    SOCIAL.  GEOGRAPHIC AND ETHNIC SECTORS OF ALASKA.  OUR MEMBERSHIP

    REPRESENTS INDIVIDUALS, COMPANIES TRADE ASSOCIATIONS, NATIVE

    CORPORATIONS, UNIVERSITIES, CHAMBERS OF COMMERCE, AND

    MUNICIPALITIES THROUGHOUT THE STATE.

    THE RESOURCE DEVELOPMENT COUNCIL STRONGLY SUPPORTS THE OPENING OF

    THE COASTAL PLAIN OF THE ARCTIC NATIONAL WILDLIFE REFUGE TO OIL

    AND GAS EXPLORATION AND PRODUCTION.  THERE ARE MANY GOOD REASONS

    WHY THE OPENING OF EIGHT PERCENT OF THE REFUGE TO OIL AND GAS

    LEASING IS IN THE NATIONAL INTEREST

    DEVELOPMENT OF WORLD-CLASS OIL DEPOSITS IN THE REFUGE PROPOSED FOR

    LEASING WOULD PROMOTE ECONOMIC DEVELOPMENT, REDUCE OR DEPENDENCE

    ON FOREIGN OIL, PROMOTE ORDERLY DEVELOPMENT IN THE ABSENCE OF AN

    ENERGY CRISIS, INCREASE REVENUES FROM TAXES AND ROYALTIES,

             PACE 2                                                                                     PAGE 3

             STRENGTHEN NATIONAL SECURITY INTERESTS. RESTRAIN THE NATIONAL                              WORLD-CLASS DOMESTIC SUPPLY OF OIL IS 1-1 THT] COASTAL PLAIN OF

             TRADE DEFICIT AND CREATE THOUSANDS OF NEW JOBS.                                            AAWR-

             WE MUST NOT BE BLINDED BY A TEMPORARY OIL GLUT. BEFORE TOO LONGp                           SOME PEOPLE CLAIM THAT DEVELOPMENT OF THE COASTAL PLAIN ISN'T

             AMERICA COULD BE FACING AN ENERGY CRISIS OF UNHATCHED PROPORTIONS.                         WORTH THE EFFORT SINCE THE 1002 REPORT ESTIMATES THAT THERE IS

                                                                                                        ONLY A 19 PERCENT CHANCE OF FINDING ECOONICALLY RECOVERABLE OIL.

             ALTHOUGH THERE IS PLENTY OF OIL ON THE MARKET TODAY, DOMESTIC OIL                          THOSE WHO CARE ABOUT OUR NATIONAL SECURITY AND ENERGY NEEDS THINK

             'RESERVES ARE PLUMMETING WHILE CONSUMPTION IS RISING. RELIABLE                             -IT IS WORTH THE EFFORT    NINETEEN PERCENT ODDS ARE TEN TIMES

             SOURCES INDICATE THAT U.S. OIL IMPORTS COULD RISE DRAMATICALLY                             HIGHER THAN THE INDUSTRY'S SUCCESS RATE IN ALASKA, YET LOOK AT ALL

             FROM ABOUT 27 PERCENT OF DOMESTIC CONSUMPTION IN 1985 TO OVER 6o                           THE OIL PRODUCED FROM THIS STATE. ONLY 2 PERCENT OF THE WELLS

             PERCENT IN EIGHT YEARS.                                                                    DRILLED IN ALASKA HAS EVER RESULTED IN A MAJOR DISCOVERY.

             PRUDHOE BAY, AMERICA'S LARGEST OIL FIELD, ACCOUNTS FOR 20 PERCENT                          THE QUESTION BEFORE US TODAY IS NOT A WILDERNESS VERSUS NO
             OF U.S. DOMESTIC CRUDE PRODUCTION. HOWEVER, IT HAS 'ALREADY BEEN                           WILDERNESS ISSUE. THERE ARE ALREADY 8 MILLION ACRES OF DESIGNATED

             PUMPED HALF EMPTY AND A STEADY DECLINE IN PRODUCTION WILL SOON                             WILDERNESS IN ANWR. THE 1.5 MILLION ACRE COASTAL PLAIN COMPRISES
             BEGIN.                                                                                     -ONLY EIGHT PERCENT OF THE REFUGE. MOREOVER, 92 PERCENT OF THE

                                                                                                        REFUGE IS OFF-LIMITS TO OIL AND GAS DEVELOPMENT. SHOULD THE
             IT IS IMPERATIVE THAT WE LOOK FOR OIL IN ANWR NOW BECAUSE                                  REMAINING EIGHT PERCENT BE CLOSED TO OIL AND GAS DEVELOPMENT, THE

             DEVELOPING OIL FIELDS IN ALASKA REQUIRES LEAD TIMES OF 10     TO 15                        POTENTIAL LOSSES TO OUR NATIONAL ENERGY POSITION VILL BE

             YEARS FROM DISCOVERY TO FIRST PRODUCTION. ASSUMING A MAJOR FIELD                           INCALCULABLE WHILE THE "GAINS" WOULD AMOUNT ONLY TO A SLIGHT

             IS DISCOVERED ON THE COASTAL PLAIN TODAY, FIRST PRODUCTION WOULD                           INCREASE IN THE AMOUNT OF DESIGNATED WILDERNESS LANDS IN ALASKA,

             NOT BE LIKELY BEFORE THE YEAR 2000.                                                        WHICH ALREADY ARE LARGE ENOUGH TO CONSUME THE ENTIRE STATE OF

                                                                                                        UTAH.

             IF AMERICA FORGOES OR DELAYS THIS MAJOR OPPORTUNITY TO REVERSE ITS

             INCREASING DEPENDENCY ON FOREIGN OIL, OUR VULNERABILITY TO OIL                             NOR IS THE ISSUE BEFORE US ONE OF ENVIRONMENTAL VALUES VERSUS OIL

             PRICE SHOCKS AND OIL SHORTAGES VILL INCREASE TO DANGEROUSLY HIGH                           AND GAS DEVELOPMENT. WE CONCUR WITH THE REGULATORY AGENCIES AND

             LEVELS IN THE NEXT DECADE. THE BEST WAY TO ASSURE THAT THE UNITED                          INDUSTRY THAT MOST ADVERSE EFFECTS WOULD BE MINIMIZED OR ELMINATEr

             STATES WILL HAVE SECURE SUPPLIES OF OIL IS TO PURSUE EXPLORATION                           THROUGH CAREFULLY APPLIED MITIGATION, USING LESSONS LEARNED AND
             AND DEVELOPMENT HERE AT HOME. AND THE BEST CHANCE TO FIND A NEW                            STATE-OF-THE-ART TECNOLOGY ACQUIRED FROM DEVELOPMENT AT OTHER

              PAGE 4                                                                                    PAGE 5
              NORTH SLOPE OILFIELDS.                                                                    WE BELIEVE TilAT WHEREVEit POSSIBLE. EVERY STATE HAS A

                                                                                                        RESPONSIBILITY -10 WORK ON THIS STAGSERING DEFICIT.    ANWR   COULD
                                                                                                        PROVIDE ALASKA WITH A SIGNIFICANT OPPORTUNITY TO RESTRAIN     THIS
              APPLICATION OF FORTY YEARS OF ENGINEERING EXPERIENCE IN ARCTIC
              ALASKA CULMINATING IN DEVELOPMENTS ON THE NORTH SLOPE DEMONSTRATE                         DEFICIT. HOWEVER, IF A DECISION WERE MADE TO DESIGNATE THE
              THAT OIL DEVELOPMENT CAN AND DOES EXIST IN HARMONY WITH THE                               COASTAL PLAIN WILDERNESS, WE WOULD IN EFFECT BE CHOOSING TO
              ENVIRONMENT. WILDLIFE POPULATIONS ARE THRIVING IN CONJUNCTION WITH                        INCREASE OUR DEPENDENCY  .ONOIL IMPORTS, ADDING TO OUR AWESOME
              INDUSTRIAL DEVELOPMENT AT PRUDHOE BAY, KUPARUK AND MILNE POINT.                           TRADE DEFICIT, RATHER THAN SUBTRACTING FROM IT.

                                                                                                        RDC WILL RESPOND TO SPECIFIC ELEMENTS IN THE 1002(H) REPORT IN
              HOWEVER, SOME PEOPLE ARGUE THAT PRUDHOE BAY IS NOT COMPARABLE TO,
              THE COASTAL PLAIN OF ANWR IN TERMS OF POTENTIAL IMPACTS.                                  MORE DETAILED WRITTEN COMMENTS TO BE SUBMITTED. WE DO WISH TO
                                                                                                        POINT OUT HERE THAT MANY OF THE ENVIRONMENTAL IMPACTS INDICATED IN
              WE BELIEVE THE SMALL LOSS OF HABITAT REPRESENTED BY DEVELOPMENT IN                        THE REPORT APPEAR TO BE BASED ON nWORST CASE" EVALUATIONS. WE
              THE 1002 AREA WILL NOT IMPACT GROWTH   OR PRODUCTIVITY OF CARIBOU.                        RESPECTFULLY CALLTO YOUR kTTENTION THAT NEPA-EIS GUIDELINES HAVE
              HABITAT IS NOT gURRENTLY PREVENTING    THE GROWTH OF THE PORCUPINE                        BEEN CHANGED FROM "WORST CASE" ASSESSMENT TO "MOST LIKELY TO
              HERD SINCE THE- HERDIS LARGE, POPULATION HAS REMAINED FAR BELOW THE                       OCCUR." WE DO APPRECIATE. HOWEV   ERt THAT THE RECOMMENDATIONS OF
              CARRYING CAPAC ITY OF THE COASTAL PLAIN. A SMALL REDUCTION IN                             THE SECRETARY OF THE INTERIOR REFLECT WHAT IS "MOST LIKELY To
              TOTAL RANGE SHOULD NOT SIGNFICANTLY ALTER THE HERD'S POPULATION.                          OCCUR."

              GIVEN EXISTING TECHNOLOGY, COUPLED WITH THE POTENTIAL SIZE OF ANY
              ANTICIPATED DISCOVERY, DEVELOPMENT IN THE REFUGE WOULD COMPRISE AN                        DUE TO TKE "WORST CASE"  BIAS, WE REQUEST THAT THOSE IMPACTS BASED
              EXTREMELY SMALL PORTION OF THE COASTAL PLAIN EVEN UNDER THE MOST                          ON A HIGHLY SPECULATIVE   NATURE BE CLARIFIED AS SUCH THROUGHOUT THE
              OPTIMISTIC PRODUCTION SCENARIO.                                                           ENVIRONMENTAL CONSEQUENCES SECTION. THIS WILL ALLOW AND HOPEFULLY

                                                                                                        ENSURE THAT THOSE READING THE DOCUMENT ARE AWARE OF THE

              A MAJOR DISCOVERY IN ANWR WOULD SIGNIFICANTLY REDUCE OIL IMPORTS,                         HIGHLY-SPECULATIVE  NATURE OF THOSE  IMPACTS.

              THEREBY CUTTING THE NATIONAL TRADE DEFICIT. THE $90 BILLION WE
              NOW PAY FOR IMPORTED OIL IS THE LARGEST SINGLE ELEMENT IN THE                             IN CLOSING, WE WOULD LIKE TO CLEAR UP A MISCONCEPTION    FOR THE
              TRADE DEFICIT, WHICH SURGED TO A RECORD $19.2 BILLION IN NOVEMBER                         RECORD. ONE IS THE MISLEADING VIEWPOINT THAT THE RESERVE
              ALONE. 1986 WAS BY FAR THE WORST YEAR EVER FOR THE NATION'S TRADE                         POTENTIAL OF THE COASTAL PLAIN MAY BE TOO SMALL TO JUSTIFY
              ACCOUNTS. FOR THE FIRST 11 MONTHS OF THE YEAR, AMERICANS IMPORTED                         LEASING.  IT MUST BE REMEMBERED THAT TOTAL. PRODUCTION FROM   . PRUDHOE
              $159 BILLION MORE THAN THEY EXPORTED.                                                     BAY ACCOUNTS FOR 18 MONTHS SUPPLY OF OIL TO AMERICA. NOTABLY OUR

                 PAGE 6

                 NATION' @IAS ONLY A FIVE YEAR SUPPI-Y OF DOf':::lrI-'-'   KliNG

                 PU14PED AT TOTAL PRODUCTION.  UNDER THIS BAS13. THE CUASTAL PLAIN

                 FIELDS MAY CONTAIN ONLY A FEW YEARS SUPPLY OF OIL. HOWEVER, IN

                 REALITY, ALL OF THIS IS TRUE ONLY IF THE FIELD IS FULLY PRODUCED

                 ALL AT ONCE. NO COMMERCIAL FIELD IN THE WORLD CAN BE FULLY

                 PRODUCED AT ONCE. FOR EXAMPLE, PRUDHOE BAY MAY PRODUCE OIL AND

                 GAS FOR 30 YEARS, EVEN THOUGH ITS TOTAL PRODUCTION WOULD SUPPLY

                 THE NATION FOR ONLY ONE AND A HALF YEARS. CONSISTENT PRODUCTION

                 FROM PRUDHOE BAY COULD OFFSET ABOUT 13 PERCENT OF FOREIGN OIL

                 IMPORTS FOR 30 YEARS.

                 AMERICA SHOULD  NOT FORECLOSE ON HER OPPORTUNITY TO INVENTORY AND

                 DEVELOP STRATEGIC PETROLEUM RESERVES AFTER SPENDING BILLIONS OF

                 DOLLARS ADVANCING THE LEARNING CURVE IN THE ARCTIC. WE CAN BE

                 PROUD OF THAT ADVANCE. WE HAVE THE WORK FORCE TRAINED AND

                 WAITING. LET'S DO IT RIGHT ONCE AGAIN.

    Resource Development Council
    for Alaska, Inc.
    										_ _ _ "G" Street, Suite _ _ _, Anchorage, Alaska _ _ _ _ _-_ _ _ _
    										Box _ _ _ _1_, Anchorage, Alaska 995_ _-_ _ _ _ - _ _ _/_ _ _-_ _ _ _

    					ORAL TESTIMONY OF THE RESOURCE DEVELOPMENT COUNCIL

    						ENVIRONMENTAL IMPACT STATEMENT
    					"ARCTIC NATIONAL WILDLIFE REFUGE, ALASKA,
    						COASTAL PLAIN RESOURCE ASSESSMENT"

    							WASHINGTON, D.C.
    							JANUARY 9, 1987

    THE RESOURCE DEVELOPMENT COUNCIL FOR ALASKA, INC. (RDC) IS A

    PRIVATE STATEWIDE ECONOMIC DEVELOPMENT ORGANIZATION COMMITTED TO

    THE ORDERLY DEVELOPMENT OF ALASKA'S RESOURCES.  THE BROADLY BASED

    MEMBERSHIP OF OUR COUNCIL COMES FROM A WIDE RANGE OF ECONOMIC,

    SOCIAL, GEOGRAPHIC AND ETHNIC SECTORS OF ALAKS.  OUR MMEMBERSHIP

    REPRESENTS INDIVIDUALS, COMPANIES, TRADE ASSOCIATIONS, NATIVE

    CORPORATIONS, UNIVERSITIES, CHAMBERS OF COMMERCE, AND

    MUNICIPALITIES THROUGHOUT THE STATE.

    THE RESOURCE DEVELOPMENT COUNCIL STRONGLY SUPPORTS THE OPENING O_

    THE COASTAL PLAIN OF THE ARCTIC NATIONAL WILDLIFE REFUGE TO OIL

    AND GAS EXPLORATION AND PRODUCTION.  THERE ARE MANY GOOD REASONS

    WHY THE OPENING OF EIGHT PERCENT OF THE REFUGE TO OIL AND GAS

    LEASING IS IN THE NATIONAL INTEREST.

    DEVELOPMENT OF WORLD-CLASS OIL DEPOSITS IN THE REFUGE PROPOSED F_

    LEASING WOULD PROMOTE ECONOMIC DEVELOPMENT, REDUCE OUR DEPENDENCE

    OF FOREIGN OIL, PROMOTE ORDERLY DEVELOPMENT IN THE ABSENCE OF AN

    ENERGY CRISIS, INCREASE REVENUES FROM TAXES AND ROYALTIES,

    PAGE 2

    STRENGTHEN NATIONAL SECURITY INTERESTS, RESTRAIN THE NATIONAL

    TRADE DEFICIT AND CREATE THOUSANDS OF NEW JOBS.

    WE MUST NOT BE BLINDED BY A TEMPORARY OIL _LUT.  BEFORE TOO LONG,

    AMERICA COULD BE FACING AN ENERGY CRISIS OF UNMATCHED PROPORTIONS.

    ALTHOUGH THERE IS PLENTY OF OIL ON THE MARKET TODAY, DOMESTIC OIL

    RESERVES ARE PLUMMETING WHILE CONSUMPTION IS RISING.  RELIABLE

    SOURCES INDICATE THAT U.S. OIL IMPORTS COULD RISE DRAMATICALLY

    FROM ABOUT 27 PERCENT OF DOMESTIC CONSUMPTION IN 1985 TO OVER 60

    PERCENT IN EIGHT YEARS.

    PRUDHOE BAY, AMERICA'S LARGEST OIL FIELD, ACCOUNTS FOR 20 PERCENT

    OF U.S. DOMESTIC CRUDE PRODUCTION.  HOWEVER, IT HAS ALREADY BEEN

    PUMPED HALF EMPTY AND A STEADY DECLINE IN PRODUCTION WILL SOON

    BEGIN

    IT IS IMEPRATIVE THAT WE LOOK FOR OIL IN ANWR NOW BECAUSE

    DEVELOPING OIL FIELDS IN ALASKA REQUIRES LEAD TIMES OF 10 TO 15

    YEARS FROM DISCOVERY TO FIRST PRODUCTION.  ASSUMING A MAJOR FIELD

    IS DISCOVERED ON THE COASTAL PLAIN TODAY, FIRST PRODUCTION WOULD

    NOT BE LIKELY BEFORE THE YEAR 2000.

    IF AMERICA FORGOES OR DELAYS THIS MAJOR OPPORTUNITY TO REVERSE ITS

    INCREASING DEPENDENCY ON FOREIGN OIL, OUR VULNERABILITY TO OIL

    PRICE SHOCKS AND OIL SHORTAGES WILL INCREASE TO DANGEROUSLY HIGH

    LEVELS IN THE NEXT DECADE.  THE BEST WAY TO ASSURE THAT THE UNITED

    STATES WILL HAVE SECURE SUPPLIES OF OIL IS TO PURSUE EXPLORATION

    AND DEVELOPMENT HERE AT HOME.  AND THE BEST CHANCE TO FIND A NEW

               PAGE 3                                                                                       PAGE 4
               WORLD-CLASS DOMESTIC SUPPLY OF OIL IS IN THE COASTAL PLAIN OF                                NORTH SLOPE OILFIELDS.

               ANWR.
                                                                                                            APPLICATION OF FORTY YEARS OF ENGINEERING EXPERIENCE IN ARCTIC
               SOME PEOPLE CLAIM THAT DEVELOPMENT OF THE COASTAL PLAIN ISN'T                                ALASKA CULMINATING IN DEVELOPMENTS ON THE NORTH SLOPE DEMONSTRATE
               WORTH THE EFFORT SINCE THE 1002 REPORT ESTIMATES THAT THERE IS                               THAT OIL DEVELOPMENT CAN AND DOES EXIST IN HARMONY WITH THE
               ONLY A 19 PERCENT CHANCE OF FINDING ECOOMICALLY RECOVERABLE OIL.                             ENVIRONMENT. WILDLIFE POPULATIONS ARE THRIVING IN CONJUNCTION WIT[
               THOSE WHO CARE ABOUT OUR NATIONAL SECURITY AND ENERGY NEEDS THINK                            INDUSTRIAL DEVELOPMENT.AT PRUDHOE BAY, KUPARUK AND MILNE POINT.

               IT IS WORTH THE EFFORT    NINETEEN PERCENT ODDS ARE TEN TIMES
               HIGHER THAN THE INDUSTRY'S SUCCESS RATE IN ALASKA, YET LOOK AT ALL                           HOWEVER, SOME PEOPLE ARGUE THAT PRUDHOE BAY IS NOT C014PARABLE TO
               THE OIL PRODUCED FROM THIS STATE. ONLY 2 PERCENT OF THE WELLS                                THE COASTAL PLAIN OF ANWR IN TERMS OF POTENTIAL IMPACTS.

               DRILLED IN ALASKA HAS EVER RESULTED IN A MAJOR DISCOVERY.
                                                                                                            WE BELIEVE THE SMALL LOSS OF HABITAT REPRESENTED BY DEVELOPMENT It
               THE QUESTION BEFORE US TODAY 13 NOT A WILDERNESS VERSUS NO                                   THE 1002 AREA WILL NOT IMPACT GROWTH OR PRODUCTIVITY OF CARIBOU.
               WILDERNESS ISSUE. THERE ARE ALREADY 8 MILLION ACRES OF DESIGNATED                            HABITAT Is NOT CURRENTLY PREVENTING THE GROWTH OF THE PORCUPINE
               WILDERNESS IN ANWR. THE 1.5 MILLION ACRE COASTAL PLAIN COMPRISES                             HERD SINCE THE HERDIS LARGE POPULATION HAS REMAINED FAR BELOW THE
               ONLY EIGHT PERCENT OF THE REFUGE. MOREOVER, 92-PERCENT OF THE                                CARRYING CAPACITY OF THE COASTAL PLAI.N. A SMALL REDUCTION IN
               REFUGE IS OFF-LIMITS TO OIL AND GAS DEVELOPMENT. SHOULD THE                                  TOTAL RANGE SHOULD NOT SIGHFICANTLY ALTER THE HERDIS POPULATION.
               REMAINING EIGHT PERCENT BE CLOSED TO OIL AND GAS DEVELOPMENT, THE                            GIVEN EXISTING TECHNOLOGY, COUPLED WITH THE POTENTIAL SIZE OF ANY
               POTENTIAL LOSSES TO OUR NATIONAL ENERGY POSITION WILL BE                                     ANTICIPATED DISCOVERY, DEVELOPMENT IN THE REFUGE WOULD COMPRISE Al
               INCALCULABLE WHILE THE ffGAINS" WOULD AMOUNT ONLY TO A SLIGHT                                EXTREMELY SMALL PORTION OF THE COASTAL PLAIN EVEN UNDER THE MOST
               INCREASE IN THE AMOUNT OF DESIGNATED WILDERNESS LAmos IN ALASKA,                             OPTIMISTIC PRODUCTION SCENARIO.
               WHICH ALREADY ARE LARGE ENOUGH TO CONSUME THE ENTIRE STATE 00
               UTAH.                                                                                        A MAJOR DISCOVERY IN ANWR WOULD SIGNIFICANTLY REDUCE OIL IMPORTS,

                                                                                                            THEREBY CUTTING THE NATIONAL TRADE DEFICIT. THE $90 BILLION WE
               NOR IS THE ISSUE BEFORE US ONE OF ENVIRONMENTAL VALUES VERSUS OIL                            NOW PAY FOR IMPORTED OIL Is THE LARGEST SINGLE ELEMENT IN THE
               AND GAS DEVELOPMENT. WE CONCUR WITH THE REGULATORY AGENCIES AND                              TRADE DEFICIT, WHICH SURGED TO A RECORD $19.2 BILLION IN NOVEMBER
               INDUSTRY THAT MOST ADVERSE EFFECTS WOULD BE MINIMIZED OR ELMINATED                           ALONE. 1986 WAS BY FAR THE WORST YEAR EVER FOR THE NATION'S TRAD
               THROUGH CAREFULLY APPLIED MITIGATION, USING LESSONS LEARNED AND                              ACCOUNTS. FOR THE FIRST 11 MONTHS OF THE YEAR, AMERICANS IMPORTE
               STATE-OF-THE-ART TECHOLOGY ACQUIRED FROM DEVELOPMENT AT OTHER                                $159 BILLION MORE THAN THEY EXPORTED.

                 PAGE 5                                                                                  PAGE 6
                 WE BELIEVE THAT WHEREVER POSSIBLE, EVERY STATE HAS A                                    NATION HAS ONLY A FIVE YEAR SUPPLY OF DOMESTIC RESERVES BEING
                 R&SPONSIBILITV TO WORK ON THIS STAGGERING DEFICIT. ANWR COULD                           PUMPED AT TOTAL PRODUCTION. UNDER THIS BASIS, THE COASTAL PLAIN
                 PROVIDE ALASKA WITH A SIGNIFICANT OPPORTUNITY TO RESTRAIN THIS                          FIELDS MAY CONTAIN ONLY A FEW YEARS SUPPLY OF OIL. HOWEVER, IN
                 DEFICIT. HOWEVER. IF A DECISION WERE MADE TO DESIGNATE THE                              REALITY, ALL OF THIS IS TRUE ONLY IF THE FIELD IS FULLY PRODUCED
                 COASTAL PLAIN WILDERNESS, WE WOULD IN EFFECT BE cHoo.simG TO                            ALL AT ONCE. NO COMMERCIAL FIELD IN THE WORLD CAN BE FULLY
                 INCREASE OUR DEPENDENCY ON OIL IMPORTS, ADDING TO OUR AWESOME                           PRODUCED AT ONCE. FOR EXAMPLE,, PRUDHO .E BAY MAY PRODUCE OIL AND
                 TRADE DEFICIT, RATHER THAN SUBTRACTING FROM IT.                                         GAS FOR 30 YEARS, EVEN THOUGH ITS TOTAL PRODUCTION WOULD SUPPLY

                                                                                                         THE NATION FOR ONLY ONE AND A HALF YEARS. CONSISTENT PRODUCTION
                 RDC WILL RESPOND TO SPECIFIC ELEMENTS IN THE 1002(H) REPORT IN                          FROM PRUDHOE BAY COULD OFFSET ABOUT 13 PERCENT OF FOREIGN OIL
                 MORE DETAILED WRITTEN COMMENTS TO BE SUBMITTED. WE DO WISH TO                           IMPORTS FOR 30 YEARS.

                 POINT OUT HERE THAT MANY OF THE ENVIRONMENTAL IMPACTS INDICATED IN

                 THE REPORT APPEAR TO BEBASED ON "WORST CASE" EVALUATIONS. WE                            AMERICA SHOULD NOT FORECLOSE ON HER OPPORTUNITY TO INVENTORY AND
                 RESPECTFULLY CALL TO YOUR ATTENTION THAT NEPA-EIS GUIDELINES HAVE                       DEVELOP STRATEGIC PETROLEUM RESERVES AFTER SPENDING BILLIONS OF
                 BEEN CHANGED FROM "WORk CASE" ASSESSNENT@TO "MOST LIKELY TO                             DOLLARS ADVANCING THE LEARNING CURVE IN THE ARCTIC. WE CAN BE

                     R       DO APPRECIATE, HOWEVER, THAT THE RECOMMENDATIONS   OF
                                                                                                         PROUD OF THAT ADVANCE. WE HAVE THE WORK FORCE TRAINED AND
                 THE SECRETARY OF THE INTERIOR REFLECT WHAT IS "MOST LIKELY TO                           WAITING. LET'S DO IT RIGHT-ONCE AGAIN.

                 OCCUR."

                 DUE TO THE "WORST CASE" BIAS, WE REQUEST THAT THOSE IMPACTS BASED

                 ON A HIGHLY SPECULATIVE NATURE BE CLARIFIED AS SUCH THROUGHOUT THE

                 ENVIRONMENTAL CONSEQUENCES SECTION. THIS WILL ALLOW AND HOPEFULLY

                 ENSURE THAT THOSE READING THE DOCUMENT ARE AWARE OF THE

                 HIGHLY-SFECULATIVE NATURE OF THOSE IMPACTS.

                 IN CLOSING, WE WOULD LIKE TO CLEAR UP A,NISCONCEPTION FOR THE

                 RECORD. ONE IS THE MISLEADING VIEWPOINT THAT THE RESERVE

                 POTENTIAL OF THE COASTAL PLAIN MAY BE TOO SMALL TO JUSTIFY
                 LEASING. IT MUST BE REMEMBERED THAT TOTAL PRODUCTION FROM PRUDHOE

                 BAY ACCOUNTS FOR 18 MONTHS SUPPLY OF OIL TO AMERICA. NOTABLY OUR

    					ROCKY MOUNTAIN INSTITUTE

    										22 January 1987
    										[BY FEDERAL EXPRESS]

    US Fish & Wildlife Service
    Att'n:  Division of Refuge Management
    2343 Main Interior Building
    18th & C Streets NW
    Washington, DC 20240

    Dear Sir or Madam:

    This letter comments on the Department of the Interior's Draft Arctic National Wildlife
    Refuge, Alaska, Coastal Plain Resource Assessment, which recommends opening to full
    oil and gas leasing the coast plain of the Arctic National Wildlife Refuge (the "1001
    area"- -a reference to _ 1002 of the Alaska National Interest Lands Conservation Act).

    These comments deal withe Draft's grossly inadequate and misleading treatment of
    two issues:  national energy needs and policies, and the economic evaluation of the 1002
    area.  Other issues are no doubt being dealt with by other reviewers.  A summary of my
    qualifications is attached.

    				Omission of energy-efficiency alternative

    The most fundamental flaw in the Draft--one which in my opinion renders it useless as
    a basis for informed decisionmaking--is that does not even mention, let alone analyze,
    the most attractive alternative to increased oil extraction 1. whether in the 1002 area or
    elsewhere.  That alternative is the more efficient use of energy in general and of
    petroleum products in particular.  As the 1985 national Energy Policy Plan--on which
    the Draft relies for its energy projections and supply-side goals--states at pp.5 and 13:

    	Energy conservation:  an integral part of the energy tri_ _.  (Energy conservation) has proven to
    be the most expeditions way to reduce the need for new or improted energy resource, and in
    fact it now contributes more to balancing our national energy ledge than does any single fuel
    source.  Despite a 21% increase in the number of U.S. households since 1973, for example, cur-
    rent total energy consumption in the U.S. household energy sector is almoste the same as it was
    twelve years ago.  Savings in the industrial, commercial, and transportation sectors are similarly
    impressive.  Even if current energyprices remained stable or declined moderately.  It would
    appear to be economically feasible to continue efficiency gains at a substantial pace for the next
    _5 years.

    	Conservation--our largest single resource.  Conservation contributes more to balancing the
    national energy ledger today than any single fule source.  If pre-1973 trends in energy use had
    continued, DOE calculates that Americans would have consumed about 29 quads 2 more pri-
    mary energy than they actually did in 19_4.  This compares with approximately 21 quads sup-
    plied that year by domestic petroleum, 20 quads of U.S. coal produced, and 18 quads of domes-
    tic natural gas.  Conservation has come chiefly from increased efficiency in the use of energy.
    and from a shift in the nation's mix of goods and services toward less energy intensiveness.  The
    energy productivity of the U.S. economy...has increased 2_% during the decade from 1974 to
    1984, and rose 14% in the last four years of that period alone.

    1 I use this term rather than the traditional "production" because it more accurately describes the process.  Oil was
    produced geological ages ago; all we know how to do is dig it up and burn it.

    2 One quad (quadrillion or 10 15 BTU) is equivalent to 0.47 million barrels of oil per day.

    The Draft irrationally ignores all demand-side options, even as its Chapter VII cities the
    sam DOE document as the authoritative official statement of the need for and benefits
    to be derived from additional supplies of domestic oil

    The case for primary attention to the demand side can be stated even more strongly.
    Since 1979, the United States, according to Energy Information Administration statistics,
    has gotten more than 50 times as much new energy from more effiecient use as from all
    net increases of energy combines.  (Moreover, of those increases, more new energy has
    come from sun, wind, water,a dn wood than from oil, gas, coal, and uranium:  renewable
    sources now total at least a tenth of the Nation's total primary supply, and the fastest-
    growing part, outpaced only by savings.).  Yet the Draft assumes that only more oil
    itself--not more efficient use of the oil we already have--can meet national needs.

    The functional equivalence of oil and oil efficency is well established.  For example, the
    1983 National Energy Policy Plan states at p. 3 that three "particularly important"
    areas "of energy programs and action,"

    The first is energy conservation, which out to be viewed by policymakers, producers, and
    consumers as a significantly important energy resource.  That is, energy conservation should be
    seen as a set of actions that individuals and businesses can take that are cost-effective alterna-
    tives to new supply developement.  Energy conservation actions are often cheaper and easier to
    undertake, and they often make good business sense.  Since the energy price shocks of the 1970s,
    energy use per dollar of gross national product has declined steadily; and important energy-
    efficiency imporvements have occurred in a host of areas, from automobiles to homes and office
    buildings and manufacturing processes.  These accomplishments, coupled with the stability of
    energy prices in general and the lowering of world oil prices within the past year, should not
    obscure the fact that further gains can still be made.  Conservation is, and will remain, an
    important component of the available energy resource mix.

    Since 1973, according to the Energy Information Administration's Monthly Energy
    Review (August 1986, p. 12, data to mid-1986), the United States has reduced the energy
    intensity of its GNP by 25% and its oil and gas intensidty by 36% OPEC's market share,
    too, has been cut roughly in half.  Yet this was done with such straightforward measures
    as a 37%-more-efficient car fleet (id., p. 15, preliminary 1985 data vs. 1973), caulk
    guns, and duct tape.  Still untapped is the potential offeredby newly commercial techno-
    logies vastly more powerful, cost-effective, and sophisticated than these.  For example,
    an improved insulating gas used to fill spectrally selective windows--a proven techno-
    logy entering the market in the first quarter of 1987--raises the potential saving of these
    windows, when eventually they are fully used in the Frostbelt, to more than one Trans-
    Alaska Pipeline's worth of saved oil which therefore need not be supplied.  Such
    "negabarrels," unlike actual barrels, do not run out and do not harm the environment.

    Even with 1980 technologies, the most detailed Federal assessment of the practical
    potential for raising energy productivity found 3 that it would be very cost-effective to
    fuel in the year 2000 an American economoy 80% larger thant that of 1977, with 22-29%
    less fuel than was actually used directly (excluding that used to make electricity) in
    1977.  That is, more, bigger, and more fully equipped and comfortable buildings could by
    2000 be using 58% less total direct fuel than in 1977; industry could add 48% more value
    while using 6% less fuel; and transportation could increase by 30-70% for personal
    driving, 60-90% for personal air travel, and 80% for freight, while transportation fuel

    3 Solar Energy Research Institute, A New Prosperity; Building a Substainable Energy Future, Brick House (Andover
    MA), 1981, 462 pp.).

                                                                                                                                                          3
                           needs  dropped by 15-35%. Even these potential savings were quite conservative at the                                                                           these and other energy efficiency options from the Draft7s, and policymakers', informed
                           time4  and have become even more so with age.                                                                                                                   consideration. The authors of the Draft appear to have artificially restricted their choice
                                                                                                                                                                                           of alternatives so as to appear to support a predetermined position, rather than to
                           Energy-saving technologies are now entering the market so quickly that most of today's                                                                          conscientiously seeking to compare the full range of choices available to achieve the
                           best electricity-saving devices were not on the market a year ago, the same was true a                                                                          same policy goals.
                           year ago, and it is now about,six times as cost-effective to save electricity as it was five
                           years ago. Very detailed analyses by this Institute have shown that full use of today's                                                                                                                    Enenry security
                           best electricity-saving technologies would deliver the same or improved services while
                           saving half of U.S. electrical use at zero net cost, or three-quarters of U.S. electrical use                                                                   The Same DCPA analysiso documented in detail why frontier projects like North Slope oil
                           at a cost below l.5C/kW-h--less than the cost of operating a fossil- or nuclear-fueled                                                                          extraction do not improve, and may well reduce, national energy security. The same ob-
                           power plant, even if building it were free. Unfortunately. since 1981 the Department of                                                                         jections, such as vulnerable tanker traffic, which apply to oil from the Mideast (Draft,
                           Energy, on whose Energy Research Advisory Board I served in 1980-81, has lost most of                                                                           p. 164) apply also to Alaskan oil, in spades. The Trans-Alaska Pipeline, for example, has
                           its capability to analyze modern energy-saving techniques. DOWS projections of future                                                                           been found by the U.S. Army to be utterly indefensible; it runs for nearly 600 miles
                           energy needs therefore take little account of these new developments and hence                                                                                  over some of the roughest and least hospitable terrain in the world, yet is accessible by
                           substantially exaggerate likely future demands. That exaggeration inflates the "need" for                                                                       road or float plane over most of its length. Although its proprietors apparently do not
                           oil from the 1002 area, and understates the importance of demand-side alternatives to it.                                                                       think they have a security problem, TAPS has already been repeatedly shot at and
                                                                                                                                                                                           bombed, fortunately, these attacks have so far been incompetent. One of the TAPS
                           A major studyll for the Defense Civil Preparedness Agency, in which the President of                                                                            pumping stations blew itself up by accident in 1977; had it been a northern instead of a
                           this Institute and I were Principal Investigators, examined major oil-saving opportuniteis                                                                      southern station, and in the winter, some nine million barrels of hot oil could probably
                           in the U.S. economy. We found, in addition to many individually smaller but collectively                                                                        have congealed in a few weeks into the world's largest Chapstickil. Even in good
                           large opportunities. two essentially untapped supergiant "oilfields,' each bigger than the                                                                      weather, the cost of failure in TAPs's oil delivery is measured in hundreds of dollars per
                           biggest in Saudi Arabia, and each capable of sustainably producing (not just temporarily                                                                        second; yet it would take as long as seven months, with good weather and smooth logis-
                           extracting) over five million barrels of oil per day at costs of a few dollars per barrel.                                                                      tics, to replace a large section of the labyrinth of 48-inch pipe at the system's north end.
                           One of these "oilfields" is in our attics: it is the "weatherization oilfield" of oil, and
                           natural gas fungible for oil, which could be saved by basic insulation, reglazing, and                                                                          Such a fragile supply link can actually interrupt a larger fraction of U.S. oil supply, for
                           weatherstripping of sievelike American buildings. The other *oilfield" is under Detroit it                                                                      longer, with fewer alternatives, than a complete embargo of Arab oil. TAPS, according to
                           is the "accelerated-scrappage-of-gas-guzzlers" oiffield, representing the _savings !vailable                                                                    the Draft, carries a fifth of U.S. crude oil input, whereas US. net imports from Arab
                           fly getting Fetropigs. oil file road taster and replacing them with efficient cars'. Either                                                                     OPEC countries accounted in i983 for only 3% of U.S. petroleum products supplied, and
                           of these oilfields could eliminate U.S. oil imports--before a synfuel plant, power plant,                                                                       all opEc countries, for only 12%. Simple, low-technology, probably anonymous and un-
                           or 1002-area oilfield ordered today could deliver any energy whatever, and at a tiny                                                                            detectable, and certainly - unpreventable sabotage to TAPS therefore presents today a
                           fraction of its cost. Either of these *oilfields* could produce in, say, 2005 about eight                                                                       greater threat to America's energy security than any conceivable interruption of oil
                           times as much oil as the Draft contemplates for a successful development program in the                                                                         imports from the Mideast. Increasing dependence on TAPS (and additional, equally
                           1002 area. Both of these *oilfields" would achieve every national policy goal which the                                                                         vulnerable facilities to gather oil from the 1002 area and deliver it into TAPS) would
                           Draft presents as a justification for leasing in the 1002 area, but neither would have                                                                          therefore decrease, not increase, national energy security. As Our DCPA analysis showed
                           significant environmental impacts. It is thus absurd, and contrary to NEPA, to exclude                                                                          in detail, energy efficiency- -coupled with the more diverse, dispersed, renewable supply
                                                                                                                                                                                           system now emerging in the marketplace--is the key to true energy security.
                           4Sao I:& A.D. Lovins &Lj&L Legot-Cost Enetim: Solving the CO, Problem, Brick House, 1081 (an analysis                                                           Investing one year's budget for the Rapid Deployment Force (meant to seize Mideast
                           counninioned by the German Fed" Environmental Agency). dopies ars available from Rocky Mountain                                                                 oilfields) in a good weatherization program would about eliminate all U.S. imports of oil
                           Institute.                                                                                                                                                      from the Mideastlo. Until energy efficiency programs receive more than Federal budget
                           I say this from the perspective of on analyst who, unlike DOE, has correctly Ibressen the major trends In energy                                                cuts and benign neglect, it is hard to take seriously the kinds of handwaving "national
                                                                                                                                                                                           security" rationales presented in the Draft.
                           demand for the pad decade, by paying attention to the emerging competition between energy supply and
                           Improved energy efficiency. and sesurning that conaurners would behave rationally-, to the discomfort of the                                                                                            Economic @enefits claimed
                           energy Industries, they I-S*ly did.
                                                                                                                                                                                            imilar fallacies lurk in the Draft's treatment of balance-of-trade benefits (even
                           6Published se a book, Brittle Power, Energy Stratear for National Security, Brick House, 1981. Copies are,                                                      Seglecting the likelihood that area- 1002 oi          .I would be exported to Japan. under a revised
                           available from Rocky Mountain Institute.
                           7For example, Brittle Poore showed that rather than building synfuel plants. the U.S. would save more oil, faster                                               gAnd a lay summary published In The Atlantic Monthly November 1993, pp. 118-126.
                           and cheaper, by siving a free 40+-mpg car to anyone who would scrap his or her Brontornabile w that nobody
                           would ever drive It again; or by paying a cash bonus of several hundred dollars for every mpg by which your now                                                 gThe operators sim said to believe that their pumps an, powerful enough to move even cooled-off oil, but that
                           car Improved on your old car which you scrapped. These kinds of numbers won agreed. in a recend; meeting of the                                                 capability is controversial and has never been ampirically verified.
                           International Association of Energy Economists. to be malistLe--but wen said to be too sensible to affect Federal                                               10 It is plausible that lout-cost Investment of the some which would be required to find and deliver oiI from on.
                           energy policyl For more such mamples, an A.B. Lovins at al.. Energy Unbound: A Fable for America'. Future,
                           Sierra Club (San Francisco), 1986.                                                                                                                              1002 might achieve the some result, but the Draft does not present enough cost data to permit such a calculation.

    														5

    statue such as the oil industry is earnestly seeking for TAPS output, rather than used in
    the United States).  Energy effieciency produces far more benefit to the balance of trade
    than new domestic oil supplies can, partly because cheap efficiently, unlike costly oil,
    directly improves the competitiveness of U.S. industry in world markets.  Efficiency
    investments themselves also tend to have a high labor-intensity and a releatively low
    capital-intensity.  Frontier oil facilities have the opposite characteristics, and hence tend
    to reduce, not increase, net employement by starving other sectors for capital.

    Efficient energy use also has a vastly larger potential for economic benefits to the
    Nation than all the unexplored hydrocarbon provinces combined.  For examples, national
    energy bills in 1984-85 ran about $430 billion, plus another $50 billion or more in
    direct Federal subsidies to the energy sector 11.  This total energy bill of aobut $480
    billion a year would be about $150 billion a year higher still if the U.S. were as energy-
    inefficient today as it was in 1973.  Yet if Americans were now as energy-efficient as
    their Western European competitors are--and those Europeans are still far short of cost-
    effective efficiency levels themselves--then U.S. energy bills would fall by an additional
    $200 billion per year--about enough to balance the Federal budget.  And if we simply
    chose the best energy buys at each opportunity for the rest of this century, the resulting
    cumulative net savings by 2000 could be serveal trillion 1987 dollars--about enough to
    pay off the entire National Debt.  The hoped-for benefits of area-1002 oil would be
    about 200 times smaller than that.  Yet no policymaker reading the Draft could be
    expected to gain that essential perspective on the descision presented--to appreciate that
    the main alternative omitted can yield, over the same 30-90 years, hundreds of times as
    much benefit, without the proposed action's costs.

    						Exaggeration of benefits

    Morever, the Draft seriously exaggerates those potential economic benefits of area-1002
    oil.  For purposes of this review, I shall assume that the probabilistic anaylysis of the
    recoverable hydrocarbons likely to be found in area 1002 is correct in every respect,
    even though no evidence is presented for the past reliability of the methods and models
    used, and the main assumptions which drive the economic model are in a unpublished
    paper which has apparently not received the critical peer review normal in published
    scientific literature.  I shall further assume that the 10% real discount rate used is
    consistent with the level of risk in the project, although it appears unlikely that free-
    market investors would be willing to invest for such returns in a project with a stated
    81% probability of finding no oil economically recoverable even at high oil prices.
    Subject ot these assumptions, the Draft's economic assessment of area 1002's
    hydrocarbon prospects includes the following major flaws:

    	Only as unusually careful reader would not that all of the stated probabilities of
    finding various amounts of oil, and obtaining various economic benefits, are
    fivefold too high.  This is because all those probabilities are "conditional" on there
    being any economically recoerable oil in area 1002 at all, and the probability of
    that occurrence is established at 0.19 (pp.49, 68, 72, etc.).  Thus the overall
    probability of finding >1.0 billion economically recoverable barrels is only -15%;
    the overall probability of a very large (9.2 billion recoverable bbl) reserve would
    be only 1%; and the probability that "the estimated [mean-case] 3.2 billion barrels
    of recoverable oil would be foregone* under Alternative E is not unity but 0.19,
    there being an 81% probability that wilderness designation would actually

    11  These have been exhaustively researched at RMI by H.R. Heede, whose publications are available from the
    institute.  For a preliminary summary, see The Wall Street Journal, 17 September 1985, p. 28.  The direct energy
    bill of $430 billion a year probably excludes minor expenditures for certain renewable sources on which the
    Department of Energy does not keep statistics.

    														6

    forego no benefit whatever, but only costs.  Yet the Executive Summary nowhere
    mentions this fivefold exaggeration of the probabilities which the reader is
    invited to infer.  Such a consistent relegation of this fivefold factor to technical
    fine print leaves an unfortunate impression of dishonesty.
    The 19% stated probability of finding economically recoverable oil, the size of the
    reserves corresponding to various probabilities, and the economic benefits of
    those reserves alld epend sensitively on the future price of oil assumed.  No
    sensitivity test is provided for this crucial variable.  Yet the $33 base-case price
    assumed (1984 $) for the year 2000 is a point estimate from a DOE model which
    is already badly outdated 12.  For example, another major model equally well
    regarded by mainstream eneryg modellers--that of the Gas Research Institute--
    used in 1985 a reference-case year-2010 U.S. refiners' crude acquisition cost
    ($56.97 in 1984 $) virtually identical to that of the reference case of the 1985
    DOE model on which the Draft relies 13 ($56.77 in 1984 $).  Yet one year later,
    GRI's preliminary 1986 model showd a 32% lower oil price in 2010--only
    $38.33 14.  Presumbably, the 1986 DOE/NEPP model will show somewhat similar
    behavior 15, although its 1986 runs have not yet been published and were not used
    or cited in the Draft.
    Such price volatility makes the Draft's conclusions utterly meaningless, because the
    minimum economically recoverable size of an oilfield in the 1002 area, and hence
    the probability of finding one or more such fields, will depend very sensitively
    on the oil price assumed.  It would not be surprising, for example, if a 30-50%
    drop in the assume doil price in 2010 reduced the state 19% probability of find-
    ing an economically recoverable oil in the 1002 area to less than 5%.  No data
    are presented from which this sensitivity can be calculated; the 5% is an
    illustrative guess on my part.  Whatever the change actually turned out to be, not
    only the probabilities of finding various amounts of economically recoverable oil,
    but also the economic value of that oil would depend on the price assumed.  It is
    therefore plausible that a more realistic and up-to-date estimate of long-term oil
    price could reduce the mean-case present-valued internal benefit of the oil (to be
    set against all its external costs) from the stated $14.6 billion (1984 $) to $5-10
    billion, while greatly reducing the probability of realizing any benefit from the
    irreversible loss of the 1002 area's non-hydrocarbon resources.
    As an illustration of the uncertainty of long-term oil prices, the Gas Research
    Institute's draft 1986 baseline forecast includes a "consensus" of oil experts'
    estimates of the real oil price in 2000-2010.  That "consensus" embraces a range of
    values spanning a range of more than fourfold16--yeat the Draft nowhere even
    hints that future oil prices are highly uncertain or that such uncertainty can

    12Actually, the cited source does not give a base-case 1984-$ world oil price in 2000 of $33/bbl, but rather of
    $36.7_, and a U.S. refiners' acquisition cost of _$36.98.  This discrepancy is apparently unexplained.

    13National Energy Policy Plan Projections to 2010.  DOE/PE-0029/S. December 1988, at p. 2-5.

    14_ _, $3_._1 in 1988 _, converted to 1984 _ using the GNP implicit price deflator.  See D.A. Dreyfus, "Preliminary
    1986 GRI Baseline Projection of U.S. Energy Supply and Demand," _ August 1986 paper to GRI Seventh Annual
    Joint Board of Directors/Advisory Council Energy Seminar.

    15It has done so before DOE's Table 5-1, at p. _ _, DOE/PE-0029/3, op.cit., shows that the NEPP-198_
    projection of a year-2010 world oil price of $56.77 reflected  a 37% drop in two years:  the NEPP-1983 projection
    was $89.95 (both in 1984 $)

    16DOE itself (id.) notes a year-2010 range of authoritative projections of 2.7-fold.

    													7

    invalidate its conclusions17.  Just in the four months from November 1985 to
    March 1986, the world oil price fell from $28 to about $12 18--a sobering
    reminder of how little confidence "consensus" forecasts merit, even those made
    months rather than decades into the furture19.
    The Draft reflects an apparent effort to distort readers' perspective of the benefits
    claimed from leasing.  For example, a mean net-present-valued internal benefit of
    $14.6 billion (p.165) sounds like a big number in isolation; but it is only  3% of
    the Nation's total energy bill for a single year (and even a smaller fraction of the
    energy bill in a future year with higher prices and presumably higher consump-
    tion).  In other words, the Draft recommends destroying important values of the
    1002 area for a benefit equivalent, over the 30-90 y of proposed hydrocarbon
    exploitation (p. 6), to about 0.03% to 0.15 of today's annual national energy
    bill20. Yet it certainly doesn't leave that impression:  it artfully invites the reader
    to suppose that in a national context, the potential benefits of the leasing are
    truly important.
    The Draft often uses undiscounted benefits to inflate their apparent size even mroe.
    Similarly, the apparent importance of the potential oil resource is seriously distorted
    (pp. 165-166) by comparing it with reserves--the much smaller quantity which
    the oil industry has bothered to invest in proving out for short-term extraction.
    The text correctly, though obliquely, suggests that this not a fair comparison,
    but it does not make a fair comparison, which would be far less favorable to the
    Draft's conclusions.
    The Draft's comparisons of area 1002's potential oil output with national oil needs,
    imports, etc. similarly rest on a single DOE/Nepp model run, showing 16.5 million
    bbl/d of demand and 7.6 of imports in 2005. (The model actually shows that de-
    mand as declining: 16.9 Mbbl/d in 2000, 16.5 in 2005, and 16.1 in 2010--al-
    thogh the Draft leaves the impression of ever-rising demand.)  But the Draft
    does not mention, among other sensitivity tests, a "high-effieciency" DOE/NEPP
    run21, described at length in the same report, which would reduce year-2010
    liquid-fuel requirements (excluding synfuels and electric utility inputs) by 10%
    or 1-2/3 million bbl/d.  That is equivalent to 2.5 times the mean output
    projected for the 1002 area.  Oil imports are likewise shown in that DOE sensitiv-
    ity run to decline from the Draft's reference case by 19% or 1 1/2 Mbbl/d, or 2.3
    times the mean output from area 1002.  The year-2010 world oil price drops by

    17For a salutary reminder, before the 198_/8_ oil price crash, of the "herd instinct" of oil-price forecasters, was
    The Future of Oil Prices:  The Perile of Prophecy, Cambridge Energy Research Associates/Arthur Anderson & Co.,
    1984.

    18J.M. Griffen & C.T. Jones, The Energy Journal 7 (4);37 (October 198_).

    19There are fundamental reasons to believe that the wolrd oil price will remain volatile and unpredictable for
    many decades to come, just as it is for other commodities.  In my opinion, it is fallacious to try to project a future
    oil price as a basis (or investment behavor today.  If a client asked me to make such a projection, I would instead
    ask at what oil price the proposed project ceased to be profitable, and then ask the client how much risk he or she
    wished to take.  For what it is worth, however, the two forecasting groups with the best track record in recent
    years--both correctly called 1985/86 price crash--expect that with fluctuations, _._. if war or peace
    breaks out in the Middle East, the real oil price will probably vary within the $16-24/bbl range for at least the
    rest of this century.  The mean of that range is about two-fifths below the Draft's point projection.

    20Expressed differently, the mean-case output of 659kbbl/d in 2005, at the apparent assumed price of $33.7/bbl
    (1984 _ in 2005), would correspond to a gross output value of -1.45 billion (1984 _ present-valued to 1986) per
    year, or 0.03% of the 1986 national energy bill.  The net value, after subtracting costs, would be even less.

    21DOE/PE-002_/3, op.cit., pp 4-3_ and 4-33.

    $2.50/bbl. "In fact, the impacts of these efficiency level changes on the world oil
    prices is marginally higher than those of [another sensitivity test assuming]...20
    percent changes in the U.S. oil and gas resources levels."22. The Draft, however,
    doesn't mention any sensitivity tests of or variations on the single demand
    forecast which it assumes23--not even those done by DOE itself in the same place.
    The Draft has an "optimistic" case but no corresponding "pessimistic" case, and does
    not discuss what plausibility it regards any variant on its base-case as meriting,
    or why.
    The Draft at pp. 164-5 comes perilously close to double-counting benefits.  It gives
    1002-area oil credit for avoiding potential disruptions of oil supply (p. 8) when
    those benefits have already been supposedly achieved, and paid for, by the Stra-
    tegic Petroleum Reserve.  It qualitatively assigns a benefit to the extended utiliza-
    tion of TAPS, without considering that the cost of TAPS is already sun and is
    therefore irrelevant to any comparison of the marginal costs and benefits of a
    new decision.

    More broadly, one might reasonably have expected the Department of the Interior, as
    the appointed steward of the Nation's resources, to discuss the policy implications of
    domestic oil depletion.  The Draft describes the collision between supposedly growing
    demands and declining domestic oil output24.  what is one to infer from that collision?
    That the bottom of the barrel must be scraped, in the Refuge and everywhere else, be-
    cause there is, as the Draft leads one to suppose, simply no alternative?  Or that we
    should instead thoughtfully consider whether postponing the ultimate depletion of the
    Nation's oil resources by fewer than 200 days25 is worth the Refuge, given that depletion
    of the finite resource is inevitable ant that whatever alternatives will be used to replace
    that oil will need to be adopted anyway--either sooner or, in the unlikely event that the
    1020 area is fully leased and actually does contain economically recoverable oil, 190-odd
    days later?  If alternatives are available, as presumably they are at some price (since even
    the Draft is not so apocalyptic as to suppose that the United States will cease to exist on
    the day its last barrel of oil is depleted), what are the costs and benefits of adopting
    them some 200 days earlier and not leasing the Refuge?  Isn't leasing taking a gamble,
    against stated odds worse than 5:1, that those alternatives will need to be adopted
    anyway, beacuse no economically recoverable oil will be found even with full leasing of
    area 1002?  The Draft is silent on these central questions:  it tacitly assumes that any
    extension of the Nation's oil-resource life, however improbable, damaging, or brief is
    worth the price.  That approach, as economist Prof. Herman Daly once remarked26 in
    another context.

    22ld.,p.4-30.

    23For officially recognized alternatives, se _.g. SERI, op. cit., and DOE, Low Energy Futures for the United
    States, DOE/_E-0020, June 1980.  Many independent experts, including me, would regard event these low forecasts
    as an understatement of how much efficiency is now available, worth buying, and practically achievable by a
    serious commitment to a competitive energy-service marketplace.

    24It does not, however, describe how oil-and-gase intensity is continuign to decline with 1986's remarkably
    low real prices.

    25Mean economically recoverable oil, 3.7 billion barrels, divided by the DOE/NEPP model's projected annual
    consumption of 16.8 million bbl/d in 2008, equals 194 days.

    26"On Thinking About Future Energy Requirements," typescript, Department of Economics, Louisiana State
    University (Baton Rouge), 197_.

                                                                                                                               9

                           I. unworthy of any organism with a central nerrous system, lot alone a cerebral cortex. For
                         those of us who also be" ouls It Is almost Incomprehensible In its Inversion of means and end..
                                                                                                                                                                                                      A*,i
                 The Department of the Interior should not shame its traditions, and expose its honest
                 analysis to ridicule, by proceeding with this mendacious Draft. It needs to be done over,

                                                                                                                                                                 BIOGRAPHICAL SKETCH OF ANIORV B. LOVINS AND L. HUNTER LOVINS
                                                                 Sincerely,
                                                                   '7 -@r .9                                                                          AMORY AND HUNTER LoviNs work together as analysts, lecturers. and consultants on energy and
                                                                                                                                                      resource policy in over fifteen countries. Their prophetic analyses hive placed them among (in News-
                                                                  Amory B. Lovins                                                                     week's phrase) "the Western world's most influential energy thinkers." They shared a 1982 Mitchell Prize
                                                                  Director of Research                                                                and a 1983 Right Livelihood Award (often called the "alternative Nobel Prize*). A 36-minute, 16mm
                                                                                                                                                      film on their work, Lovins ops the Soft Path, got blue ribbons at the American and three other film
                 encl: biographical sketch                                                                                                            festival% and in 1985 60 Minutes featured their work.

                                                                                                                                                      Mits LoviNs, 36. earned BA degrees from Pitzer College in political studies and sociology, a JD from
                                                                                                                                                      Loyola University School of Law with the Alumni Award for Outstanding Service, and an honorary
                                                                                                                                                      doctorate. For six years she was Assistant Director of the California Conservation Project ("Tree
                                                                                                                                                      People'), which she helped to establish. A member of the California Bar, she has served on the City of
                                                                                                                                                      Los Angeles Energy Management Advisory Board. lectured extensively, published many papers, coau-
                                                                                                                                                      thored five books on energy policy, and been 1982 Henry R. Luce Visiting Professor at Dartmouth
                                                                                                                                                      College. Her current research focuses on resource efficiency and local economic development.

                                                                                                                                                      AMORY LoviNs, 39. is 2 C0115111t3ni experimental physicist educated at Harvard and Oxford. A former
                                                                                                                                                      Oxford don, he holds an MA by Special Resolution and five honorary doctorates. lie was Regents' Lec-
                                                                                                                                                      turer in the University of California in resource policy (1978) and in economics (1981), Grauer Lectur-
                                                                                                                                                      er in the University of British Columbia, 1982 Luce Visiting Professor at Dartmouth, and 1982 Distin-
                                                                                                                                                      guished Visiting Professor in the University of Colorado. In 1980-81 he served on the Department of
                                                                                                                                                      Energy's senior advisory board, and in 1984 was elected a Fellow or the American Association for the
                                                                                                                                                      Advancement of Science "for his book Soft Energy Paths and many other noteworthy contributions to
                                                                                                                                                      energy policy." He has briered five heads of state. testified at hearings in eight countries and twenty-
                                                                                                                                                      odd states, and published a dozen books and over a hundred papers. Dr. Alvin Weinberg, ex-Director
                                                                                                                                                      or Oak Ridge National Laboratory, has called Mr. Lovins *surely the most articulate writer on energy in
                                                                                                                                                      the whole world today.*

                                                                                                                                                      The Lovinses' clients have included U.S. and U.N. agencies, the International Federation            of   institutes
                                                                                                                                                      for Advanced Study. OECD. Resources for the Future, the German Federal Environmental Agency, the
                                                                                                                                                      Science Council of Canada, eleven state governments, the U.S. Navy, and the U.S. Defense Civil
                                                                                                                                                      Preparedness Agency. As part of their work with managers of electric utilities and related industries in
                                                                                                                                                      more than thirty states, the Lovinses have briefed, among others, the Energy Committee of Xerox Cor-
                                                                                                                                                      poration and the senior managements or Westinghouse Electric Corporation, Royal Dutch/Shell Group,
                                                                                                                                                      Phillips Petroleum. Bank of America. Allstate Insurance Co., Bonneville Power Administration, Ten@es-
                                                                                                                                                      see Valley Authority, Texas Utilities. Public Service Co. or New Mexico, Snohomish PUD, and other
                                                                                                                                                      public and private utilities. They have addressed Edison Electric Institute functions, the Electric Power
                                                                                                                                                      Research Institute. an American Public Power Association workshop and annual meeting, the National
                                                                                                                                                      Association of Rural Electric Cooperatives, the National Association of Regulatory Utility Commission-
                                                                                                                                                      ers, the National Association of State Utility Consumer Advocates, the National Regulatory Conference,
                                                                                                                                                      California Puc and Brookings Institution utility colloquia. and many other industry groups.

                                                                                                                                                      Mrs. Lovins is Execuiive Director, and Mr. Lovins is Director of Research, of ROCKY MOUNTAIN
                                                                                                                                                      INSTITUTE, I nonprofit foundation which fosters efficient resource use and global security. RMI's 23
                                                                                                                                                      staff explore the connections between energy, water, agriculture. security, and local economic
                                                                                                                                                      development. Much of RMI's budget ($820.000 in 1987) is earned. mainly by consultancy.

          Rural Alaska
          Community Action Program, Inc.
                                                                                                       William P. Horn                    -2-            February 6. 1987

                                                                                                       Second, the report gives very short shrift to coastal impacts. If
              February 6, 1987                                                                         oil and gas development does occur, then it is quite likely that
                                                                                                       there will be considerable interest in offshore prospects near the
                                                                                                       coastal plain. For example, shore-based facilities might be used by
                                                                                                       offshore rigs, and if oil is found, it might be pumped through a
                                                                                                       pipeline located on the coastal plain. This sort of associated
                                                                                                       development could have impacts on key subsistence resources#
              William P. horn                                                                          particularly fish and bowhead whales. Thereport should therefore
              U.S. Fish and Wildlife Servic                                                            focus more carefully on the impacts of associated development.
              ATTN: Division of Refuge Man:gement
              2343 Main Interior Building                                                              RelatIedly, the report pays very little attention to cumulative
              18th and C Streets, M.N.                                                                 impacts, focusing purely on what might happen to the coastal plain.
              Washington, DC    20240                                                                  This is insufficient to provide the necessary information to Congress
              Dear Mr. Horn:                                                                           or rural people in Alaska. The report should address a variety of
                                                                                                       cumulative Impacts. A critical deficiency In this regard concerns
                                                                                                       the Central Arctic Herdp another important source of subsistencep
              We appreciate this opportunity  to comment on the Draft Report to                        especially for Kaktovik and Ruiqsut.    Development of the coastal
              Congress and Legislative Environmental Impact Statement regarding the                    plain might have the effect of pushing the CAN into an even smaller
              coastal plain of the Arctic National Wildlife Refuge. These comments                     area, given existing development at Prudhoe Bay.     This is
              aee.filed on behalf of the Rural Alaska Community Action Program                         particularly important in view of the evidence that cows and calves
              (RurAL CAP), which works to aid rural Alaskans (principally Natives)                     have been avoiding the areas that have been developed in Prudhoe
              bring themselves out of poverty.                                                         Day., The report, however, only looks'at Impacts due to development
                                                                                                       on the coastal plain -- it should consider the overall impacts on the
              RurAL CAP does not have a formal  position on whether.the coastal                        CAN, due to development throughout the Worth Slope.
              plain should be opened.to oil and gas exploration and development,
              left as a refuge within the national wildlife refuge system, or                          The report notes that two key issues revolve around where the oil and
              designated as wilderness. We are concerned, however, that full                           gas facilities will obtain the needed gravel and water.      But having
              information be presented to Congress and the rural people of Alaska#                     said this, the report is totally silent on where these vital
              so that the beat decision can be made.    These comments are offered in                  materials will be found, or what the environmental impacts of the
              the spirit of assuring an comprehensive and accurate a report as                         various alternatives might be. Given the importance of this issue,
              possible.                                                                                and the possible negative impacts, the report should contain a
                                                                                                       detailed discussion of alternative methods of procurement, and the,
              The principal concern of rural people# especially Natives, is what                       impacts of each alternative.
              the impact of development or wilderness will be on subsistence. We
              commend you on the frank statements contained in the subsistence                         The report also in totally silent on development for gas, on the
              section in the report with regard to those impacts, which we feel are                    grounds that such development to unlikely.     But the conclusion that
              generally accurate as far as they go.    But nevertheless, certain key                   it is unlikely is only part of the report, for Congress wanted
              areas do not receive sufficient coverage.                                                information on what exploration for and development of gas would do
              First# the report does not adequately discus  .a impacts of development                  to the environment.   The report must provide this information.
              on users of the Porcupine Caribou Herd other than residents of
              Kaktovik. The people of Arctic Village principally rely on the PCH
              for subsistence, and the herd is of great importance to other
              villages as well, such as Venetia, Fort Yukon, Chalkyitaik, and Old
              crow In the Yukon Territory. If there are fewer caribou available
              for these villages the impacts could be severe. Congress should be
              made aware of wh  t might happen to other village residents before it
              decides whether to allow oil and gas development.

         Adnikilsiration     P-0. F40X 20090U,

              William P. Horn                 -3-              February 6, 1987

              Finally# we are troubled by the lack of analysis in the actual draft
              recommendation. That recommendation is for full leasing, and
              operates on the assumption that full leasing can be accomplished
              without adverse impacts on fish and wildlife or subsistence. But
              this conclusion is belled by the analysis of the report Itself, which
              concludes that even with stipulations, effects on caribou and
              subsistence will be major. The recommendation also points to Prudhoe
              Day as an example of how environmentally safe development can
              proceed# yet the report states unequivocably that the experience with
              caribou at Prudhoe Say cannot be applied to the coastal plain of ANWR.-

              We do not feel that the Department, or Congress, can have It both
              ways. while as noted above. we do not take a position on what the
              recommendation ought to bep we feel that it in disingenuous for the
              Department to claim that development can occur In harmony with the
              wildlife, given the conclusions of the body of the report. tt
              appears that Congress is faced with a basic choice: whether to allow
              oil and gas exploration and development In the coastal plain and
              accept the apparently severe impacts on fish and wildlife and
              subsistence, or to preserve the status quo, or to select wilderness.
              The Department's recommendation should recognize this basic choice
              explicitly, so that all involved know what they are getting Into.

              Thank you for your attention to these comments.

              sincerely,

             @Jeanine Kennedy
              Executive Director

              Met

    SIERRA
      CLUB

    									330 Pennyslvania Avenue, S.E. Washington, D.C. 20003 (202)_47_-_ _ _ _

    						February 6, 1987

    U.S. Fish and Wildlife Service
    2343 Main Interior Building
    18th and C Streets, N.W.
    Washington, D.C. 20240

    Attention:  Division of Refuge Management

    Dear Sirs:

    	The Sierra Club has completed its review of the draft Coastal Plain
    Resource Assessment for the Arctic National Wildlife Refuge.  The Sierra
    Club is an environmental organization with over 400,000 members
    nationally, and approximately 1,800 members in Alaska.

    	Sierra Club strongly supports wilderness designation for the entire
    Arctic National Wildlife Refuge coastal plain.  We submit the attached
    comments for your consideration.

    					Sincerely,

    					Michael McCloskey
    					Acting Executive Director

    	"When we try to pick out anything by itself, we find it hitched to everything else in the universe." John M_ _
    		National Headquarters: 730 Polk Street, San Francisco, California 94109 (415) 77_-2211

    	The resource assessment is required by Section 1002 of the Alaska

    National Interest Lands Conservation Act (ANILCA), passed by Congress in

    1980.  ANILCA left unresolved the question of whether oil and gas

    development should be allowed to occur on the Arctic National Wildlife

    Refuge.  The 1002 Report, as it is referred to, is to aid Congress in

    making its final determination on the disposition of the coastal plain,

    which may hold significant quantities of oil and gas reserves but also

    contains preeiminent wildlife and wilderness resources.

    	The Report is therefore is a very important document; however, the

    Department of the Interior refused to allow public review of the Report.

    Only after a successful lawsuite brought by several conservation

    organizations was the public given this opportunity.  As the steward of

    publicly owned lands, the Department of Interior  seriously breached its

    responsibility by initially denying citizens this very basic right.

    	The Department is still not living up to the spirit of the court's

    judgment for a complete and open review process.  The Report should have

    been submitted to Congress in September of 1986 as requried by Section

    1002.  Instead, the Department chose to release the Report in late

    November with a brief 60-day reivew and comment period (later extended

    by two weeks) that overlapped the holiday season when most people are

    traveling or otherwise preoccupied.

    	Concurrent with the review and comment period for this Report was

    the same period for several other public documents.  These include the

    Beaufort Sea Sale 97 Environmental Impact Statement and an environmental

    impact statement for a gas pipeline from the North Slope south to the

    tidewater.  Additionally, the Alaska Department of Natural Resources is

    soliciting comments on Camden bay Sale 50, which is scheduled for

    leasing later this year; and the Fish and Wildlife Service is also

                                                        -2-                                                                                                      -3-

                    conducting its Comprehensive Conservation Plan process for the rest of                                  Management, and construction proceeds, then gas resources of the coastal
                    the Arctic Refuge at this same time.                                                                    plain may be judged economical to extract      contrary to the contention
                                                                                                                            of the Department in the Report that "natural gas Is not expected to be
                         The public 13 currently overwhelmed  with reports, environmental                                   economic during  the time.period considered." Additional Industrial
                    impact statements, or preliminary analyses.   All except one call for oil                               activity and support facilities for gas production would increase the
                    and gas development In environmentally sensitive arctic coastal and                                     impact to fish, wildlife and wilderness resoutces.    The law require3
                    Off-3hore regions. The impossibility Of careful review of each of the                                   that those impacts be as3essel; however. they are not in this Report.
                    proposals limits the useful involvement of concerned and arrected
                    individuals. No discussion of cumulative impacts 83 a result of all                                          Third, Section 1002(h)(5) requires a discussion or   the national
                    this development is presented to any of these documents.                                                need for the oil and.gas resources or the Coastal plain. Such a
                                                                                                                            discussion is done In a cursory and biased fashion In Chapter VII of the
                    Report Deficiencies                                                                                     Report. No assessment of national need for oil and gas is complete
                                                                                                                            without a discussion of how alternative energy sources and energy
                        The draft Report Omits some critical components that are required                                   COD3ervatton programs could out the n8ttO03'3 need for oil.    Existing or
                    by the Alaska National Interest Lands Conservation Act and other                                        proposed programs in this regard should be cited a3-part of this
                    applicable laws.                                                                                        examination.
        OD              First. Section 1002(c)(B) of ANILCA requires a -determination of the                                     Fourth, In Section 1005 of ANILCA the Department is required to
                    carrying capacity for fish and wildlife habitats. Alteration of                                         consult with various entities and Individuals. This has not been done
                    wildlife habitat caused by the development of oil and gas resources                                     In a satisfactory manner with either the Government of Candada or the
                    would affect its carrying capacity. Without Information on carrying                                     people in several Canadian villages who depend heavily on the
                    capacity, it is even more difficult to assess potential losses of fish                                  international wildlife resources of the coastal plain. This oversight
                    and wildlife resources. This may mean that many of the assessments Of                                   In procedural matters needs to be remedied prior to the Report's
                    fish and wildlife losses contained within the Report are too                                            finalization.
                    conservative. Furthermore, no discussion is presented relative to the
                    Impact that full leasing would have on the natural diversity Of wildlife                                     Finally, since this is an environmental Impact statement, the
                    populations. ANILCA requires the Fish and Wildlife Service to manage                                    Report must conform to the guidelines attpul ated by the National
                    fish and wildlife populations and their habitats In their natural                                       Environmental Policy Act. These guidelines require that an evaluation
                    diversity.                                                                                              or cumulative effects be performed.   It has not been done in the Report
                                                                                                                            As mentioned aboveo current state and federal proposals would result in
                        Second, the Report has not assessed the Impact from development of                                  leasing of state submerged lands and federal outer continental shelf
                    gas resources 33 required by Section 1002(h)(3).  If the aforementioned                                 areas adjacent to the coastal plain.   In addition to the 4evelopment   in
                    proposal to construct a gas pipeline is permitted by the Bureau of Land                                 the Prudhoe Bay area, a gas pipeline may also be proposed.    The major

                    cumulative effect to the fish and wildlife resources from all these                                               Americans have become increasingly Conscious or the need to retain
                    developments are not analyzed. 7he Department neglects to examine what                                      some areas in an undeveloped condition for the intrinsic benefits to
                    additional legal authority would be required to minimize environmental                                      society. Wiltiernew areas provide unparalleled research opportunities.
                    impacts.                                                                                                    Wilderness areas maintain genetic diveraltyo Wilderness provides
                                                                                                                                wildlife managers with their most effective management tool for
                          In our detailed comments that follow, we elaborate on these and                                       conserving fish and wildlife,populations. Wilderness areas epitomize
                    other deficiencies In the draft Report.                                                                     our national heritage. We carved our American society out of the
                                                                                                                                natural world around us. Now we finally have come to the sensible
                    Wilderness                                                                                                  conclusion that we have carved enough, and that we need to retain some.
                                                                                                                                as enacted in the Wilderness Act of 1964.
                          The coastal plain is an Integral part of vast arctic ecosystem
                    encompassed in a pristine state by the Arctic National Wildlife Refuge                                           For a century, Intense controversies have occurred between those
                    and the adjacent Yukon National Park in Canada. The Report notes. In an                                     who recognized wilderness' Intrinsic benefits to society and those who
                    extremely cursory and Inadequate discussion. that *the Arctic Refuge is                                     could not understand resources as other-than commodities to be tappede
                    the only cons ervatto; System unit that protect$. in an undisturbed                                         harnessed, plowed or 3crapedt the battle over Hatch Hetchy dam In,
                    condition, a complete spectrum of the various sictio ecosystems."                                           Yosemite,  geothermal development adjacent to Yellowstone, efforts to
                    Moreover, the coastal plain is the portion of the Arctic Refuge most                                        construct dams in Grand Canyon National Park and Dinosaur National
         (D
                    prolific In wildlife.                                                                                       Monument,and attempts to log the forest* of Olympic National Park.

                          The Irregular coastline     formed  by barrier Islands, tee-choked                                         The Arctic National Wildlife Refuge represents our country's last
                    beaches, and sprawling river deltas -     gives way to an austere and                                       chance to preserve Intact an arctic ecosystem unique in Its natural
                    rolling coastal plain. Broken only by     braided waterways, the coastal                                    wonder. To the west lie the Prudhoe Bey industrial area and the
                    plain stretches northward from the Brooks Range. The mountains here are                                     National Petroleum Reserve-Alaska. both of which are available for oil
                    at their closest to the Beaufort Sea of any point along the entire North                                    and gas leasing and other development. The Beaufort Sea to the north 13
                    Slope, making the galcier-covered peaks stunning sentinels that peer                                        currently scheduled for oil and gas development.@ Only 25 miles or
                    downward on the coastal expense and outward to the ice pack.                                                coastal plain are curfently designated wilderness, out of 1.100 miles of
                                                                                                                                arctic coastline in Alaska. Any development on the coastal plain would
                          The Department assesses impacts to wilderness solely from the                                         not just affect those 1.5 million acres, but a significant portion of
                    perspective or damage incurred to recreationsists' experiences.                                             the established wilderness area in the Arctic Refuget as well as a
                    Recreation is o ly one reason for the designation of wilderness areas..                                     Canadian national park.

                                                        -6-                                                                                                       -7-

                         The Report is sadly remiss in delving into the importance of' this                                   grounds in the Ogilvie Mountains of Canada and In the Interior of
                    wilderness resource.   In its final Report, the Department should cite                                    Alaska.  This cycle has been repeatel year after year for 3ons.
                    some of its former employees' writings on this subject. Murie and
                    Calef, noted explorers and researchers, long ago recognized the need to                                        The far western portion of the coastal plain also provides habitat
                    protect this arctic world from encroaching development.                                                   for the Central Arctic Herd (CA4), which at 13,000 animals is
                                                                                                                              approximately one-fourteenth the size of the PCH. The CAM does not
                    Environmental Consequences                                                                                migrate extensively ;nd has ample stretches of unconstricted coastal
                                                                                                                              areas On which to calve.  Biologists have studied the impacts of
                         Aside from the inevitable -- and irreparable - loss of a                                             development on the CAH for only the last decade or so.
                    magnificent wilderness treasure, the coastal plain biota would   be
                    seriously harmed by oil and gas development.                                                                   The differences between the two herds are great, and wildlife
                                                                                                                              biologists note that compariston3 can only be made with extreme caution.
                         In general. the sections of the Report that describe the fish and                                    Yet, the executive summary carelessly compares the two herds, and
                    wildlife resources and detail the environmental consequences of oil and                                   downplays the significance of the differences. The executive summary
                    933 development are comprehensive and InfrmatIve,     The executive                                       echoes oil Industry claims that experience with Its extensive
                    summary. however. fails to note several critical points that were made                                    development has shown no adverse effects to caribou and other   wildlife
                    in the body or the Report.   The recommendation to allow full oil and gas                                 resources. This ignores scientific date that demonstrate otherwise.
                    leasing is apparently based without complete regard to these issues,
                    highlighted below.                                                                                          -  Impacts from development include displacement from preferred
                                                                                                                              calving habitat. Development also impedes movement to in3ect-relief
                                                      Caribou                                                                 areas. That the CAH has not seen a population decline to date means
                                                                                                                              only that It has yet to reach the carrying capacity of available
                         The Poicupine Caribou Herd (PCH) is the fourth-large3t   herd In                                     habitat. and was far from such a limit when development of the
                    North America and the only herd in Alaska whose entire range is almost                                    tran3-Alasks pipeline and Prudhoe Bay development began.    Moreover. the
                    entirely protected from development. The Arctic National Wildlife                                         CAH remains in the vicinity of oil development year-round. and therefore
                    Refuge and the adjacent Yukon National Park in Canada were both                                           has more' time to adjust to industrial activity than would the PCH.   The
                    principally established as sanctuaries for this herd.                                                     CAH has been further aided by a prohibition on hunting and low predation
                                                                                                                              by other natural predators, which have decreased in numbers since the
                         The 180,000-head herd 13 highly migratory in behavior and travels                                    development at Prudhoe Bay.
                    hundreds of miles in a never-ending cycle. The cycle begins with
                    calving on the Coastal plain or the Arctic Refuge In late spring, moves
                    through the summer aggregation and fall rut, and ends in its wintering

                                                                                                                                                                  -9-

                          More Importantly, comparisons cannot be credibly drawn between the                                      Development of the oil and gas.resources would reverse this trend
                    two heids because of these additional reasons:                                                           by displacing muskoxen from as much as 71% of their high-use habitat.
                          9  The absolute density of the PCH on Its calv .Ing grounds 13                                     Field researchers predict a major population decline or change in
                             14 times that of the CAH. This results in a ratio or                                            distribution of up to 50%. The Report should assess what efrect this
                             more than 50 caribou per square mile for the PCH as                                             will have on the statewide population of muskoxen, of which the coastal
                             opposed to 5 caribou or less per square mile for the CAH.                                       plain population constitutes one-third.
                             The CAH has been displaced from only a small portion of'
                             the entire area available for calving. which is equal In                                                                        Polar Rears
                             size to the PCH calving area. Suitable alternative
                             habitat exists.. The PCH. however, will see over a third
                             (38%) of Its concentrated calving area list to
                             development under full leasing. No alternative habitat                                               The Coastal plain of the Arctic Refuge is the only portion or the
                             for calving exists. The PCH has calved In the same area                                         entire arctic coast of Alaska where researchers have found polar bears
                             for nine of the last fourteen yews in which studies have                                        to den onshore. The Report falsely states that "the onshore area from
                             been conducted.
                                                                                                                             the Colville delta to the Canadian border is within the area usg by the
                                                                                                                             Beaufort Sea population of polar bears for denning. However. the most
                          In general terms, the executive summary notes the consequences or                                  Consistently used land denning areas were on and adjacent to the 1002
         ?          oil and  gas development to be "some long-term effects on caribou from                                   area...
          FS        the Porcupine herd,r and foresees that illong-term losses in fish and
                    wildlife resources ... would be the Inevitable consequences Of a long-term                                    In 1985. crews transporting materials to an exploratoey well site
                    .commitment to oil and gas development. production and transportation."                                  wit.hin the Coastal plain on Native-owned lands traveled too close to a
                    The executive summary, however. fails to point out just how adversely                                    known den of a pregnant female polar bear. The radio-collared animal
                    the caribou of the PCH would be impacted. Field experts predict "a                                       later was found to have left her den prematurely. and when she was later
                    major population decline and change In distribution of M to 40
                    percent." Forty percent of the herd Is 72,000 animals. They note that                                    tracked and sighted, she had no cubs with her. Presumably, the
                                                                                                                             disturbance caused her to abort her young.
                    this estimate is uncertain, due In part to look of relevant experience.
                    The Report, especially the executive summary. needs to clearly                                                Biologists Contend to the Report "that the Beaufort Se   Ia population
                    distinguish and interpret differences in these herds.                                                    (of 2,000 animals) can sustain little. if any, increase in mortality."
                                                                                                                             The Report concludes that full-scale development would cause only a
                                                     Muskozen                                                                moderate impact I, "so long as similar Intensive developments did not
                                                                                                                             occur along the entire northern coast of Alaska and Canada." Such
                          HU3koxen were extirpated in the lost of the 19th century by
                    overhunting. The prehistoric-looking animals were reintroduced in 1969                                   development is ongoing and proposed throughout the Alaska arctic coastal
                    -and haIve..been 31OWlY making a comeback under the careful eye of wildlife                              and outer continental shelf areas, and ongoing in portions of the
                                                                                                                             Canadian outer continental 3heIr areas.
                    managers. They number about 500 animals now.

                        The polar bear population is now stable. But any additional                                                                            Birds
                   mortality, - which has already occurred as a result of oil exploration
                   efforts - will be detrimental to the Beaufort Sea population. This                                            Of major concern here Is the  disruption of a major staging area for
                   impact will be be exacerbated by similar Intensive development elsewhere                                 a variety of migratory waterrowl.   Oil and gas development would cause a
                   In the range of polar bears. The Report should thoroughly consider                                       major population decline and change in distribution of 50% for lesser
                   these cumulative effects in making judgments on the degree to which the                                  snow geese, and would also affect other waterfowl and bird species,
                   polar bear population will be affected.                                                                  Including the endangered peregrine falcon. For the waterfowl specte3g
                                                                                                                            development of oil and gas resources would be inconsistent with
                                     Other Marine and Terrestrial Mammals                                                   International migratory waterfowl treaties signed by Canada, Mexico and
                                                                                                                            the U.S. Signatory nations should have been consulted, but were not;
                        Very little is known about the migration and habits of the                                          this needs to be remedied prior to release or the final Report.
                   endangered bowhead and grey whales. or Beluga Whales. which are    all
                   found in the waters north or the coastal plain, as are ringed, bearded

                   and spotted seals.   The assumption In the Report that impacts to these                                                    Water Resources and Gravel Extraction
                   species would be minor neglects Consideration of cumulative impacts.
                                                                                                                                 The. potential environmental degradation resulting from water and
                        If the coastal plain were opened to oil and gas development, the                                    gravel Use for exploration, development and production is hardly dealt
                   Report acknowledges that the area would be used extensively as a staging                                 with in a comprehensive manner.   This is one of the Most serious
                   area for off-3hore development. Additionally. the prevelant method of                                    shortcomings of the Report.   The Report states that not enough water or
                   extracting oil from arctic off-ahore areas is the construction of gravel                                 gravel are available; the lack of water presents a "major engineering
                   causeways and islands. The gravel Islands and attendant off-3hore                                        obstacle" for the oil Industry.
                   development would affect reading areas for the bowhead whales in
                   Demarcation Bay, and disrupt migration routes for all species. The                                            Nearly all of the few lakes, rivers and streams Of the coastal
                   tMPIiC8tiOn3 need to be assessed In the Report.                                                          plain freeze solid In the winter months.   Those that are deep enough not
                                                                                                                            to freeze to the bottom, or that do not freeze entirely becaus? of warm
                        Other terrestrial mammals Include Moose. wolves, grizzly bears,                                     springs, are used by fish for overwintering areas.    Likewise, gravel is
                   arctic foxes, wolverines and other small mammals.   Though each of these                                 in short supply on the C023tal plain, and is a much-needed material for
                   species will be affected to one Jegree or another, no comprehensive                                      the construction of well pads, roads, airstrips, port facilities and
                   discussion of cumulative impacts is contained In the Report. Since this                                  causeways.
                   is an environmental impact statement, CEQ regulations (40 CFR Sections
                   1502.16 and 1508.8) require a discussion of cumulative impacts be done                                        Apparently. the most feasible means of solving both shortages Is to
                   for all wildlife species.                                                                                mine for gravel In stream and river channels, which would create deep

                                                       -12-                                                                                                     -13-

                     pools that would remain unfrozen during the winter.   If this is the                                                                    Air Quality
                     case, then it Is difficult to understand how the Department can claim
                     such development would cause only minor impacts to fish resources,                                           Discussion or likely degradation of air qualtity as a result of
                     especially when the Report in another section notes that taking the                                     intensive industrial activity is essentially nonexistent in this
                     amount of water necessary from a water-deficient coastal plain could                                    document.  Four brief paragraphs In Chapter II note that effects on air
                     result in major adverse effects. The effects of this scenario are                                       quality are localized.
                     unsatisfactorily discussed in the Report. More complete discussion
                     should be contained in the final Report.                                                                     Mention is made of arctic haze, an ominous phenomenon of increasing
                                                                                                                             concern.  Its implications to the coastal plain are not discussed even
                          The Report notes that "populations or slow-growing fish can be                                     though news reports from the past year cite studies that show increased
                     affected easily by changes in environmental factors." Some of the                                       ground temperatures and associated melting of permafrost In arctic
                     anticipated changes could be increased turbidity, decreased water                                       Alaska.  The ramifications of these changes are unknown, but potentially
                     quality, and changes In stream courses. as well as disruptions in the                                   serious to the arctic biota.
                     off-shore currents. This will present a much greater Impact to
                     anadromous and freshwater species than the Report addresses. and a                                           The extent to which emission Of Pollutants from North Slope
          9          reassessment or these impacts needs to be conducted In the Report.                                      industrial activities contributes to this environmental dearsdatton
          i@                                                                                                                 should be looked at closely in the Report. Some characterizations of
          CA)             Additionally, the effects associated with reserve pits of drilling                                 North Slope Industrial emissions place them to the category of a
                     mud fluid discharges are just now in preliminary stages Of study.   These                               Chicago-sized city.   Self-monitoring by Industry has made an accurate
                     investigations have only begun in the last few years on the North Slope.                                assessment virtually impossible. Funding is lacking for monitoring and
                     The findings 30 far are not encouraging, and the scope of study is                                      enforcement agencies on the state and federal levels.
                     extremely narrow in these initial Stages. Still. results indicate that
                     "along with deterioration in water quality, the quality and quantity of                                      This is especially important, given that the   coastal plain is prone
                     organisms Used as food by North Slope bird species may be decreasing."                                  to temperature inversions, which concentrate pollutants nearer to the
                     Again, the cumulative effect should be addressed but is not.                                            ground and inhibit dispersal.   No studies have been Initiated to
                                                                                                                             investigate such a concentration's effect on the blots. More study is
                          Many questions are left unanswered In the discussion or water  and                                 needed regarding air quality before Congress has sufficient information
                     gravel resources. Congress is left with incomplete information on   which                               to allow oil and gas leasing.
                     to base its decision to open the area for oil and gas leasing.
                                                                                                                                                          Natural Diversity

                                                                                                                                  The opening paragraphs of Chapter I cite the Purpose$ Congress

                    delineated for the Arctic Refuge when it was enlarged in 1980.     The                                     or tmptoperly designed to produce   the desired effect.    Industry
                    first of four purposes reads, in part:                                                                     representatives have even gone so    far asto admit publicly that they
                                                                                                                               often do not abide by the Fish and Wildlife Service's mitigation policy.
                                  To conserve fish and wildlife populations and habitats in                                    which-ts applied to the Prudhoe Day industrial.development and which
                             their natural diversity including. but not limited to, the
                             Poicu    e caribou herd, @ . . polar bears, grizzly bears,                                        would be applied to any development on the Coastal Plain. Moreover,
                             muskox. Dall sheep wolves. wolverines, 36OW geese. peregrine
                             falcons and other migratory birds and Arctic char and grayling.                                   stipulations can be administratively changed ot tossed out.
                             (emphasis added)
                                                                                                                                    These factors inspire little faith In the ability of the Fish and
                         A major population decline and change of distribution of 20-40% for                                   Wildlife Service to ensure protection of fish and wildlife resources.
                    the PCH, and a 38%.reduction in its calving habitat, Is not conserving                                     ANILCA Section 1002 requires that the Fish and Wildlife Service examine
                    this wildlife species and its  habitat In Its natural diversity.                                           and request what additional legal authority would be necessary to     . ensure
                    Similarly, a major p.opulation decline and change In distribution of 50%                                   protection or fish and wildlife resources.
                    for muskozen is contrary to the natural diversity mandate. The same is
                    true for polar bear 3. snow geese and other wildlife species. All will                                           It Is apparent that protection Of POPU18ttOn3 and habitats in t     .heir
                    see impacts Congress did not intend them to experience when it expanded                                    natural diversity for most species is Impossible. and pollution of air
                    the Arctic geruge In 1980.
                                                                                                                               and water from noxious emissions and hazardous Wastes is unavoidable.
                         Another of the purposes:                                                                              In fact, the Prudhoe Bay Industrial development Is not the shining .
                                                                                                                               example both the oil industry and the Department claim it to be. Since
                              To fulfill the international treaty   obligations of the                                         1912. there have been 23.000 Oil Spills In the Prudhoe area. The two
                         United States with respect to fish and wildlife and their habitats.                                   largest of these spills, categorized as "small," were 200.000 gallons
                                                                                                                               and 658,000 gallons. Studies of 30-year-old oil spills in the arctic
                         This refers to migratory waterfowl treaties, which will be violated
                                                                                                                               show absolutely no recovery. The effects of emitting 80.000 to 100.000
                    if development is allowed to proceed on the coastal plain.                                                 tons of nitrogen oxides into the air - currently permissible for North
                                                                                                                               Slope operations -- are unknown because of little or no government
                                                Mitigation Measures
                                                                                                                               monitoring. Atlantic Richfield Company     recently signed a consent.decree
                                                                                                                               allowing them to exceed carbon monoxide    standards until early In the
                         The Department reels that in moat instance3.M8jOr IMPOCtS to fish
                    and wildlife and to the environment can be mitigated by placing                                            1990s. Finally, a state report notes that discharges from 20 out of 21
                    stipulations on development activities. Oil Industry representatives,                                      Waste disposal operations are in violation of government standards.
                    however. have at various times expressed their displeasure with such                                            Much of the dirty work   .is contracted out to smaller firms.
                    Stipulations.  Industry often claims such restrictions are unnecessary                                     Probably the most eye-opening example of abusive practices Involved a
                                                                                                                               firm which in 1983 had an illegal spill of approximately 10,000 barrels

                                                         -16-

                    of hazardous waste.    The fact that this work was contracted out does not                                     Oil Lesoqrces
                    absolve the oil industry's responsibility. The operations at Prudhoe
                    Bay are not the Idyllic model the industry would like the public to                                                  Using data collected from two years or seismic exploratory work,
                    believe. A lack or government monitoring and no enforcement of                                                 the Department estimates a range of Possible in-place oil resources.
                    mitigation measures have obscured the extent of the problems.                                                  The Department contends there is a 5% chance that 29.4 billion barrels
                                                                                                                                   or oil (BBO) and a 95% chance that 4.8 BBO could be found in 26
                         Additional authority is needed by the Fish and Wildlife Service and                                       different prospects scattered across the coastal plain.        The Report then
                    other agencies to minimize adverse environmental impacts. Yet. the                                             assesses the economically recoverable oil resource, and estimates that
                    Department in its Report makes no substantive requests that would enable                                       at the 5% probability level there could be 9.2 BBO, and 590 MBO has a
                    the Fish and Wildlife Service to minimize as much 83 Possible impact                                           95% chance or being recovered. The mean estimated value of in-place
                    :
                      Oct ted with development, If It is allowed. A more complete                                                  resources is pegged at 13.8 880 in-place. with 3.2 OBO recoverable.
                    ::min:tion of the need for additional authority should be included In
                    the final Reportt along with requests for such legal measures as would                                               Two very critical factors included in the meat of the Report are
                    be required to minimize environmental degradation.                                                             omitted from the executive summary. First. the economically recoverable
                                                                                                                                   oil resources are calcuated at prices of $33 and $40 per barrel.
                    Sub3l3t_ence                                                                                                   Second, the chance of actually finding any deposits that could be
                                                                                                                                   considered commercial. figured at the lower price, is a mere 19%.
                         The third purpose outlined for the Arctic Refuge Is:                                                      Stated another way, at a price of $33 per. barrel, there 13 more than an
                                                                                                                                   80% chance that no oil could be recovered economically rrom the coastal
                                   To provide, in a manner consistent with the     purposes set                                    plain of  the Arctic Refuge.
                             forth (above]. the opportunity.ror continued subsistence uses
                             by local residents.
                                                                                                                                         The Department has misled the public in its executive summary about
                    The Report candidly admits that the major adverse effects to the                                               the likelihood of recovering oil from the coastal plain.
                    Porcupine Caribou Herd, "in combination with adverse effects on other
                    ub31stence use species, disruption of traditional subsistence use                                                    Furthermore, to compare any oil prospects or the coastal plain to
                    :ttes, and likely Psychological effects OP a people accustomed to                                              the Prudhoe Bay fields Ignores some of the Report's findings. The
                    Isolation, will result In a major adverse effect on subsistence uses        in                                 discussion of geology notes that "none of.the sampled 0113 are similar
                    the 1002 area."                                                                                                to Prudhoe Bay oil." Additionally, potential oil reserves of the
                                                                                                                                   Coastal plain would be found at depths or 26,000 feet, more than three
                         This ancient way of life would be completely and undeniably lost to                                       times the depth oil reservoir   a at Prudhoe Bay are found.     The analysis
                    a cash-based economy. This is contrary to the purpose quoted above.                                            of geological formations. moreover, finds marked differences between the
                                                                                                                                   "relatively simple structure that underlies" the Prudhoe Bay area and

                                                                                                                                                                        -19-

                    the ",Complexly folded and faulted" subsurface of the Arctic      Refuge                                            The highest probabilities for finding economically recoverable oll
                    Coastal plain.                                                                                                 on the coastal plain would be In amounts that are virtually identical to
                                                                                                                                   the size of fields described above. The Aleaka.Department or Natural
                         The Report further acknowledges that lr@-place oil estimates clearly                                      Resources assessment of the Coastal plain's oil potential backs this
                    Include "many deposits well below any economic size limit which may                                            statement, finding a 95% chance of only 80 HBO present, with 35%
                    currently be assumed for the Arctic. and Includes deposits Which have                                          recoverable.
                    reservoir characteristics that preclude them from.being economic." This
                    is calculated at an extremely optimistic price of $33 per barrel (in                                                Unfortunately, the Department's analysis contained in the Report is.
                    1984 dollars). The Alaska Department of Revenue price projections do                                           not tempered with a less optimistic economic scenario. Instead, the
                    :
                    ot foresee oil prices reaching that level for at least the next                                                Summary misleads the public by misrepresenting economic recoverability.
                     ighteen years:                                                                                                Only by carefully scrutinizing the contents buried in the Report does.
                                                                                                                                   this important facet become clear.
                                    1987                  $13-00/barrel (1981 dollars)
                                    1990                   14.98                                                                        The Department should provide    an analysis of economically
                                    1995                   15-88
                                    2000                   17-38                                                                   recoverable resources using more realistic oil price projections.         This
                                    2005                   19.54                                                                   13 critical to later discussions In the Report that discuss benefits.
                        'Admittedly. price projections Ore subject to a high degree or                                             from producing oil to the national budget deficit an     d to state and local
                                                                                                                                   government revenues.
                    uncertainty; yet there are strong indications In the world oil market
                    that conservative projections are more realistic for estimating future
                    Iprice trends. The price the Department Uses to.base economic                                                  National Need
                    feasibility of potential oil reserves 13 unquestionably too Optimistic.
                    The present and reliably predicted future oil price is the primary                                                  While many of the substantive discussions in the heart of the
                    factor preventing several proven North Slope discoveries from being                                            Report concerning wildlife resources, environmental consequences and
                    Initially tapped or from continuing production. The onshore West Sak                                           geological formations are admirable to their objectivity# the chapter
                    field contains 750 HBO to 1 BBO of proven reserves, yet remains untapped                                       which examines the national need for the coastal plain's potential oil
                    by the lessee, Atlantic Richfield Company. Another onshore deposit.                                            13 fraught with subjectivity.
                    Milne Point, began production over a year ago, but operator Conoco
                                                                                                                                        The Report list$ and briefly describes the contribution to national
                    recently shut down production from this 60 HBO field. Three off-3hore
                    deposits in the arctic - Seal Island, Colville Delta and Sandpiper -                                           objectives production of potential oil from the coastal plain might
                    collectively hold upward of 750 HBO. Oil prices would need to be $24                                           make. Three of the six include:
                    per barrel to cover high capital expenditures of arctic oil development
                    for the fields noted above. The potential oil fields of the coastal
                    plain would incur the additional expense of drilling deeper to reach the
                    oil.

                                                       -20-                                                                                                           -21-

                            Reducing dependence on imported oil                                                                 to be 90%'depleted by 2004. Oil flows from the Middle East in stable
                            Enhancing national security                                                                         supplies currently, and at relatively low prices due to a world-wide
                            Improving international trade balance                                                               oversupply. The Strategic Petroleum Reserve, created by Congress to
                                                                                                                                provide a burrer in the event or a supply interruption. should be filled
                        These are substantially the same point.                                                                 to two or three times Its 1986 target level. Yet the present
                                                                                                                                Administration has ceased oil deposits into this reserve at its 1985
                        As domestic oil production Continues to    decline. the U. S. becomes                                   level rather.than filling It to its minimal target of 750 MBO.
                  increasingly dependent on foreign sources of     oil. This dependence
                  increases the nation's trade deficit and possibly subjects the nation to                                            The nation should aggressively pursue energy conservation programs
                  an interruption or oil supplies. Both these situations jeopardize the                                         that have proved effective in the last decade and we should continue
                  national security.                                                                                            efforts to find alternative sources of energy. This Administration has
                                                                                                                                proposed discontinued funding for alternative energy and energy
                        The-Department contends potential oil reserves from the coastal                                         conservation programs. The President vetoed legislation passed last
                  plain could help prevent this situation from occurring by      significantly                                  year that would have saved the equivalent of a billion barrels or oil
                  contributing to the domestic supply or oil and go., D     url" the   r ield'a                                 per year by requiring energy standards for appliances. The
                  production life. however. no more than e% or u. S. production would be                                        Administration has rolled back standards for automobile fuel efficiency,
                  provided by this speculative field. Only 4% of U. S. need would be,                                           and favored raising interstate highway speed limits.
                  satisfied by potential oil ofthe coastal plain. The man estimated
                  recoverable reserve of 3.2 BBO represents only a six-month      supply at                                           Current recovery techniques of the oil industry can only recover
                  current consumption rates of 16 MW per day.                                                                   35% to 50% of' known oil reserves. The remainder is left in the ground.
                                                                                                                                There is as yet no concerted effort*by the Industry to enhance oil
                        Furthermore, the aforementioned   proven  fields in arctic Alaska                                       recovery rates.
                  could .be tapped at prices of $24 per   barrel. Those fields would then
                  contribute to domestic supplies. 1he Report      completely tginore3 these                                          While the Department .currently stresses   the need for the energy
                  prospects.                                                                                                    resource represented by the potential oil of     the coastal plain. it also
                                                                                                                                processes a permit ror a pipeline from the North Slope of Alaska to
                        Unquestionably. the U. S.   will become Increasingly dependent on                                       tidewater for exportation or natural gas     to the Far East      energy that
                  foreign   oil supplies. namely, the two-thirds of the non-coomnist                                            ironically could be,. used to  meet current  U. S. needs.
                  world's   oil reserves that We   round in the Middle East.
                                                                                                                                      These glaring  %"consistencies in a national   energy plan do not
                        In  the Interest of national  security, common  sense argues against                                    inspire confidence   ip-the Departme
                                                                                                                                                                     nt'3  assessment or national need for
                  draining  the nation's  dwindling domestic supplies.   which are   estimated                                  the coastal plain's potential oil resource.

                                                   -22-                                                                                                  -23-

                      The Department needs to present a summary or reassessment of the                                 so, and does not consider environmental consequences in relation to the
                 present Administration's current energy plant rather than merely quoting                              statutory mandate of maintaining wildlife populations and habitats in
                 bits and pieces of the Department of Energy's 1985 National Energy                                    their natural diversity.
                 Policy Plan. The Department should explain why it believes that
                 potential oil reserves or the coastal plan fit Into this plan. As Part
                 of this discussion, the Department should provide an In-depth discussion
                 of energy conservation measures and alternative energy sources, which                                     We. are compelled to urge the Department to select Alternative E
                 could decrease energy demand and lessen the nation's dependence on oil.                               Wilderness - and recommend such be adopted by Congress, in cider to
                 Finally. a detailed discussion examining the political and economic                                   provide the appropriate protection for preeminent wildlife and
                 ramifications or hastened depletion of the nation's last remaining                                    wilderness resources of the Arctic National Wildlife Refuge.
                 domestic oil supplies should be Included.

                      It 13 safe to assume, since answers to these important questions
                 are crucial to making a decision on the coastal plain's disposition.
                 that Congress Intended a comprehensive discussion that included these
                 aspects of a national need determination when It required such an
                 evaluation be incorporated in the Report. The Department has covered
       00        this component unsatisfactorily In the 5-page discussion contained In
                 the Report.

                 Conclusion

                      Sierra Club strongly disagrees with the Secretary's recommendation
                 that Congress should adopt legislation which would open the coastal
                 plain of the Arctic National Wildlife Refuge to full easing of oil and

                 gas resources.

                      The recommendation has been based on highly speculative information
                 regaiding potential oil reserves, and on an extremely biased and
                 self-fulfilling analysis of national need for the potential oil
                 underlying the coastal plain. The recommendation also fails to consider
                 cumulative impacts to the arctic blots, despite legal requirements to do

    SIERRA
      CLUB
    					330 Pennyslvania Avenue, S.E., Washington, D.C. 20003 (202) 547-1441

    				STATEMENT OF J. MICHAEL MCCLOSKEY

    						SIERRA CLUB

    						ON THE

    				ARCTIC NATIONAL WILDLIFE REFUGE

    			DRAFT COASTAL PLAIN RESOURCE ASSESSMENT

    					WASHINGTON, D.C.

    					January 9, 1987

    	The Sierra Club, a national conservation organization of 400,000

    members, supports statutory wilderness protection for the coastal plain

    of the Arctic National Wildlife Refuge.  Our Alaska Chapter, which

    testified in Anchorage on January 5, strongly agrees.

    	Sierra Club's support for wildlife protection and wilderness

    preservation of this one remaining area of the Arctic slope, which is

    not devoted to petroleum production, dates from before the days of its

    establishment in 1960 by President Eisenhower.

    	The Arctic National Wildlife Refuge, together with adjacent

    national park lands in Canada, comprise the most extensive and diverse

    undeveloped landscape in the American North, including unsurpassed

    wildlife values and a "mountains to the sea" spectrum of high Arctic

    ecosystems of life forms.  It is the home for the 180.000-animal

    Porcupine caribou herd (so named for the Porcupine River).  This herd

    		"When we try to pick out anything by itself, we find it hitched to everything else in the universe" John Alu_ _
    			National Headquarters 730 Polk Street, San Francisco, California 94109 (415) 776-2211

    								-2-

    includes half of all the caribou remaining in Alaska, and is the last

    large caribou herd which is intact and healthy, living in an intact and

    healty wilderness range.  These animals are essential to the

    subsistence culture of Eskimo and Indian peoples on both sides of the

    international border.

    	The Porcupine caribou herd calves and raises its young on the

    Arctic coastal plain within the Arctic National Wildlife Range.  This

    area has characteristics essential to the caribou during this critical

    portion of their life cycle.  These natural values overwhelm the

    conclusions reached by the 1002 reprot.

    	The Interior Department has attempted to prevent public input on

    the most import issue.  Only through the courst have we been allowed

    to review the draft report, much less comment on it in a public hearing.

    Furthermore, the Secretary's recommendation, and in particular the brief

    "executive summary" of the draft report, almost completely ignore the

    serious environmental consequences of full oil leasing, as delineated by

    FWS in the EIS section.  We do not feel this is in keepin with the

    responsibilities entrusted to government officials as stewards of our

    public lands.

    	The draft report predicts a mean of 3.2 billion barrels of

    recoverable oil in the 1002 area, but also notes that only a 19 per cent

    chance of economically recoverable oil is present.  This estimate is

    based in part on a questionable prediction of a $33 per barrel price of

    crude oil at the time of production.  Furthermore, under this scenario,

    under maximum production, the 1002 area would supply on 4% of total

    U.S. oil demand, and 8% of domestic production.   Its projected lifespan

    is only about 30 years for active production.

                                                     -3-                                                                                                       -4-

                      Except for the minor portion of the ANWR coastal plain east of the                                   only compare Prudhoe Pay oil development and its effects on wildlife to
                 1002 area now in   Ilderness, all of the other lands - state, Native.                                     development in the 1002 area with extreme caution. For example, the
                 and federal -- onshore and offshore, are open to or devoted to petroleum                                  magnificent 180,000-animal Porcupine caribou herd has 'its major calving
                 resources. These Include state-owned offshore and onshore lands between.                                  grounds and major insect-relief habitat in the 1002 area.    The absolute
                 Prudhoe Bay and the Canning River, such as the Camden Bay and                                             density of this herd on its calving grounds is 14 times that of the
                 Demarcation Point Lease Sales of 1987 and 1988 and Federal OCS lands in                                   Prudhoe-area Central Arctic Herd of some 12,000-14,000 animals, giving
                 the Beaufort Sea, such as proposed Lease Sale 97. There may be oil                                        the Porcupine herd little room to adept to oil production or to escape.
                 development offshore and in the Mackenzie River Delta of Canada.                                          There has been almost no reported calving by the Central Arctic Herd in
                                                                                                                           the Prudhoe Bay oil fields since oil development. Full oil production
                      Not only do these adjacent development Possibilities make the                                        also could result In loss of much of the insect-relief habitat available
                 protection of wilderness values In ANWR more essential, but they 8130                                     to the Porcupine herd.   The FWS predicts that a major population decline
                 may produce a cumulative impact on the region which Is not analyzed in                                    and change in distribution of 20 to 40 percent could occur.
                 the draft report.
                                                                                                                                Some of the other significant effects on wildlife could include a
                      A major weakness of the 1002 report Is its failure to explain                                        25-50 Percent population decline or change In distribution of muskoxen,
                                                                                                                           which now number about 500 animals; a moderate decline in brown bear
                 adequately how water will be obtained for exploratory drilling.     It
                 takes about 15 million gallons of water to drill one exploratory well;                                    numbers;  a moderate decline in golden eagle numbers, and a,major cnange
                 yet the FWS states that there is simply not much water available in the                                   In.lesser snow geese distribution of up to 50 percent.
                 1002 area for oil exploration, which is usually done In the winter.
                 Almost all of the lakes and 24 major streams In the 1002 area freeze to                                        As pointed out by the Goverment of the Yukon, "There is no
                 bottom in winter and are not available for water access.    The                                           adequate treatment of the transboundary consequences of those direct
                 suggestions offered in th .a report for obtaining water range from the use                                impacts [on wildlife that utilizes the coastal plain and Canadian
                 of piped-in seawater to the creation of deep streambed3 by gravel                                         habitats] or is an important constituent of a larger regional
                 mining.   The Fish and Wildlife Service calls water access a major                                        population." This criticism is very well taken, and again points up a
                 engineering problem for oil development in the 1002 area. yet does not                                    major flaw of the draft report -_ the attempt to isolate the coastal
                 predict the environmental consequences of the proposed schemes to obtain                                  plain for purposes of Impact analysis.   This basis shortcoming must be
                 it.                                                                                                       corrected if the final Assessment is to assist Congress in its
                                                                                                                           decision-making process.

                      The fish and wildlife values of the 1002 area are incomparable.
                 According to the report. the environmental consequences of full oil
                 leasing would be devastating.   Contrary to oil industry claims, we can

                                                                                                                                                                  -6-
                                                        -5-

                                                                                                                                  The omission of discussion concerning energy conservation programs
                         The draft report also predicts that oil development will have 9                                      and alternative energy sources completely discounts any possibility of
                   major adverse effect on the subsistence lifestyle of Native people.                                        prolonging existing supplies and lessening the perceived need for oil
                                                                                                                              from the coastal plain.  The underlying premise is to allow complete
                         The Sierra Club finds the above environmental consequences of oil
                                                                                                                              depletion of.this country's last remaining on-shore oil supplips,
                   exploration andlor production in the 1002 area totally overw1nelming. We                                   without coherent plans for a future with severe shortages of domestic
                   do not accept the Secretary's citing of national security as sufficient                                    oil.  Ibis would be ironic if It were not for the recent Presidential
                   justification to drill in this area. -In fact, the discussion in the                                       veto of the National Appliance Energy Conservation Act which would save
                   draft report on the notion's need for any oil that might be found on the                                   1.47 billion barrels of fuel and $3 million to consumers over ten years.
                   coastal plain is inadequate.                                                                               Such policies are not in the national interest.

                         A detailed discussion and comparison of alternative   strategies for
                                                                                                                                  There is no discussion of a proposed land exchange with various
                   meeting the nation's energy demands and objectives should be part of                                       Alaska Native regional corporationst In which some subsurface estate in
                   this LEIS.   An analysis of alternatives is of course the essence of the                                   the coastal plain would be exchanged for corporation-owned inholdings
                   environmental impact statement process.    Congress is not well served by                                  within other nati.onal wildlife refuges In Alaska.   This bundle of
                   an LEIS that.discusses -_ and unabashedly promotes      only one strategy.                                 exchanges is sometimes rererred to by the Department as the "megatrade."
                         Among other alternatives is one that permanently forgoes
                                                                                                                                   In his introduction to the draft report, Assistant Secretary ttorn
                   exploration and possible development of the coastal plain in favor of                                      observes that "Development must result in no unnecessary adverse effects
                   reliance an oth .er existing and potential oil and gas reserves.    For                                    and unavoidable habitat losses should be fully compensated."     As the
                   example, instead of permitting the export of North Slope natural gas                                       draft report acknowledges, there will be substantial adverse effects and
                   (other than possible reserves in the ANWR) to Far Eastern markets,                                         unavoidable habitat los.sea 8330CiOt.ed with the proposed leasing.    The
                   Congress could prohibit such export In the interest of domestic                                            megatrade is the compensation envisioned by the Department and thus is a
                   consumption.
                                                                                                                              fundamental part of the Administration's proposal to open the coastal
                         More efficient use of existing  energy could also  help meet the                                     plain to full leasing.
                   national need for additional energy   and at the same time avoid the                                            Already. several hundred thousand dollars or federal funds have
                   permanent environmental degradation   of the ANWR that the draft repo  Irt                                 been expended for appraisals, negotiations, and other aspects of the
                   acknowledges will occur if leasing Is allowed and economically                                             proposed megatrade.   According to the U.S. Fish and Wildlife Service,
                   recoverable quantities of oil and -gas are discovered.
                                                                                                                              the Service hopes to submit the proposed exchange to Congress at the

                                                       -7-

                   :
                     e time as the final Resource Assessment Is submitted or as soon                                                      "Why is the Sierra Club so concerned about Alaska? Is it the
                   hMereafter 83 possible.                                                                                           tremendous areas of scenic magnificence In Alaska? Is it the great
                                                                                                                                     number and variety of its wild rivers? Is It because In Alaska
                        In order that the public and Congress may have the opportunity to                                            there room freely the lost great herds of large wild animals in our
                   :ssess the Administration's entire proposal, the final Assessment should                                          country?   Is it because in Alaska there is the lost of our
                   nclude a full discussion of the proposed megstrade.                                                               unspoiled wilderness remaining on a grand scale?    .Is it because in
                                                                                                                                     Alaska people can experience the wonders of nature as they can
                        Finally, we oppose any oil drilling in the 1002    area because It                                           nowhere else on earth?
                   will destroy forever one of North America's greatest    wilderness areas.
                   No amount of reclamation would ever render this area    "wilderness" again.                                            "It is because of all these reasons -- and much more -- that
                                                                                                                                     we are testifying here today.    For we believe that In Alaska there
                        We are not merely trying to protect beautiful scenery in the Arctic                                          are rare -- Indeed unmatched -- opportunities for all the. people of
                   Notional Wildlife Refuge, nor are we merely attempting to maintain a                                              the United States.   There is not only the superb scenic and
                   population of magnificent and unusual animals. We are trying to                                                   wildlife resource and unmatched recreational potential. there is
                   preserve the best, the largest, the most diverse migratory wildlife                                               the chance for our country to make wise decisions - to combine
                   wilderness habitat on the continent.                                                                              good development with good conservation -- and to do it right the
                                                                                                                                     first time.   In Alaska we have an unparalleled opportunity to learn
                        Let me refer to the statement of Dr. Edger Wayburn, chairman of the                                          from our past mistakes. In the post, we have been all too generous
                   Club's Alaska Task Force, to the House Interior Committee in 1977:                                                with many of our country's greatest treasures . . . We have given
                                                                                                                                     away California's coastal redwoods, the Big Thicket in Texas.
                             "The Sierra Club itself has a long-time interest In Alaska.                                             Florida's Great Cypress swamps - to name only a few. Now we are
                        The Club's founder and first president, John Mir. went to Alaska                                             having to buy them back for the Omerican people and at enormous
                        three times on extensive Visits, starting in 1879.     The Club's                                            cost.  In Alaska. we have this remarkable opportunity -- we can set
                        Intense concern, however, dates to 1967. when the Directors of the                                           aside superb national lands for their highest and best use at no
                        Sierra Club made the future of Alaska's land one of our 6 priority                                           cost to the American people - the people to whom they now belong.
                        projects. Today, with some 170,000 members all over the country,
                        the Sierra Club has made Alaska's National Interest Lands our                                                     "The critical decisions in Alaska are being made at this
                        number one priority.                                                                                         moment. And these decisions are being made by you. Congress has
                                                                                                                                     already dealt generously With the State of Alaska.      In the
                                                                                                                                     Statehood Act of 1958, Congress granted the new state 104.2 million
                                                                                                                                     acres of land, and approximately 45 million acres of tidelands and

                                                        -9-                                                                                                             _10-

                         submerged lands passed into the ownership of the state at the same                                                   "A second. related principle behind HR 39 is that the national
                         time.  Thus Alaska was granted a total of nearl    y 150.000,000 acres                                         interest lands should be administered by the most appropriate
                                                                                                                                        agency.   HR 39 places administration of these lands primarily under
                         of land, more land than was granted all the 17 western states
                         together.   150,000,000 acres. incidentally, is an area 1-112 times                                            the two agencies of our government which are charged with the care
                         the entire state of California.                                                                                of natural ecosystems: the National Park Service and the Fish and
                                                                                                                                        Wildlife Service. The National Park Service is charged with the
                              @'Cbngress has also dealt generously and fairly with the Native                                           objective of preserving land In its natural state, and providing
                         peoples of Alaska, conveying to them some 43.7 million acres to be                                             for human use and enjoyment of the land consistent with that
                         their private property to use as they choose -- along with nearly                                              preservation.    The Fish and Wildlife Service.is charged with
                         one billion dollars in cash.     Congress has in the past also set                                             protection of habitat for wildlife in the National Refuge System.
                         aside key areas in Alaska to remain in particular Federal                                                      We propose that these two systems are the proper ones for the
                                                                                                                                        protection of most or the Federal lands in Alaska and tne
                         ownership. It now seems opportune for Congress to reserve the
                         remainder of the unappropriated public lands of Alaska for their                                               perpetuation of the vast wildlife populations they shelter."
                         highest and beat use for all the American people. We are convinced
                         that the highest and beat use for these lands is a status wnich                                                The principles that led to Sierra Club's original involvement in
                         will protect for all time their unequalled natural values."                                               the Alaska Lands legislation. H.R. 39. remain unbowed today for tne
                                                                                                                                   coastal plain of the Arctic National Wildlife Refuge is tne quintessence
                                                                                                                                   of the natural values remaining in Alaska.      Chancy, environmentally
                                                . . . . . . . . . .
                                                                                                                                   destructive energy development in this one magnificent place is not in
                              "HR 39 is based on the general principle that significant                                            the national interest.
                         portions of the wildlands of Alaska which are now in the public
                         domain should remain in public ownership because of their
                         'nationally significant natural, scenic, historic, geological,
                         scientific, wilderness, cultural, recreational, and wildlife
                         values.'   Therefore, the policy goals include preservation of the
                         wildlife, both the resident populations and the millions of
                         wildrowl which migrate seasonally; protection of the habitat In

                         Arctic and sub-Arctic ecosystems; preservation of historic and
                         archaeological sites and cultural values of Native peoples;
                         protection -3f the wilderness; and provision of wilderness

                         recreational opportunities.

    Tustees for ALASKA

    						February 5, 1987

    Noreen Clough
    Division of Refuge Management
    U.S. Fish and Wildlife Sevice
    18th & C Streets
    Washington, D.C. 20240

    Dear Ms. Clough:

    	Enclosed please find the comments of Trustees for
    Alaska on the Department of the Interior's Draft Arctic
    National Wildlife Refuge, Alaska Coastal Plain Resource
    Assessment.  Thank you for your attention to these
    comments.

    					Very truly yours,

    					Robert W. Adler
    					Executive Director

    725 Christensen Drive, Suite 4 Anchorage, Alaska 99501 (907)276-4244

    Trustees for ALASKA

    				TRUSTEE FOR ALASKA'S COMMENTS

    				ON THE DRAFT RESOURCE ASSESSMENT

    				FOR THE COASTAL PLAIN OF THE

    				ARCTIC NATIONAL WILDLIFE REFUGE

    					FEBRUARY 5, 1987

    I. INTRODUCTION

    	Trustees for Alaska submits the following comments on the U.S.

    Department of the Interior's Draft Resource Assessment for the

    Coastal Plain of the Arctic National Wildlife Refuge, prepared

    pursuant to section 1002 of the Alaska National Interest Lands

    Conservation Act (ANILCA) and section 102 of the National Environ-

    mental Policy Act (NEPA).  Trustees for Alaska is a nonprofit,

    public interest environmental law firm with approximately 700 mem-

    bers within Alaska and in other states.  The opportunity to comment

    on this draft of the section 1002 report was provided only as a

    result of a lawsuit filed by Trustees for Alaska.  The court ruling

    required Interior to provide both an opportunity for written com-

    ments and public hearings, and emphasized that Interior was re-

    quired to incorproate and to respond to public comments in the

    final report to Congress.  To comply with this mandate, Interior

    must address each of these comments in its final report, as well as

    725 Christensen Drive, Suite 4  Anchorage, Alaska 99501 (907)276-4244

             the comments raised by other parties.     40 CFR 1502.9(b).                                 to submit a now version of tile report for public rev I ew.be fore

                  The Interior nepartment violated the spirit of tile    court or-                       presenting a final report to Congress.      The NEPA implementinU regu-

             der, which expressly required the Department to provide     tile ."local                    lation of the rouncil on Environmental QualItY state that if a

             population" an opportunity to comment    on the report, by. fail iiig to                    draft statement Is "so inadequate as to preclude nteaninuful analy-

             hold public hearings in Fairbanks,    Arctic Village, arid other loca-                      sis," a revised draft.shall be    prepared and circulated for addi-

             tions where significant public interest was evident.      Moreover. it                      tional public review.- 40 CFR 1502.9(a).

             was unconscionable for Interior to schedule tire    pub] ic colitillent                          Our comments are divided Into twomain sections. The first

             period and the public hearings over and through     the Christmas and                       section will outline'the broad legal and substantive deficiencies

             New Years holidays, particularly when the District Court decision                           in the draft report,.and will cut across a number of.specific sub-
             had been rendered almost a full year before the hearings were held.                         ject areas. The second section will address specific amissions and

             Even the extended public comment period was insufficient given the                          deficiencies involving particular environmental issues.

             complexity and importance of this issue. By scheduling public.                              II. Major Deficiencies in interior's Analysis

             hearings in this manner, the Department continued its po    .]icy of                             The draft 1002 report is riot merely deficient in the details

                          &.....                                                                         of its an.-l,--sis.

             possible.                                                                                   sions and analytical flaws that render it completely inadequate for

                  However.  the procedural deficiencies in the Department's pro-                         purposes of Congressional   review. First, the report does not com-
             cess are dwarfed by  the substantive problems   with the draft report.                      ply with a number of applicable laws'and regulations, including

             Many of these deficiencies run to the heart of Interior's analysis.                         NF.PA and ANILCA.  Second, tire report suffers.from additional broad
             and.render the current version of the report almost entirely inade-                         analytical defects.    It suffers from art exceedingly narrow and

             quate as a basis for Congress to m  ake an informed decision as to                          obviously result-oriented perspective; It lacks an adequate evalua-

             the proper management of the coastal plain of the Arctic National                           tion of wildlife habitat and carrying capacityl and most important-

             Wildlife Refuge. More importantly, the draft report does not                                ly. the conclusions do not match the body of the report, as if the

             cIomply with a number of relevant laws and regulations, including                           author of the draft Secretarial RecomiliendatIon section did not read

             NEPA and section 1002 of ANUCA.    renderiny the report legally defi-                       the rest of tile document. These broad deficiencies will be de-

             cient and Inadequate. As a result of these deficiencies. we be-                             tailed below.

             lieve that the proper course would be for the Department to rewrite

             the report completely, based on the public comments received. and

                                                                                                                                             3
                                                 2

                 A.  Legal Deficiencies                                                                         The environmental effects of oil and gas develolmient in the

                       2.  NEPA                                                                           Arctic National Wildlife Refuge cannot be separated from the ef-

                 Tn Trustees for Alaska   v. Hodel, the Interior Department                               fects of similar develooment both onshore and offshore along the

           ultimately conceded that it    was required to include, as part of the                         entire coast of Alaska and Canada.      This development includes ex-

           sec tion 1002 report, a legislative environmental impact statement                             ploration and extraction from the NPRA, state leases at and around

           under section tO2(2)((') of NP.PA.    However, the draft report fails                          Prudhoe Ray, extensive existing and proposed state leases in coast-

           to comply with a number of well-accepted requirements for environ-                             al lagoons across the entire northern Alaskan coast, existing and

           mental impact statements.     Most clearly, the reports fails to con-                          proposed leases in the Beaufort Sea (Sale 97), and existing and

           sider a large number of individual environmental issues addressed                              proposed exploration and development onshore and offshore in the

           In part 2   of these comments, such as air quality and water quality.                          Canadian Beafort.    Maps of this extensive development can be found

           But the report falls short of NEPA requirements In a number of more                            in the Mineral Management Service's DEIS on Proposed Sale 97 (Beau-

           comprehensive respects discussed below.                                                        fort Sea) (Sale 97 DEIS) and in     the State of Alaska's Preliminary

                 Cumulative Impacts Analysis                                                              Best Interest Findings on Proposed Sale 50 (Camden Bay) (Sale 50

                 First, the report fails completely, and in many cases express-                           Findings). For example, the Sale 50 Findings note that the state

           ly, to consider the cumulative environmental impacts of oil and gas                            has leased more than 3.6 million acres since 1964, and plans to

           development In the Arctic National Wildlife Refuge with similar                                lease an additional 1.9 million acres on the North Slope within the

           development elsewhere in arctic Alaska and Canada. This type of                                next five years.

           analysis is fundamental to NEPA review. particularly where a pro-                                    The resources that are threatened by the leasing proposal are

           ject will have regional impacts. Kleppe v. Sierra Club. 427 U.S.                               not,  in many cases, local in nature. This is particularly true for

           390 (1976).   The CEQ regulations require EISs to evaluate both                                migratory species such as marine mammals. waterfowl and other bird

           direct and indirect environmental effects, 40 CFR 1502.16. which                               populations. caribou, anadromous fish, and other resources.         More-

           encompass cumulative environmental impacts.       40 CFR 1508.R.     A                         over, Interior's approach does nut recognize that habitat losses

           "cumulative Impact" Is defined ass                                                             within the ANWP, in combination with similar habitat losses else-

                       the Impact on the environment which results from the                               where, may have substantial effects on regional resources.
                       incremental impact of the action when added to other
                       past, present, and reasonably foreseeable future actions                                 Tnterior's failure to consider cumulative impacts is all the
                       regardless of what agency (Federal or non-Federal).or
                       person undertakes such other actions.                                              more  difficult to understand IF) light of the fact that the develop-

           40 CFR 1508.7.                                                                                 ment  of the Arctic National Wildlife Refuge is considered a neces-

                                                4                                                                                             5

    sary economic prerequisite to the development of the nearshore

    coastal lagoons owned by the state.  (Sale 50 Findings).  Indeed,

    development of the two areas will almost certainly share onshore

    support facilities, including port and loading areas.  Yet the 1002

    report fails to address the cumulative effects of development with-

    in the 1002 area with development of the coastal lagoons along the

    entire coast of the Refuge.  Given the intensive use of this area

    by resources that migrate beetween onshore and offshore areas, such

    as birds, marine mammals, caribou, and anadromous fish, this flaw

    is fatal to the adequacy of Interior's review.

    	Similarly, the 1002 report does not address the relationship

    between 1002 development and proposed federal OCS leasing in the

    Beaufort Sea.  Incredibly, at the same time that its sister agency

    is proposing full leaisng of the ANWR coastal plain, MMS assumes in

    its Sale 97 DEIS that effects on the Porcupine Caribou Herd from a

    pipeline and road across the coastal plain are "not likely to occur

    ... since an onshore pipeline is not assumed to occure under the

    proposal" (p. TV-B-68).  But if oil development occurs in both the

    ANWR and in the eastern portion of the Beaufort Sea, pipelines from

    the eastern Beaufort would logically intersect the ANWR onshore

    pipeline.  Yet the cumulative effects of this development are not

    considered in either document.

    	There are a large number of examples of the types of cumula-

    tive effects on biological and other resources that should have

    been considered in the 1002 reprot, but a few examples will suf-

    fice.  Perhaps the most glaring example is the statement that

    disturbance to polar bear denning sites:

    						6

    	would not likely affect the species' overall survival, so
    	long as similar intensive development did not occur along
    	the entire northern coast of Alaska and Canada.

    1002 Report, at 118.  But as noted above, similar intensive develop-

    ment is either occuring or planned throughout the northern coast of

    Alaska and Canada.  The 1002 reprot notes the possible effects of

    losses of polar bear denning sites on the overall popluation (pp.

    117-18).  In particular, Amstrup et al. assert that the Beaufort

    population can withstand little if any increase in the mortality

    rate of females.  In light of these realities, the lack of a cumula-

    tive impacts analysis of this issue is difficult to understand.

    Notably, the Sale 97 DEIS predicted "moderate" effects on the polar

    bear population without consideration of development in the ANWR or

    in the state coastal sales.  Obviously, these effects will be fur-

    ther exacerbated by disturbance to denning sites in the Camden Bay

    and Demarcation Bay lagoons, and in the ANWR coastal plain.  No

    agency has evaluated the total impact on the polar bear population.

    	Another example of an important cumulative impact ignored in

    the 1002 reprot is the effect of port and causeway development on

    water quality and fish migration.  Interior predicts generaly minor

    effects on aquatic resources from causeway construction.  1002

    Report, at 125-26.  Yet evidence indicates that the West Dock and

    Endicott causeways are already resulting in adverse effects, and

    the Sale 97 DEIS (p. TB-B-24-25) predicts MAJOR cumulative offshore

    effects form additional developments, without including development

    in the ANWR and the offshore state waters.  Interior not only under-

    states the potential effects of similar developments in the ANWR

    alone, but fails to consider the cumulative effects.

    						7

                Similar arguments can be raised with respect to a large riuifber                  action.  40 CF11 1.502.1.4.
           of additional issues.   The continuation of tile proposed pipeline                          The 1002 Report sets forth a range of alternative-; fur tile
           across the coastal plain on state lands between Prudhoe Bay arid the                   management of the coastal plain of the Arctic National Wildlife
           Canning River, which would occur as a direct result of tile develop-                   Refuge, from wilderness designation to full-scale oil and gas leas-
           ment of the coastal plain. w-ill transect a major calving area for                     ing.  However, the fundamental reasoning behind the proposed Sec-
           the Central Arctic Caribou Herd (CAH), but no analysis of the ef-                      retarial recommendation for full leasing is the national need for
           fects of this development on tile CAH is given. Tire report dis-                       enerqy resources from tire Arctic National Wildlife Refuge. Nowhere
           cusses chronic water quality degradation due to leaking drilling                       does the document evaluate alternative means of meeting the cited
           muds reserve pits and other sources of waste discharge, but aside                      energy need, as is required to give the  decisionmakers (The Sccre-
           from quantifying the number of acres effected. no attempt Is made                      tary and Congress) and the public a valid basis for a reasoned
           to assess the long-range and cumulative effects of this chronic                        decision on this Issue.   In particular. there is no analysis of
           degradation. The Sale 97 DEIS engages in a comprehensive cumula-                       other energy supply sources, or more iMDortantly, of available arid
           tive oil spill and fuel spill risk assessment, but expressly omits                     anticipated methods of reducing the nation's consumption of petro-
           the ANWR and offshore state sales. This gap Is not filled by the                       leum resources rather than extracting these resources from the last
           1002 report. despite the need to transport large quantities of fuel                    great arctic wilderness in the United States.    Notably, even tile
           through the two proposed port facilities.                                              Sale 97 DEIS includes a consideration of alternative energy
                Until the 1002 report is revised radically to include a compre-                   sources, including energy conservation and efficiency. while this
           hensive cumulative environmental impacts analysis. It falls short                      analysis is woefully deficient (for example, it relies on 1979
           of the well-accepted standards for environmental Impact analysis,                      information), at least it recognizes the basic NEPA requirement to
           as required by NEPA and the CEQ regulations.                                           evaluate alternatives to the project. Failure to consider otber
                Consideration of Alternatives                                                     strategies for meeting the nation's energy needs essentially consti-
                Evaluation of all reasonable alternatives Is another mainstay                     tutes a failure to give due consideration to tire wilderness or no
           of NEPA analysis. Natural Resources Defense Council v. Morton. 458                     action alternatives In the 1002 report, because these options are
           F.2d 827 (1972).  In fact, the CEQ regulations indicate that the                       dismissed out of hand on the basis of national security arid need
           evaluation of alternatives is the "heart of the environmental im-                      for energy.
           pact statement." and require the agency to "rigorously explore arid                         Interior's approach is particularly diuturi>ing given this
           objectively evaluate all reasonable alternatives" to tire proposed                     Administration's sorry record in the area of alternative energy

                                                                                                                                  9

            resources. The Administration proposes to lease the Arctic Natiun-                         even Lhe most uptimistic predictions for ANWR can be reaped using
            al Wildlife Refuge at the same time that it rejects programs that                          available but untapped energy efficiency strategies, at far lower
            would save a good portion of the oil that might be extracted from                          economic and environmental cost.    The 1002 report, however, ignores
            the Refuge.                                                                                this potential resource entirely .(as well as all energy supply
                 For example, President   Reagan vetoed the National Appliance                         sources other than oil). and assumes that only oil extraction can
            Efficiency Act, which would  save approximately 1 billion barrels     of                   meet the cited demand growth.
            oil, and the energy equivalent of 3 billion barrels of oil.       The                           Interior's failure to consider alternatives to Increased oil

            Administration also proposes to repeal fuel economy standards for                          arid gas extraction as a means of meeting national energy needs is

            automobiles. and to raise the speed limit on Interstate highways,                          all the more inappropriate given the tinte-frame of the analysis.
            both of which will increase oil consumption for reasons that are                           oil and gas extraction from the ANWR will not occur for -at least
            entirely unrelated to national security and energy Independence.                           10-15 years. Existing energy efficiency resources could substan-
            In short, the Administration's policy is to increase the demand for                        tially reduce the demand for petroleum resources. as demonstrated
            oil for reasons of personal comfort or   convenience, and then to                          In Lovins' comments, without evert considering improvements in eff21-

            Justify 0.11. an- gas developme-rit in sensitive environmental areas.                                       y. By the time the 1002 o!!field could be put into

            indeed, in national environmental treasures. on the basis of nation-                       place. these existing technologies could be saving far more oil

            al security. The only winners are the oil companies that reap                              than would be produced from the ANWR, at far lower cost. The only
            profits from petroleum.product odl  es. The American pub]   ic pays                        losers would be the oll companies. Moreover. given the tremendous
            more for their energy needs. and loses a major part of their nation-                       recent advances In this area, and ongoing improvements In energy

            a] wilderness  .3nd wildlife heritage.                                                     efficiency technology, there is strong reason to believe titat ever]

                 The case for using demand side energy strategies for meeting                          greater gains could be made, at lower cost, by the end of the

            the ehergy,4emand cited in the 1002 report Is far frow speculative.                        century.

            This case"was made in detail in comments submitted to Interior by                               Interior's complete failure    to consider alternative nteans of

            Amory rovins of the Rocky Mountain Institute an January 22, 1987,                          meeting the nation's energy needs is a fatal flaw in the DEIS. and
            which we incorporate herein by reference.     Mr. bovins notes tha  t                      constitutes a blatant violation of NEPA and the CEQ regulations.
            since 1979, the United States has gotten 50 times as inuch new ener-                       In fact. 40 CFR 1502-.16(e) and (f) expressly require the considera-

            gy from more ef*f1clent use than from all net increases uf energy                          tion of the energy conservation potential of alternatives.        This
            supply combined. and demonstrates clearly that equivalent energy      of                   deficiency should be. cured as part of a rewritten draft of the 1002

                                             10

    report.

    	Consideration of Long-Range Impacts

    	Interior inexplicably considers only the impacts of develop-

    ment that is expected to begin during the first 10-15 years after

    initial oil and gas leasing of the ANWR.  Most notably, the report

    ignores almost entirely the effects of gas production from the

    ANWR, beacuse it is beyond the time frame chose by Interior for

    analysis.  But no reason for the selection of this time-frame is

    given, and the report itself predicts that gas production would be

    economically feasible within 2-3 decades.  Prevailing NEPA law,

    however, requires the Department to consider the long-range impacts

    of developement, even if development proceeds in stages.  Cady v.

    Morton, 527 F. 2d 786 (9th Cir. 1975).

    	It is interesting in this regard to note Interior's own defini-

    tions of long-term versus short-term impacts:  "Effects that could

    likely persist 20 years or more were considered 'long-term' and

    those likely to persist less than 20 years were considered 'short-

    -term.'"  Based on this criterion, by excluding the effects of gas

    production because it is not likely to be economically feasible for

    2 or more decades.  Interior is considering only the "short-term"

    effects of leasing in ANWR.

    	Irreversible and Irretrievable Commitments of Resources and
    	Comparison of Short-term Uses and Long-term Productivity
    	These two sections are expressly required to be included in

    environmental impact statements under section 102(2) (c) of NEPA,

    and by the CEO regulations, as they form part of the fundamental

    basis for dicisonmaking.  Interior's treatment of these issues,

    however, is entirely summary and cursory in nature, and does not

    							12

    include the comprehensive explication required by NEPA.  In fact,

    it appears that these two sections, both of which combined comprise

    less than 3 pages, were simply tacked on to the 1002 report when it

    was decided that the report had to be accompanied by an EIS.

    	The summary nature of these two sections leaves little if

    anything on which the public can comment.  To give an example of

    the deficiency in these sections, however, nowhere does Interior

    explain in full the significant losses to the nation as a result of

    the elimination of the only remaining arctic coastal wilderness in

    the United States.

    	For example, the report should not that there would be an

    irretrievable loss of the only baseline area of the study of a

    complete scope of arctic ecosystems in North America.  This would

    constitute an irretreivable loss to the scientific community and to

    our civilization's ability to understand natural arctic ecosystems.

    The report should explain the uniqueness of this region as a wild-

    life and wilderness resource, rather than stating simply that

    long-range losses of these resources would occur.  The fundamental

    problem with Interior's treatment of these issues, both here and

    elsewhere in the report, is the lack of recognition that there is a

    major difference between the loss of some wilderness acreage on the

    North Slope of Alaska and the loss of the last chance for compre-

    hensive arctic wilderness in North America.  (Thus, the report

    mentions in passing that an earlier government analysis recommended

    wilderness designation for this area, but does not explain why the

    area is a significant wilderness resource.)  Similarly, there is a

    major difference between some disturbance to a 180,000 head caribou

    							13

            herd and the disturbance to and predicted decline  in the last major                  discuss such habitat reductions, for caribou and other species, in

            migratory caribou herd in the United States which  is substantially                   its evaluation of fish and wildlife resources. If suchanalysis

            undisturbed by major human development. Con  gress and the public                     underlies the report, it is neither mentioned nor explained for

            have the right to understand what is truly at stake before deciding                   purposes of public critique. A "black box' evaluation does not

            whether to go along with Interior's proposal to lease this area.                      serve the public comment goals of NEPA.

            It must be acknowledged that this choice reduces to value judgments                        c. Section 1002(c) requires an evaluation of the effects of

            -- but these judgments cannot be made without a full understanding                    oil and gas development in the coastal.plain on the culture and
            of the stakes In the debate.  This is the fundamental purpose of,                     lifestyle of affected native villages.' It must be recognized that.

            NEPA.                                                                                 even if fish and wildlife mitigation were completely successful,

                 2. ANILCA                                                                        the type of intensive industrial development that will accompany

                 The 1002 report violates both section 1002 and section 810 of                    oil andgas leasing in   this area will result in major, irreversible

            ANILCA as a result of fundamental omissions in the analysis:,                         changes in the culture and lifestyle of  the region. Yet Interior
                 a. Section 1602(c) and (h) both require an analysis of the                       evaluates this issue solely in terms of  subsistence yields of fish
        4&  impacts of oil and gas development. Yet the report expressly                          and game. This approach Is not only unduly narrow -- it reflects.O-
            ignores the impacts of gas development due to the unexplained                         callous indifference to the integrity of the local Native culture.
            choice of time frame. Thus, the report on its face fails to comply                         d. Section 1002(h) requires Interior to identify additional

            with the statute.                                                                     legal authority necessary to protect the area's resources. This

                 b. Section 1002(c) requires an evaluation of the carrying                        section of the 1002(h) report is entirely absent. One Interprets-

            capacity of fish and wildlife habitats in the coastal plain, but                      tion is that Interior believes that the existing regulatory regime

            the 1002 report contains little or no analysis of this issue. For                     is completely adequate to protect the valuable natural resources of

            example, the report fails to explain or to analyze the effect of                      the area. But given the conclusions'elsewhere in the report that

            forcing a fixed caribou population into a smaller calving and                         long-term losses to fish and wildlife populations  and other re-

            post-calving habitat. Notably, MMS recognized:                                        sources will result from the proposed leasing, it  is difficult to

                      The need for caribou to migrate appears to be a behavior-                   understand why Interior would not seek more stringent authority and
                      al adaptation that prevents destruction of forage habi-
                      tat. If movements are greatly restricted, caribou are                       tools to protect these resources.
                      likely to overgraze their habitat, leading to perhaps a
                      drastic. long-term population decline.                                           e. Section 810(b) of ANILCA states clearly that where environ-

            Sale 97 DEIS, at 111-31. The 1002 report does not analyze or even                     mental impact statements are required pursuant to section 102(2)(c)

                                             14                                                                                    15

           of NEPA, as Interior admits here, the notice and hearing required                         with the purposes of the refuge to allow an activity that will

           by section 810of ANILCA are required to be incorporated into the                          result in adverse effects to 20-40% of the Porcupine Caribou Herd

           NEPA process. Interior admits openly, at p. 129, that leasing                             (36,000-72,000 caribou), 25-50% of the muskoxen population, 5-10%

           could result in a significant restriction of subsistence uses under                       of the Banks Island Snow Geese population (30,000-50,000 geese) and

           section 810 of ANILCA. but expressly refused to incorporate the                           half or more of the wolverine population? The only way to arrive

           section 810 analysis into the NEPA process. This omission denied                          at the conclusion in the proposed Secretarial recommendation is to@

           residents of affected villages, including not only Kaktovik but                           consider the oil and gas values Of the refuge to be paramount to

           Venetei. Old Crow, Fort Yukon, Arctic Village, and Nuiqsuit, the                          the fish and wildlife purposes for which the refuge was created.

           opportunity to understand and to   comment on the proposed signifl-                       This approach is illegal under existing law.

           cant restrictions on their subsistence uses. Interior's decision                               4. Other Environmental Laws

           conflicts not only with the plain language of ANILCA, b   ut with                              The draft 1002 report falls to consider a wide range of

           prevai ling Ninth Circuit case law created in the context of OCS                          environmental protection laws that could be violated by oil and gas

           lease sales in Alaska.                                                                    leasing In the Arctic National Wildlife Refuge. In particular,

                3. Fish and Wildlife Compatibility Test                                              there is no consideration whatsoever of compliance with federal and
                The most fundamental legal basis for the.management of activi-                       state airquality. water quality, solid waste, and hazardous waste
           ties in fish and wildlife refuges is the "compatibility" test set                         laws and regulations. This major flaw in.the report was noted in
           forth in the National Wildlife Refuge Administration Act, and re-                         the Alaska Department of Environmental Conservation's (DECIS) com-

           peated and applied in section 304 of ANILCA. The Secretary may not                        ments on the 1002 report, at 1-3. Consideration of these laws and

           permit uses in the Arctic National Wildlife Refuge that are not.                          regulations would require major revisions to the draft report.

           "compatible with the purposes of the refuge," as set forth in sec-                             Individual environmental pollution issues will be addressed in

           tion 303(2) of ANILCA. Incredibly, in evaluating whether oil and                          greater detail In the second part of these comments. The funda-

           gas leasing should be permitted in the coastal plain of the ANWR,                         mental assumption used in ignoring these environmental issues,

           Interior did hot even evaluate, on the   basis of its own assessment                      however, appears to be Interior's assumption, as part of its envi-

           of probable impacts, whether the compatibility test would be met.                         ronmental assessment, of full compliance with all relevant laws and
                It is difficult to believe, in fact, in light of some of the                         regulations (p. 98). However, despite the oil industry's unsub-
           predicted impacts in the 1002 report, that this test would be met                         stantiated claim to a perfect environmental compliance record at
           under even the loosest standards. For example, is it compatible                           Prudhoe Bay, assuming 100% compliance with applicable laws and

                                             16                                                                                        17

    regulations for purposes of weighing environmental impacts is com-

    pletely inappropiate.

    	For example, a printout of state enforcement actions in

    progress identifies 24 open items, including Notices of Violation,

    compliance orders, and criminal and civil actions.  Violations have

    ranged from air quality to water quality, sold and hazardous

    waste.  For example, ARCO signed a Consent Decree in 1986 for viola-

    tions of a carbon monoxide air emissions.  According to DEC, dis-

    charges from 20 out of 21 drilling muds reserve pits violate appli-

    cable effluent standards, with violations involving toxic metals

    such as arsenic, manganese, chromium, lead, and copper, as well as

    aromatic hydrocarbons.  A single brine spill at one location de-

    stroyed 5 acres of tundra vegetation, and there has been at least

    one major hazardous waste incident.  In 1983, North Slope Salvage

    spilled thousands of gallons of chemicals generated by North Slope

    oil companies as a result of the improper storage of over 10,000

    drums of waste material.  The owners were convicted of criminal

    charges.  In light of this compliance history,  Interior's failure

    to consider the likelihood of compliance with environmental laws

    and regulations is ocmpletely unwarranted.

    	Finally, both Interior and the oil companies treat the "inevitable

    minor oil spills" as if they wer not violations of environmental

    laws, so long as prompt cleanup action is undertaken.  This is

    simply not the case.   Moreover, there is a widespread tendency to

    understate the magnitude of this problem.  According to DEC, there

    were 521 oil spills on the North Slope in 1985 alone, with a total

    of more than 82,000 gallons spilled.  According to these figures,

    							18

    the mean volume of oil spilled per incident is approximatley 150

    gallons, a conservative estimate given that individual spills over

    the life of the Prudhoe Bay complex have exceeded 200,000 gallons.

    Interior states that there have been mor than 23,000 separate oil

    spills since 1973.  Multiplying this figure by the conservative

    average of 150 gallons per spill, more than 3.5 million gallons of

    oil have been spilled at Prudhoe Bay since 1973.  It is difficult

    to understand how Interior can refer to this major environmental

    compliance problem as "inevitable small oil spills."

    	B.  Other Major Flaws in interior's Analysis

    	In addition to the report's failure to meet the requirements

    of a large number of applicable laws and regulations, the report

    suffers from additional major flaws in its analytical approach.

    The report suffers from an exceedingly narrow perspective, par-

    ticularly in its evaluation of national need and national security

    issues.  It is immediately apparent from reading the report that

    the authors, at least of the Executive Summary and Chapters III,

    VII and VIII, worked backwards from a forgone conclusion that re-

    flects the general bias of the current Administration to a ration-

    alization of the recommended action.  This is reflected in a large

    number of specific biases within the body of the report.  These

    biases are reflected in overstatements of the oil and gas and econo-

    mic potential of the coastal plain, and in tremendous understate-

    ments of the value of the coastal plain to the nation as a wildlife

    and wilderness resource.

    	Second the slanted approach in the report is reflected in

    the relationship between the recommendations and the report itself.

    							19

          In fact, the conclusions simply do not match the teport, as if fit(,                      evaluation of the no action dnd wildernest, options in the report.

          author of Chapter VIII did not even read many of the specific con-                             In fact. the $33/bb] price estimate lacks credibility given

          clusions in the rest of the analysis.                                                     current and predicted market cond  itionB.  Most Oil economists have
                   1. Major Biases                                                                  drastically reduced their Ipredicted oil price estimates given re-

               It was noted earlier that Interior understates tremendously                          cent dramatic declines in world oil prices.     Economist Arlon Tus-
          the losses to the nation of allowing oil and gas "leasing in the                          sing commented that Interiorts $33/bb] estimate is twice what is

          coastal plain of the Arctic National Wildlife Refuge. These argu-                         currently expected through the turn of the century.     Instead, Tus-

          ments will not be repeated here.    Interior matches this bias with                       sing predicts that oil prices will more likely center around the'

          its optimistic and unbalanced evaluation of the economic value of                         wid-teens for the foreseeable future, and rise at most to the
          the region.                                                                               mid-201s. Seattle Times, Januaryll, 1981, at B4. The current

               For example, Interior's oil and gas estimates chronically                            Alaska Department of Revenue forecast is that oil priceB will not

          overstate the potential of the region by burying the relationship                         rise above $20/bbl into the late 1990's.     Notably, oll production

          between the 19% marginal probability of any economically recover-                         In the Arctic National Wildlife Refuge Is not even economically

          able oil and gas in the ANWR and the probability curve of potpntial                       feasible at a price of $15/bbl. other economic assumptions used by

          recoverable resources if there is recoverable oil.     It is particu-                     Interior. such as a 10.0% real discount rate, are similarly noncon-

          larly misleading of Interior not to include this fact in the Execu-                       servative, and should be tempered by a sensitivity analysis.

          tive Summary of the Report, particularly when busy members of Con-                             Interior's geologic predictions also appear to be unduly opti-

          gress (and interested members of the public) are not likely to sift                       mistic. in order to make a stronger case for allowing full leasing

          through the entire report.                                                                of the coastal plain. For example, interior admits that the proba-
               Even the 19% figure is questionable. however, in light of the                        bility of large oil finds in the coastal plain would be reduced

          economic assumptions used by Interior in determining the minimum                          drastically if there were no Elleamerian rocks below the region,
          economic field size (MEFS), and in calculating the economic bene-                         but there Is no clear evidence on this point (p.54). The report

          fits of production. Most dist   ,urbing is interior's use of a "most                      also admits that the complex, folded structure below much of the
          likely" oil price of $33 per barrel (1984 $). and their accompany-                        coastal plain Is far different from the geology in the Prudhoe Bay
          Ing failure to employ a sensitivity analysis reflecting it wore                           region. which increases the risk factor (p.70). These uncertain-
          likely average figure as well as a low-price scenario.     In fact,                       tit's do nor allf1par to havp affected Interior's full leasing
          the failure to include a low-price scenario entirely prejudices      any                  Y ecommencla t I on.

                                          20                                                                                        21

                 A comparison between the federal and state geologic 1.)rvdic-                    oil anti gas.  Most incredibly, the.list of major oil fields on.page

            tions is also illuminating.  State geologists, using the same daV;i                   162 (and elsewhere) omits the 20 BBO West Sak field west of Prudhoe

            available to USGS as well as additional data from state ]ands, were                   Bay.  This field is more certain than the ANWR, is proximate to

            far less optimistic than their federal counterparts. While thp low                    existing pipelines and support facilities, and would serve the same

            probability (5%) state estimates approached the federal estimates                     goal of replacing oil for transport through TAPS.    While it was
            (26.52 BBO versus 29.4 BBO), the state estimates drop off sharply                     initially thought that extraction from the West Sak Bands Yas not

            through the rest of the probability curve:                                            feasible.-ARCO recently completed a test well demonstrating that

                           STATE               FEDERAL                                            extraction from this field ]a technically feasible. but not econom-

            MEAN           7.22 BBO            13.8 BBO                                           ical given current oil prices. The same economic factors. however.

             50            3.77 BBO            11.9 BBO                                           would prevent.development in the ANWR, if oil is dicovered in the

            .95            0.08 BBO             4.8 BBO                                           coastal plain. Moreover, since development in ANWR cannot. be ex-

            These differences do not appear to affect the low probability of an                   pected for a minimum of 10-15 years, ARCO has at least that amount

            extremely large find In the coastal plain. but render extremely low                   of time to improve extraction technology   in the West Sak area.

            the chance of finding some oil in economically recoverable quanti-                    Development of West Sak. which Is in a currently developed area

            ties.  Interior was in possession of the state estimates well be-                     rather than the MOBt sensitive portion of one of the nation's most

            fore the 1002 report was drafted, but completely ignored the                          valuable wildlife refuges. is a clear alternative to ANWR develop-

            state's predictions.  This burying of significant information evi-.                   ment. but Is not even mentioned in passing in the draft 1002

            dences the Department's lack of objectivity. Congress and the                         report.

            public are entitled to a full understanding of the uncertainty                             2. Variance Between Report and Recommendations

            inherent in the oil and gas estimates for the coastal plain.                                Perhaps the most insidious flaw in the draft 1002 report is

                 Finally, Chapter VII of the report consists of unabashed scare                   the gross variance between information in the body of the report

            tactics designed to frighten the American public into thinking that                   and the proposed Secretarial Recommendations. We believe that a
            all possible sources of petroleum resources. wherever located, must                   proper rewrite of the draft report would clearly support a wilder-

            be explored and developed. As noted above, Interior ignores com-                      ness recOmmendation for the coastal plain. However, even as writ-

            pletely all other strategies for meeting the nation's energy needs,                   ten, the existing body of the report supports. at most, a recom-

            including other supply side options and all demdnd side options.                      mendation for an extremely limited, winter-only exploration program

                 However, the report even ignores other potential sources of                      to determine the nature of rocks beneath the coastal plain.     Only

                                          22                                                                                     23

          by ignoring much of the Information in the report itself can a full                       effort to obtain a less extrome result.     This dpproach is inapprop-

          leasing proposal be rationally justified.    The following compdrison                     Hate for a government agency that was directed by Congress to

          of a few selected statements in the body of the report with J)aral-                       prepare a thorough and objective report so that Congress could

          lel statements in the recontmendat ions evidences the misleading                          reach Its own conclusions from a fully informed basis.      This tactic

          proposed conclusion:                                                                      also denegrates the hard work and sound analysis obviously per-

                     CONCLUSIONS                    REPORT                                          formed by staff level personnel in the Interior Department, as

                                                                                                    evidenced by portions of the report and by the Baseline studies
          The Central Arctic caribou           Analogies comparing the
          has increased substantially          effects of current Oil devel-                        prepared pursuant. to section 1002(c) of ANILCA.
          during the period that devel-        opment on the CAR and effects   of
          opment has occurred within           potential 1002 area development                      III. Specific Comments on Environmental Impact Analysis.
          the heart of its range.              on the PCH must be drawn with
                                               caution.                                                  In addition to the major analytical flaws identified     above, we

          overall  ... most adverse            Long-term losses of fish and                         have a number of comments on specific Issues addressed, and in some
          environmental effects would          wildlife resources, subsistence
          be minimized or eliminated           uses, and wilderness values                          cases omitted entirely, in the environmental impacts section of the
          through   itlgatln.                  would be the Inevilible conse-
                                               quence of ... development ....                       1002 report. Given the large number of problems, only major issues

          ... the coastal plain has            Though the structures appear                         are raised.   These comments are organized topically     rather than
          been predicted to contain            highly favorable. there is no
          as much as 29 billion                assurance that they do in fact                       chronologically.
          barrels of oil  ....                 contain oil and gas.
                                                                                                    Caribou
               other key conclusions in the body of the report are completely
                                                                                                         The draft 1002 report admits substantial possible impacts to
          ignored in the draft recommendations section.     For example, the
                                                                                                    both the PCH and the CAII if oil and gas leasing is allowed in the
          report states:
                                                                                                    coastal plain. Given these predictions alone. it is im[possible to
                     Traditional subsistence life styles would be irreversibly
                     and irretrievably lost or altered with the introduction                        justify'the proposed full leasing recommendation.      In fact, the
                     of widespread industrial activity and greater opportuni-
                     ties for a cash-based economy.                                                 full leasing proposal contradicts the recommendations of virtually

          Apparently, the author of the recommendation section felt that the                        all of the caribou biologists at the caribou workshop sponsored by

          tremendous impact of oil and gas leasing on the local population                          USFWS in 1985 for the express purpose of reviewing this issue.        The

          was not even significant enough to address In the recommendation                          result Is also criticized by biologists in the Alaska Department of

          section.                                                                                  Fish and Game, in their comments on the 1002 report.

               The generally biased approach evidenced in the report appears                              Historically, major industrial development has been found to

          to be a political maneuver to begin with an extreme position in an                        be incompatible with. and highly disruptive of, caribou popula-

                                              24                                                                                       25

            tions, particularly during calving and post-calving.       See Shideler,                      Management Guide (A11MG), Arct ic Vol    11, at 51 ot sr-q.   Since the.
            ImpactsI of Human Developments and Land Use on Caribou. Vol. II, at                           roasons, for this variation are not well understood, it Is       insuffi-
            27-34 (case histories from Norway and the U.S.S.R.)       In art evalua-                      Ciel'It to protect only the core areas.
            tion of potential oil and gas leasing in the Teshekpuk lake Special                                Nor does Interior evaluate the potential effects of restrict-
            Area, the Bureau of Land Management (which has less of a clear                                Ing caribou to the same calving and post-calving area year after
            mandate to protect fish and wildlife populations than USFWS)                                  year as the result of permanent Industrial development.. For exam-
            stated:                                                                                       'ple. driving the PCH further south for calving each year will ex-

                       Based on the available literature ... pregnant cows and                            pose calves to higher predation. since predators are wore,common in
                       cows with calves would not be compatible with a major oil
                       and gas development complex.                                                       the southern calving-areas, and since predators will."learn" calv-
            Teshekpuk  Lake Special Analysis, Biological Evaluation. at 66.        In                     ing locations with greater certainty.      Since predation is a major
            short, the report's conclusions cannot be justified in light of the                           factor in calf survival, this could have a major effect on the
            vast wpi@jht of scientific opinion on this issue.                                             herd. AHMG. Vol. I at 123, Vol. 11 at 69-70; 1002 Report at 28.
                 Even the analysis in the report, however, is.incomplete and                                   A second possible effect of restricting calving areas is

                                                                           tection of                     overgrazing if calving and post-calving     -------- 4
            understated.   For example, the 1002 report focuses on pro                                                                             g aggregations   are 1.0rced
            the "core" and "concentrated" calving grounds of the PCH. Core                                into the same area each year. Sale 97 DEIS at 111-31. Shideler
            calving grounds are defined by reference to a density of 50 animals                           noted the importance of nutrition to reproductive success and calf
            per square milel concentrated calving grounds are areas where core                            survival, but these effects are Ignored In the 1002 ret-ort (or at
            calving has occurred in 5 of the last 14 years. Nowhere. however.                             least go unstated).    In fact, nowhere does Interior address the
            is the derivation of these magic numbers explained. While the                                 issue of maximum calving densities for caribou.       Is there a maximum
            numbers obviously have value for comparative purposes, there is no                            calving density, and If so. what is the carrying capacity of the
            explanation of why they are an appropriate basis for deciding which                           remaining undisturbed calving areas given predicted habitat losses
            areas should be protected or not protected, particularly given the                            in the 1002 areal?
            historical variation In the use of calving areas by the PCH.        In                             Finally, Interior fails to explain why insect relief areas are
            some years, for example. the PCH has used none of the "core" or                               not considered Category I habitat. deserving of full protection.
            "Concentrated" calving grounds.     See ADFG. Alaska Habitat                                  The report admits that "access to insect-relief habitat and forage

                                                                                                          resources ... may be critAcal to herd production."       P. 28; See also

                                                                                                          p. 109; Shideler, at 23-24; Ar)FC, comments at 7-8.     For this reason,

                                             26                                                                                            27

    ADFG recommended a 3-mile development-free corridor along the

    coast.  Since "insect harassment can have a pronounced negative

    effect on caribou survival," these critical insect relief areas are

    worthy of protection.

    Birds

    	The report recognized some major ptoential impacts on the

    major bird populations of the coastal plain, but understates or

    ignores other possible impacts.  For example, there is no discus-

    sion of the use of the Camden Bay area (where a port facility and

    state leasing are proposed) by threatened brant populations.  Sale

    50 Findings, at 19.  Given the sensitivity of brant to disturbance,

    and the danger of further declines in brant populations.  Teshekpuk

    Evaluation, at 17-23, this issue should be addressed in greater

    detail.

    	Similarly, the report understates possible impacts to threat-

    ened peregrine falcons, because Interior states that there is no

    nesting in the 1002 area.  But the state reports that peregrines

    nest immediately adjacent to the 1002 area along the Canning River,

    and hunt in a 5-15 mile radius.  Therefore, acitivity in the 1002

    area, including the construction and use of the area west of the

    Canning for road and pipeline construction and use could adversely

    affect these populations.

    	Tundra swans are alos extremely sensitive to disturbance,

    Teshekpuk Evaluation at 44.  Camden Bay is a high density nesting

    area for tundra swans; in fact, graphic 3 in the Sale 97 DEIS iden-

    tifies the ANWR coastal plain as the only major tundra swan concen-

    tration area on the North Slope.  But the 1002 reprot does not

    								28

    identify this conflict as a major issue.

    	Finally, the report does not fully analyze the possible ef-

    fects of two major types of disturbance on ANWR bird populations.

    First, aircraft flight restrictions are one of the major mitigation

    methods to protect bird species (as well as other wildlife).  How-

    ever, the report alson notes that fog restricts visibility 27% of

    the time from May to September, with a maximum of 31.5% in August.

    This is precisely when major bird activity occurs in the area.

    Human safety will always take precedent over environmental protec-

    tion (as it should if leasing is allowed).  Therefore, Interior

    must presume that flight restrictions will be avoided much of the

    time in weighing unavoidable impacts to bird populations.

    	Second, the report fails completely to conduct a risk assess-

    ment for the potentially most devastating impact to ANWR bird popu-

    lations - - the risk of a major oil or fuel spill in the coastal

    lagoons, either from supply vessels or from related oil extraction

    in state lease areas.  Since eve a single exploratory well re-

    quires 500,000 to 800,000 gallons of fuel (refined fuel is more

    toxic to both plant and animal life than crude oil), the risk of a

    major spill should be considered even for exploratory activity.

    According to the Sale 97 DEIS, at IV-B-27-34, a major oil spill

    could kill thousands or tens of thousands of bird in a coastal

    lagoon.  Rather than performing a risk analysis, an MMS typically

    does, Interior simply specualtes that the risk of a major spill is

    minor.  However, this approach is unwarranted in light of risk

    figures produced by MMS.  For example, without even considering oil

    development in state coastal lagoons and in the ANWR, MMS predicted

    						29

    a most likely cumulative probability of 24 spills greater than 1000

    barrels in the Beaufort Sea (i.e. not unlikely events).  Sale 97

    DEIS, at III-A-5.  This is not a low probability event.  Moreover,

    the greastest risk of land contact is form nearshore activity that

    would be precipitated by ANWR leasing, and the effects of land

    contact could be devastaging:  a 10,000 barrel spill could contami-

    nate 30 km of shoreline, and a 100,000 barrel spill could contami-

    nate 90 km of shoreline.  Id. at III-A-10.  Particulary in light

    of the relationship between state and federal leasing in the ANWR

    region, Interior should have engaged in a serious oil spill and

    fuel spill risk evaluation, to give a true picture of the potential

    environmental risk of leasing in the Arctic National Wildlife Ref-

    uge.  Obviously, this risk extends to other species as well as

    birds, particularly marine mammals and fish.

    Fish

    	1.  Interior minimizes or does not consider effects to species

    that are not used for sport or commercial fishery.  (p. 125)  but

    the Refuge is not a fish hatchery; it is supposed to be managed for

    its natural diversity.  Impacts to all fish species should be

    considered.

    	2.  As noted above, other agencies have documented major water

    quality and fish passage problems from port and causeway develop-

    ments.  Interior virtually ignores these impacts, and fials to

    weigh the cumulative impacts of coastal development.

    	3.  Spring-fed and other fish overwintering areas appear to be

    critical to the survival of many freshwater species.  ADFG com-

    ments; 1002 report, at 37.  Given the shortage of water in the

    					30

    area, and the tremendous need for water for oil and gas production,

    this poses a major, unresolved resource conflict.  Based on this

    conflict, ADFG recommends that overwintering areas be treated as a

    Category 1 habitat, worthy of complete protection.  Yet Interior

    goes so far as to suggest the withdrawal of water from Saddlerochit

    Spring to meet water needs for oil and gas production (p.104).

    	4.  The identification of fish only in certain watershed areas

    is highly misleading.  According to the AHMG, Arctic Map 11, the

    watersheds not identified as having fish are in fact unsurveyed.

    In fact, the map states expressly that "the category 'not present

    in watershed areas' is not included because available data do not

    document such areas."

    Polar Bears

    	1.  Interior's complete failure to evaluate the cumulative

    impacts of disturbance to denning sites was addressed extensively

    above.  It is clear, however, that human industrial activity poses

    a serious threat to polar bear denning.  Sale 97 DEIS, at IV-B-38.

    In fact, one incident of apparent den abandonment resulted from

    winter exploratory activities on the coastal plain, and is docu-

    mented in FWS records.

    	2.  Polar bear habitat is protected by the Marine Mammal Pro-

    tection Act and by International Agreement.  The 1002 report does

    not explain how the unavoidable disturbance of denning sites (both

    onshore and offshore) that will result from ANWR leasing is consis-

    tent with these legal protections.

    Bowheads whales

    	As noted above, Interior performed no oil spill risk analysis

    							31

    or other extensive evaluation of environmental disturbances to

    nearshore and coastal areas as a result of leasing in the coastal

    plain.  As a result, there is virtually no evaluation of potential

    impacts to endangered bowhead whales.  However, the possible ad-

    verse effects of human activity on bowheads is well-documented.

    AHMG, Vol. I, at 38-46.  Moreover, the Demarcation Bay regione ast

    of Barter Island, where Interior proposes a por tand loading facil-

    ity and where the state proposes a lease sale that is not likely to

    be economically feasible without ANWR devlopment, is one of the

    two most vulnerable areas for the Beaufort Sea bowhead migration,

    as it is a critical fall feeding area.  AHMG, Vol. II, at 12, 15

    and Map 9; Sale 97 DEIS, at I-10, II-27, IV-B-47.  Interior's fail-

    ure to evaluate possible effects to this endangered population is a

    critical falw in the report.

    Terrestrial predators

    	While Interior predicts the imapcts of oil leasing on caribou

    populations, little attempt is made to discuss the resulting effect

    on predator-prey cycles in the coastal plain.  In particular, reduc-

    tions in caribou populations could have ripple effects on popula-

    tions of brown bear, wolves, and golden eagles.  See AHMG, Vol. II,

    at 41 and Map 17.  Interior's statements regarding the effects on

    wolves are particularly disturbing.  The report indicates that only

    5-10 wolves per year use the coastal plain (p. 31) but proceeds to

    predict only a "moderate decline" in the wolf population (p. 115).

    What is a "moderate decline" with respect to such a marginal popula-

    tion?  This issue must be viewed in light of the fact that oil

    development near Prudhoe Bay has virtually eliminated the regional

    						32

    wolf population.  A similar result in the 1002 area cannot be con-

    sidered unlikely.

    Muskoxen

    	The Arctic National Wildlife Refuge contains the second lar-

    gest muskox population in Alaska, with one third of the state's

    total population.  In addition, the high growth rate of this

    reintroduced population evidences excellent muskox habitat.  In

    light of the obvious importance of the 1002 area for the survival

    of this population.  Interior's acceptance of major (20-50%) effects

    to muskox is inexplicable.  In particular, oil development is pro-

    posed in the middle of two critical habitat areas - - traditional

    calving areas and important wintering areas.  There appears to be

    no reason why muskox calving areas should be trated as any less

    important than caribou calving areas.  In fact, since Alaska has

    far fewer healthy muskox herds and vastly lower total numbers of

    muskox than caribou, it could be argued that it is even more import-

    ant to protect muskox habitats, or in the language of the mitiga-

    tion policy, that muskox calving habitat is even more "unique and

    irreplaceable on a national basis or in the ecoregion."  Yet Inter-

    ior classifies caribou calving areas, but not muskox calving areas,

    as category I habitat.  This result is anomalous and inappropriate.

    Subsistence

    	1.  As noted above, Interior treats the subsistence issue as

    one of pure harvest and harvest opportunity.  This demonstrates a

    fundamental misunderstanding of the importance of subsistence to

    the way of life of the residents of area villages.  Both under NEPA

    and sections 810 and 1002 of ANILCA, the report should include a

    						33

    far more comprehensive evaluation of the impacts or development on

    Native culture and life style.  Unfortunately, the unavoidable

    result of major oil and gas leasing in this area, unlike similar

    leasing at Prudhoe Bay, which is further from any village, will be

    a drastic change in the life style of the people of the village of

    Katovik.  Similar impacts will occure in other villages that rely

    heavily on the PCH not only for food, but for cultural sustenance,

    if major changes in the size and distribution of the PCH and CAH

    result.

    	2.  Interior's major focus on subsistence impacts only in

    Kaktovik is entirely inappropriate in light of the heavier reliance

    on the PCH by other villages, including Arctic Village, Old Crow,

    Venetie, and Fort yukon (p.29).  Interior has exhibited an extreme-

    ly callous indifference to the welfare of the people of these

    villages.

    Water and gravel resources

    	Interior properly identifies the fact that oil and gas develop-

    ment in the coastal plain will require major amounds of water and

    gravel resources, and properly identifies this as a major resource

    conflict.  However, the report falls far short of evaluating and

    resolving these major conflicts.  For example, if the "innovative"

    methods of water use identified on page 76 are unsuccessful, it is

    likely that far more gravel roads will be constructed than are

    currently predicted.  Alternatively, once a major commitment to oil

    and gas extraction from ANWR is made, it is unlikely that the

    oil industry will be prevented from using available fresh water and

    gravel sources, despite adverse effects on fish and other popula-

    							34

    tions.  Therefore, the sources of water and gravel necessary to

    support oil development in the area should be fully identified

    before a decision to allow leasing is made.  If environmentally

    acceptable sources of these materials are not present, this fact

    should be clearly state in the report rather than engaging in an

    exercise in wishful thingking.

    Environmental pollution

    	As noted above, Interior's evaluation of a wide range of envi-

    ronmental pollution effects from oil leasing in the Arctic National

    Wildlife Refuge is woefully inadequate.  Major potential problems

    are identified below:

    	1.  Air pollution.  There is no evaluation whatsoever of air

    quality impacts from oil development in the ANWR, despite evidence

    of major potential problems at Prudhoe Bay, the possibility of more

    severe problems in the 1002 area in light of the closer proximity

    of mountainous terrain and requent inversions, and the cumulative

    air quality effects of additional development on the North Slope.

    DEC and EPA currently have a very poor understanding of the effects

    of a air pollution from Prudhoe Bay facilities, but there are a num-

    ber of reasons for concern.  Permiteed NOx emissions at Prudhoe are

    80,000 to 100,000 tons per year, and ambient monitoring to deter-

    mine whether these massive emission rates result in ambient air

    quality violations has just begun.  Moreover, it is suspected that

    EPA's NOx model has underpredicted ambient NOx concentrations, and

    no snow pH measurements have been taken to determine whether acid

    precipitation is a problem.   But in comments submitted on the

    state's proposed Camden Bay sale, DEC commented that "air quality

    							35

             in the proposed sale area will be a significant conceti, if t-w                                 a landfill will have to be sited in the refuge.

             production facilities are developed."      Ariother major air quality                                6.   Drilling muds.    Interior's treatment of this mojor waste

             problem, particularly in a National Wildlife Refuge with proximate                              disposal problem is insufficient.      Notably, DEC refers to tile 1002

             wilderness areas, is startup and "emergency" gas flatin(j, or block                             report's treatment of the drilling muds issue as "grossly inade-

             smoke incidents.    Recent startup flaring oil tile North Slope con-                            quate and misleading."     Each of the 500-600 wells at Prudhoe Bay

             tinued for an entire month, with black smoke visible for up to 50                               generate approximately 840,000 gallons of wastes per year.          In 1984

             miles front tile site.                                                                          alone, 58 million gallons were discharged to tundra wetlands, but

                  3.   oil spills.   The massive cumulative problem of chronic oil                           as ii(ited above. there have been pervasive violations of applicable

             spills was identified above.     In addition to direct. spills to tun-                          discharge standards.     Rather than addressing the major water qua)-

             dra, DEC indicates that chronic leaking of oil through gravel pads                              it-y problems that could result in the ANWR, Interior suggests that

             is adding to the overall amount of oil reaching the environment.                                the only permanent effects of drilling muds disposal practices will

             The 1002 report identifies the problem, but makes no attempt to                                 be tile creation of "rectangular-appearing ponds" after operations

             evaluate the long-range and comprehensive effects of oil pollution                              cease.   Wldle mentioning pervasive leakage problents Jn passing,

             on the refuge.                                                                                  Interior does not analyze the potential long-range effects on the

                  4.   Hazardous waste.    As noted above, at least one major hazar-                         water supply and other resources In the refuge.        Finally.. no wen-

             dous waste spill has occurred in the Prudhoe Bay area.         in addi-                         tion Is made of the fact that EPA is in the process of reevaluating
             tion, both the state and the oil companies are currently grappling                              the regulation of all oil industry wastes, pursuant to a consent

             with the major problem of how to handle hazardous wastes front North                            decree In Alaska Center for the Environment v. Thomas. The initial

             Slope operations.    Currently, oily wastes are taken to the North                              results of this study indicate that existing industry waste dispo-

             Slope Borough's Oxbow landfill, but there Is no approved facility                               Sol practices, on the North Slope and elsewhere, may be inadequate

             for hazardous wastes under RCRA.      The 1002 report does not address.                         to protect human health and the environment.

             how either oily wastes or other hazardous wastes generated from

             development in the ANWR will be handled or transported.                                         IV. CoTiclusion

                  S.   Solid waste.    Similarly, the 1002 report does not address                                Based on the above deficiencies, the draft 1002 report does

             where even nonhazardous   solid wastes. which are generated in tremen-                          nut serve its intended purpose, arid violates a number of applicable

             dous quantities by North Slope operations. will be handled.          Either                     laws ond regulations.     Congress souyht an independent, objective

             these wastes must be transported out of the refuge for oj@posal, or                             analysis SO that it could have a well,    -informed basis for the debate

                                              36                                                                                                  37

            over the fate of the coastal plain of the Arctic National Wildlife

            Refuge. This basis simply has not been provided. The report

            should be rewritten, and submitted for another round of public

            comment before a final version is submitted to Congress, as re-

            quired by the NEPA regulations.

                 However, even on the basis of the adverse impacts predicted In

            the report, it is apparent that oil and gas development in the 1002

            area cannot be accomplished without major, long-term losses to

            internationally-significant fish and wildlife populations, the

            irretrievable loss of the nation's last arctic wilderness, and

            major damage to the culture and lifestyle of the Native villages in

            and around the refuge.

                 On the other hand, it is equally apparent that no effort what-

            soeverwas made to evaluate the true national need for the petro-

            leum resources that may exist in the region, I.e. whether equal

            amounts of energy could be generated or saved through other strate-
            gles. if such an analysis were undertaken seriously, it would be

            realized that the national security and energy independence goals

           .discussed in the report could be met without the tremendous losses

            that will accompany oil and gas leasing in the refuge. and at a

            lower economic cost,to the nation. We do not have to lose such

            precious resources in order to meet our energy goals.

                 No valid case has been made to allow oil development in this

            area. Rather, the coastal plain of the Arctic National Wildlife

            Refuge should receive the protection it deserves through placement

            in the National Wilderness Preservation System.

                                          38

                            Washington Native Plant Society
                      "Preserve and Enjoy Washington's Floral"                                                 6. The proposed action and other development
                                                                                                          alternatives presented would cause severe environmental
                                                       4611-2nd. Avenue N.E.                              degradation of one of North America's most important and
                                                       Seattle, WA                                        fragile wild ecosystems  and would make a 0ockery of the very
                                                                                                          concept of the National  Wildlife Refuge system. This is
                                                       20 January 1987                                    clearly not acceptable.
               U.S. Fish and Wildlife Service                                                                  The WNPS urges the  withdrawal of the proposed
               Division of Refuge Management Resources                                                    alternative in favor of  the only ecologically and
               2343 Main Interior Bldg.                                                                   biologically Justifible  course of action     the adoption of
               l8th. and C Sts. N.W.                                                                      Alternative E.
               Washington, D.C.  20240

               Greet ings,
                                                                                                                                Sincerely,
                    This letter is written on behalf of the Washington
               Native Plant Society's Board of Directors to comment on     the
               proposed alternatives for oil development on the Arctic
               National Wildlife Refuge fdraft 1002 Report). The WNPS      is an
               organization of over BOO professional and amateur botanists                                                      Mark Egg.Tr
               in Washington state who share an active interest in the                                                          President, WNPS
               preservation of our nation's native flora and fauna.

                    The WNPS would.like to offer its full support to
               Alternative E. We wholeheartedly endorse Wilderness Area                                   cc: Hon. Bennett Johnson
               designation for the entire Arctic NWR. We strongly oppose                                      Hon. Stve Cowper
               any form of gas and/or oil development in the Arctic NWR.                                      Hon. Dan Evans
                                                                                                              Hon. Brock Adams
                    We find the "Preferred Alternative" to be totally
               unacceptable for the following reasonst

                    1. You have not adequately evaluated or considered the
               probable impacts of the proposed action on native plant
               communities and on rare and sensitive plant species.

                    2. You have not demonstrated a convincing case for
               either the need for or the feasibility of the proposed
               extraction program.

                    3. You have not properly evaluated the cumulative
               effects of the proposed actions on the emtremely fragile
               natural ecosystems of the high arctic.    This is in cleat,
               violation of NEPA regulations.

                    4. You have not adequately assessed the impacts of the
               prooposed action on caribou herds or an the native peoples
               dependent on these herds.

                    5.  Proper environmental safeguards in respect to
               disposal of hazardous waste by-products from the proposed
               actions are not delineated.

                                                                                                         The Wilderness Society
                                                                                                         Page 2

                                                                                                         wildlife, wilderness, and recreational values" that the
                                          , rMV//,-
                                            .-01                                                         refuge was established to protect.
                   THE WILDERNESS SOCIETY                                                                     The following comments on the draft Resource Assessment
                                                                                                         and recommendation to Congress on the Arctic National

                                                                                                         Wildlife Refuge Coastal Plain are submitted on behalf of The
                                                 February 6, 1987
                                                                                                         Wilderness Society's 160,000 members nationwide.
                  U.S. Fish and Wildlife Service
                  Attn: Division of Refuge                                                               INTRODUCTION AND SUMMARY
                        Management
                  2343 Main interior Building                                                                 In these comments, The Wilderness Society concludes
                  18th and C Streets, N.W.
                  Washington, D.C. 20240                                                                 that the 1002 report fails to meet the requirements of
                       Comments on the Draft Resource Assessment for-the                                 either the Alaska National Interest Lands Conservation Act
                       Arctic National Wildlife Refuge Coastal Plain
                  Dear 'Sir:                                                                             (ANILCA) or the National Environmental Policy Act (NEPA).
                       For over 50 years, The Wilderness Society has been                                     Specifically, the report falls short in the following
                                                                                                         respects:
                  dedicated to the wise management of the.federal lands and
       01                                                                                                        Analysis of oil and economics. The DepartmAnt's
       CA         the preservation of wilderness. The Society's history in                               geologistsestimated that there was just a 19 percent chance
                  Alaska goes back to its very founding by Robert Marshall,   an                         of finding economically producible oil under the coastal
                  early explorer of the Brooks Range.
                                                                                                         plain. This key finding was buried in the report and was
                       The incomparable and indisputable wilderness and
                  wildlife values of the Arctic National wildlife Refuge, and                            not included in either the executive summary or the Press
                                                                                                         release. Moreover, In calculating the likely revenues from
                  specifically the coastal plain, have long made it a major
                                                                                                         oil development and the total value of development, the
                  focus of The Wilderness Society. The original wildlife
                                                                                                         report falls to multiply the dollar values arrived at by
                  range was established in 1960 largely as the result of the
                  tireless efforts of Olaus and Margaret Murie. The late                                 that 19 percent probability.
                  Olaus Murie, President of The .Wilderness Society for 17                                    Further inflating the projected economic gain were th  .e
                                                                                                         exceptionally optimistic assumptions about future oil
                  years, spent years conducting research in the refuge, and
                                                                                                         prices. The report assumes a 4.1 percent annual increase
                  Margaret Murie still guides the organization as a member of                            through the Year 2000. That is more than twice the most
                  the Governing Council. The Muries recognized the "unique                               optimistic estimate being used today by th  .e Department's

                      14111) FVE STRFET, N.W. WASIIINGI'ON. D.C 200115
                                        i20h 8,12-34(m)

                 The Wilderness Society                                                                  The Wilderness Society
                 Page 3                                                                                  Page 4

                 Mineral Management Service (MMS). The report's projected                                Fish and Wildlife Service finds them acceptable. The
                 Year 2000 price of $33 per barrel (real 1984 dollars) is 39
                                                                                                         Wilderness Society considers such losses unacceptable.
                 percent greater than the price would be using the highest of
                                                                                                              Nor does the report show much concern about potential
                 MMS's assumptions.                                                                      pollution.. It does not mention that since 1972 there have
                         Potential role of energy conservation. In 1985 the
                                                                                                         been 23,000 oil spills reported at Prudhoe Say. it does not
                 Department of Energy issued a National Energy Plan stating
                                                                                                         mention that at  Prudhoe Bay 20 of the 21 major reserve pits,
                 that energy conservation "has proven to be the most
                                                                                                         which store toxic chemicals and heavy metals, violate EPA
                 expeditious way to reduce the need for new or imported                                  discharge standards. It fails to address the impact of the
                 energy resources; and in fact it now contributes more to                                ser.ious air pollution caused by Prudhoe Bay operations on
                 balancing our national energy ledger than does any single                               the growing Arctic haze problem--or the contribution that
                 fuel source." Yet the Administration has vetoed a bill
                                                                                                         oil activity in the 1002 area would make to that problem.
                 setting efficiency standards for appliances,rolled back                                 These are important concerns that call for thorough
                 automobile fuel efficiency standards, pushed for higher                                 investigation.
                 speed limits, and cut the energy conservation budget. The                                       Appropriate mitigation measures. The report
                 1002 report falls to investigate alternative energy sources,
                                                                                                         acknowledges that there would be serious wildlife population
                 as.re'quired by the National Environmental Protection Act.                              declines and difficulty for those with a subsistence
                 The Administration should pursue such options before                                    lifestyle, and it concedes that 111t]he wilderness character
                 drilling in an area that, according to the 1002 report,
                                                                                                         of the 1002 area would be destroyed..." But the report
                 would account for only four percent of U.S. oil needs in the
                                                                                                         fails to spell out how these impacts would be mitigated.
                 Year 2005.                                                                                      Analysis of area's wilderness values. Section 1004
                          Proiected environmental consequences. The report                               of ANILCA required a thorough review of the coastal plain's
                 predicts population declines of up to So percent for                                    suitability for wilderness designation. Yet the report
                 muskoxen and 40 percent for the Porcupine caribou herd. It                              includes only half a page on the subject; half of that is a
                 acknowledges that wolves, polar bears, and snow geese, and                              quotation from the Wilderness Act. The report concludes
                 other wildlife populations would suffer, as well. These                                 that the area could meet the criteria in the Wilderness Act,
                 projected impacts are conservative. Assuming for the moment                             an indefensibly weak statement in view of the plain's
                 that they are reasonable, It is disturbing that the U.S.                                pristine condition, natural qualities and spectacular

                                                                                                         wilderness values.

                 The Wilderness Society                                                                     The Wilderness Society
                 Page 5                                                                                     Page 6

                         Secret land trade negotiations. The interior                                       Only upon delving deep into the body of the 1002 report does
                 Department has been conducting secret land exchange                                        the reader find that there is an 81 percent chance that no
                 negotiations with several Native corporations despite                                      economically recoverable oil at   all lies within the refuge.
                 requests from Members of Congress to desist. Negotiating      to                           The chances of discovery reported in'the Executive Summary
                 trade away the very area it was directed by statue to study                                and fact sheet are "conditional" estimates. The condition
                 for wilderness protection demonstrates the lack of                                         is that at least one economically recoverable field will be
                 objectivity that Is reflected throughout the report.                                       found. In other words, the much-touted probability that the
                      ** Consultation with Canada. Despite the clear mandate                                refuge holds from 0.6 to 9.2 billion barrels of recoverable
                 in ANILCA's Section 1005, the Interior Department failed to                                oil is valid If economically producible oil is discovered --
                 consult officially with the Canadian Government during                                     the chances of which-are only one in five.
                 preparation of the report. Since release of the report,                                         The Executive Summary declares the Arctic coastal Plain
                 both the Yukon Government and the Government of Canada have                                to be "the most outstanding oil and gas frontier remaining
                 stated clearly that they disa  .gree with its recommendations.                             in the U.S.." However, though a cursory glance at the report
                      ** Provision for public comment. Despite the                                          may appear to lend credence to this statement, careful
                 importance of this issue, its complexity, and the broad                                    scrutiny fails to substantiate it. This peculiarity results
                 interest in it, the Department provided for a relatively                                   from a combination of omission of crucial information,
                 brief cormnent period and hearings in too few locations.                                   @ncomplete analysis, and the inclusion of incomparable sets

                                                                                                            of numbers in single charts.
                 THE INADEQUACIES OF THE OIL AND GAS ASSESSMENT AND ANALYSIS                                     The report presents two probability distributions to
                 Many of the assertions made by the Interior Department in                                  answer the following questions: 11) what is the likelihood
                 the report's Executive Summary, the "draft" recommendation                                 that any hole drilled in the region will encounter economic
                 to Congress, and many of the conclusions drawn throughout                                  quantities of oil and gas, and (2) if economic quantities of
                 the document are not supported by the findings In the                                      oil and gas are found, how much is there likely to be7
                 report.                                                                                    These probability distributions are based on simulation
                      In stating the oilpotential, for example, the                                         modeling of data obtained from minimal outcrop
                 Executive Summary fails to report the marginal probability,                                investigations and reconnaissance seismic surveys.
                 or risk, associated with Arctic Coastal Plain development.                                      The Wilderness Society believes that the 1002 report

                  The Wilderness society
                  Page 7                                                                                        The Wilderness society
                                                                                                                Page 8

                  should instead ask these questions:     (a) what is the likeli-
                                                                                                                addition, many of the same non-quantifiable costs that would
                  hood that oil and gas will be developed If the area Is
                                                                                                                be realized in the connercial-production scenario would also
                  opened to7leasing, and (b) what will be the resulting costs
                                                                                                                occur, including the environmental damage caused by the
                  and benefits of this action to the federal          Mjt-& j        -
                                                                              govern
                                                                  IT!                                           building of haul roads, drilling pads, airstrips, port
                  ments, and the oil-prciducing corpoiations. The difference
                                                                                                                facilities, desalination plantis), in the midst of an
                  between questions (a) and M and the issues addressed in
                                                                                                                otherwise pristine area.
                  the report is that the DOI document does not go beyond the
                                                                                                                      Clearly the decision to open the wildlife refuge to
                  estimation of the quantities of oil and gas that may be in
                                                                                                                petroleum development must consider the quantities of oil
                  the refuge. The relevant question that needs to be answered
                                                                                                                and gas that are likely to be present, but the net economic
                  is: What are the financial benefits (both magnitude and                                       benefits of development must also be considered         The DOI
                  duration) that are likely to acc   .rue from opening the coastal                              analysis, however, skews this assessment towards development
                  plain of the Arctic Refuge to oil and gas development?                                        by ignoring the non-quantifiable costs of foregone wildlife
                       If petroleum is economically-producible In the 1002.                                     and wilderness values and grossly overstating the potential
       01         area, then lease bonus payments, corporate income taxes,
       OD                                                                                                       benefits of development.
                  severance taxes, windfall profits taxes, royalties, and
                                                                                                                      The estimation of the Net National Economic Benefits
                  perhaps other benefits would be obtained by the federal and
                                                                                                                (NNEB) presented in Chapter VII of the report Is deceivingly
                  state governments. These quantifiable benefits from                                           high. Unrealistic oil price assumptions are used in t        he
                  petroleum production must be compared with the largely                                        analysis and oil and gas volumes and dollar values are
                  non-quantifiable costs of.development of the wildlife                                         oftentimes presented as if there is a 100 percent
                  refuge. These costs include the disruption of.the caribou                                     probabi .lity of finding these commodities. In reality, the
                  calving grounds and other wildlife habitat losses.                                            probability of drilling a hole that taps an economically-
                       If the 1002 area Is opened to full-scale oil                                             viable oil pool is only 19 percent (pg. 68). Thus, any
                  exploration and development and commercially-exploitable                                      estimate of the likely oil revenues and associated benefits
                  quantities of oil and gas are not found, then the state and                                   that could be obtained from the 1002 area should be
                  federal governments would not receive corporate     .income                                   multiplied by this marginal probability factor I      n order to
                  taxes, severance taxes, or royalties, and the oil companies                                   present a true picture of the likely value of opening the
                  would not earn a profit on their exploration investment. In
                                                                                                                refuge to petroleum production. To do.otherwise Ignores the

                 The Wilderness Society                                                                    The Wilderness Society
                 Page 9                                                                                    Page 10

                 fact that 8 out of 10 wells drilled in the ar  ea will   yield                            from in analysis using critical assumptions about (1) the
                 no net benefits.                                                                          minimum field size that is likely to be economically
                      The Net National Economic Benefits   are defined  in the                             produced, and (2) future oil prices, among others.
                 report (pg.165) as "the expected net   value of oil                                       According to the most-likely DOI scenario, the,oil price in
                 production, or th e difference between revenues from sale of                              the year 2000 Is assumed to be $33 per barrel in real 1984
                 oil and the costs of exploration, development, production,                                dollars (pg.72) (or about $36.30 In 1987 dollars), In order
                 and transportation." The remaining dollars-go to the.state                                for this value to be reached in the year 2000, the oil price
                 and federal governments and the oil-producing corporation.                                would have to grow at an average rate of 4.1 percent per
                 State and fedeial benefits are obtained from the lease bonus                              year (starting from the current oil price of approximately
                 payments, royalties, severance taxes, and corporate income                                $18 per barrel). The most recent projections of the
                 and profits taxes. Any money left over from these costs is                                Minerals Management Service (MMS) of the DOI assume three
                 a profit to the oil companies.                                                            oil price growth scenarios: 0, 1, and 2 percent per year.
                       According the Doi analysis, the NNEB from full-scale                                The 4. 1 percent growth rate -- in real prices -- is more
                 development of the mean potential find of 3.2 billion                                    .,than twice the highest growth rate assumed by the mms.
                 barrels of oil (BBO)Js $14.6 billion (adjusted for                                        Using the optimistic assumption of an oil price of $40 per
                 the time value of money). The NNEB of limited leasing from                                barrel (about $44 in 1987 dollars), yields a yearly growth
                 a field size of 9.2 BBO (there is a 5% probability of this                                rate of approximately 4.9 percent. Since these values are
                 size or larger) is presented as $9.4 billion using                                        compounded annually, the effect of such a price assumption
                 optimistic economic assumptions. These values fail to                                     is magnified with each passing year. For example, using a
                 account for the high potential that no economic oil will be,                              growth rate of 1  percent per year, the price for a barrel of
                 discovered if  leasing is allowed. To get the true expected                               oil In the year 2000 would only be $18.62 (in 1984 dollars,
                 NNEB from these field sizes, the agency should have                                       $20.69 In 1987 dollars). Thus the value of $33 per barrel
                 explicitly factored this   risk into the analysis by                                      is 77% higher than the value of $18.62 that would be
                 multiplying the above values by tfie 19% marginal                                         obtained from a one-percent-per-annum oil price growth rate,
                 probability. This would yield the much lower net national                                 and 39% more than the two-percent-per-year growth rate.
                 economic benefits of $2.8 and $1.8 billion respectively.                                         The effect of these very high oil price assumptions

                       The values..for the NNES reported above  are obtained                               is to project a much higher NNEB for   the oil-producing

                 The Wilderness Society
                 Page 11                                                                                 The Wilderness Society
                                                                                                         Page 12

                 projects than would be the case for a more conservative oil
                                                                                                         probabilities of discovery, though of lower quantities of
                 price estimate. if the NNEB is calculated using an oil
                                                                                                         oil, actually have more "outstanding" oil Potential than the
                 price estimate that is too high, the benefits of producing                              Arctic.
                 oil will be over-estimated, and the resulting balancing of                                   The same criticism holds true for Figure 111-2, also on
                 the costs and benefits of the project will be misleading.                               page 50, a bar graph of the conditional production estimates
                       The incomparable sets of numbers in the two charts on                             for the 1002 area compared to five producing fields. Once
                 page 50 of the report can also be misleading. Table ZIZ-1                               again, the numbers do not fit because the estimates for the
                 fails to report the risks associated with potential oil                                 Arctic are contingent upon the one-in-five chance that any
                 resources in a variety of areas around the country. Since
                                                                                                         economic fields will be discovered, while the other numbers
                 many of the areas listed are already producing, there is no                             refer to prove reserves. To make a meaningful comparison
                 longer an associated risk that economic finds will not be                               of this sort, the estimates for the 1002 prospects should be
                 made. However the range of risks associated with the                                    explicitly adjusted downward to account for the differences
                 undiscovered  resources vary widely and, by definition, are                             in risk among the different areas. if the Interior Depart-
                 all greater than the risks associated with prove areas. If
                 the risk were factored into  .the probabilities for the                                 ment had done this, instead of the highest bar for the
                                                                                                         Arctic outstripping Prudhoe Say, it would only reach about
                 Arctic, the average quantity of economically recoverable oil                            as.high as Kuparuk, a difference of about 7.5 billion
                 expected to occur in the area would be 0.61 billion barrels,                            barrels. This report is intended to guide the general
                 not the 3.2 billion barrels reported in this table and                                  public and Congress in reaching a decision on the future of
                 throughout the report. Based on current domestic                                        the Arctic Coastal Plain. Misrepresentations such as these
                 consumption, 0.6 billion barrels would supply the nation for                            only serve to undermine the credibility of the entire
                 a mere 33 days.                                                                         report.
                      The Interior Department's failure to Include a column                              ENERGY CONSERVATION
                 in the chart (pg. 50) showing the risked probabilities makes                                 The Secretary's recommendation states that 11(d)evelop-
                 it impossible for the public to make any meaningful                                     ment of its potential oil and gas resources could make a
                 comparison of the oil potential of the 1002 area with other                             significant contribution to the economy and security of this
                 areas around the country. If the risk information were                                  Nation ... 11 However, even the 3.2 billion barrels of
                 available, it would likely show that other areas with higher                            supposedly recoverable oil would supply a mere 4 percent of

                 The Wilderhess Society                                                                  The Wilderness Society
                 Page 13                                                                                 Page 14

                 U.S. oil demand in the year 2005 1page 169). This much oil                              ENVIRONMENTAL CONSEQUENCES
                 could be saved through a variety of energy conservation                                      Not only does the Department exaggerate the oil
                 measures, leaving the Arctic Refuge intact for the benefit                              potential of'the refuge, it dramatically understates the
                 of future generations.                                                                  threat oil development poses to the refuge's incomparable
                      In 1985, the Department of Energy issued a National                                and irreplaceable wildlife. For example, the report
                 Energy Pol Iicy Plan which stated that energy conservation                              concludes that full-scale oil development would have a major
                 "has proven to be the most expeditious way to reduce the                                adverse Impact on the nearly 600 muskoxen that reside on the
                 need,for new or imported energy resources; and In fact it                               coastal plain, resulting In the loss of up to 50% of the
                 now contributes more to balancing our national energy ledger                            population. Habitat loss and direct mortality would have a
                 than does any single fuel source." Despite this                                         majoradverse affect on the snow geese population, a species
                 acknowledgement of the benefits of energy conservation, the                             that is already declining in numbers.   IThe report predicts
                 President recently vetoed the National Appliance Energy                                 the average number of snow geese using the 1002 area for
                 Conservation Act, passed overwhelming by both houses of                                 Fall staging could be reduced by nearly 50 percent. With an
                 Congress. This single piece of legislation, which would                                 average of 105,000, and as many as 325,000 birds staging in
                 have established-national efficiency standards for home                                 the area, this is a reduction of 52,000 to 162,000 geese.
                 appliances, would have saved more than 1.5 billion barrels                                     Polar bears, a circumpolar species also in decline,
                 of oil over the life of appliances purchased during the next                            would lose two of three known concentrated denning areas
                 14 years. How can the Administration talk about the need to                             within the 1002'area to development such as port facilities
                 develop a highly speculative area of the Arctic Refuge for                              and desalination plants, vehicles, human intrusion, and
                 .national security, wh ile vetoing a sure-fire way to conserve                          noise during critical phases of the animal's life cycle --
                 a very significant amount of energy?                                                    hibernation, birthing and nursing. The report    concludes
                      Likewise, the Administration has rolled back automobile                            that the Beaufort Sea population could not sustain an
                 mileage standards and supports raising the 557mph speed                                 increase in mortality because the death rate Is already
                 limit. Collectively these energy conservation measures.and                              equal to the birt.h rate, yet states that development in   the
                 others could save more oil than the Arctic Refuge is.                                   refuge would have an adverse effect on the species. In
                 predicted to yield under the most likely.scenario..                                     reaching this conclusion, the report assumes,that similar

                                                                                                         intensive development will not occur along the entire

                 The Wilderness Society                                                                 The Wilderness Society
                 Page 15                                                                                Page 16

                 northern coast of Alaska and Canada. This assumption                                   hunting) that can;be attributed to development. It seems
                 ignores the fact that, outside of the refuge, the entire                               more reasonable to conclude that development would result in
                 Arctic coastal plain shoreline and outer continental shelf                             the continuation of a major adverse impact on wolves.
                 in Alaska are open to development. Petroleum development is                            Porcupine Caribou Herd
                 also occurring east of the refuge in the Mackenzie River                                    The assessment concludes there could be a major
                 delta region of the Northwest Territories. The cumulative                              negative impact on the 180,000-head Porcupine caribou herd
                 effects of current and future oil development could                                    (PCH), that mitigation is not possible in the herd's core
                 virtually eliminaIte the polar bear in the United States.                              calving area, and that full-scale leasing and development
                         The Interior Department report estimates that five                             could result in up to a 40% decline in the population. Not
                 to ten wolves (Weiler and others, 1985) seasonally use the                             only do we believe that such losses are unacceptable, but
                 1002 area, while the Alaska Department of Fish and Game                                based on the best scientific research and information, we
                 (ADFG) documented as many.as 27 adults and seven pups in the                           believe that the effects on the herd would be far greater
                 northern portion of the Arctic Refuge in late summer, 1984.                            than the report predicts.
                 Both agencies report high mortality in North Slope packs due                                The Wilderness Society's primary concerns are:
                 to hunting, aerial hunting, and disease Je.g. rabies). it is                                1) Loss of calving habitat would be the major
                                                                                                             contributing factor to population decline. Studies
                 generally acknowledged that wolves have been eliminated In                                  have shown that parturient and postpartum cows
                                                                                                             accompanied by calves are intolerant of stressful
                 the area around the Prudhoe Bay complex. Yet the report                                     surroundings and seek areas of little or no disturbance
                                                                                                             (Cameron, 1983). Cameron believes that "intensive
                 concludes that full-scale petroleum leasing and development,                                oilfield development may result In virtual abandonment
                 along with 6,000 people moving onto the the coastal plain of                                of areas previously occupied during calving."
                                                                                                             2) Specifically, calving and feeding habitat would be
                 the refuge, would result in only a moderate decline in the                                  lost by covering drill pads, approximately 20 to 35
                                                                                                             acres in size, with 5 feet of gravel. However, the
                 wolf population. What is a moderate impact on 5, 10, or 20                                  visual impacts of pads with derricks would be far
                                                                                                             greater. Dau and Cameron (1985) report a two-mile
                 wolves?                                                                                     sphere of influence around development -- an area that
                                                                                                             is avoided by caribou during the critical calving and
                      Researchers report the wolf populations on the North                                   post-calving period. Under the preferred alternative,
                                                                                                             the assessment estimates that 50 to 60 drill pads would
                 Slope are considered.low compared to their abundance prior                                  be constructed on the herd's calving grounds. If the
                                                                                                             caribou do in fact avoid each of these pads as the
                 to intensive aerial hunting and predator control (Weiler et                                 research indicates, an enormous amount of habitat would
                                                                                                             be lost. To make matters worse, the ADFG believes that
                 al., 1985). The Interior Department report predicts this                                    "the numbers of drill pads and material sites are
                                                                                                             greatly underestimated." This should be a serious
                 trend will continue due to the direct mortality (i.e.                                       concern for the Fish and wildlife Service and must be

                  The Wilderness society
                  Page  17                                                                                  The Wilderness Society
                                                                                                            Page 18

                        adequately addressed in the f inal Environmental Impact
                        Statement.                                                                               report asserts many of the adverse affects from
                                                                                                                 development but seems to ignore the effects 6000 people
                        3) The loss of insect-relief habitat, particularly in                                    are going to have on the herds, especially during such
                        coastal areas, is also greatly understated. While the                                    a critical phase of the life cycle.
                        report does admit that nearly 80% of the coastal                                    Pollution Impacts
                        insect-relief habitat could be affected if development
                        proves to be a barrier to movement, it ignores the fact                                  The assessment is seriously deficient In addressing the
                        that research indicates that linear development, such
                        as the proposed east-west road and elevated pipeline                                effects of pollution from oil development on the refuge and
                        bisecting the 1002 area, has the lowest crossing
                        success rate (Shideler:ADFG Technical Report No.86-3,                               its sensitive wetlands, aquatic systems, and wildlife. For
                        pg. xi, No. 12). Smith and Cameron 11985) found that
                        "large, mosquito-harassed groups of caribou do not                                  instance, the report fails to mention that there have been
                        readily cross beneath elevated pipelines." They found
                        that many animals walked or trotted parallel to the                                 more than 23,000 reported oil spills at Prudhoe since 1972.
                        pipeline for long distances, "result[ing) in a
                        substantial increase in energy expenditure. These                                   The two largest spills were 200,000 and 658,000 gallons. or
                        authors expressed concern that if this unproductive
                        activity is repeated several times during the summer,                               that in 1985 alone there were 521 spills dumping more than
                        as it surely would be in the case of the PCH, it "would
                        result in a net decrease In fat accumulation    *                                   82,000 gallons of oil onto the tundra and Into the
                        during the (crucial] midsummer period of rapid giow*th
                        and fattening." These changes in energy status and the
                        associated stress could have serious implications for                               drainages. Nor was it pointed out that studies have shown
                        the winter survival rate for these animals and                                      that 30-year old spill sites in Alaska show little signs of
                        adversely affect the long-term health and viability of
                        the herd.                                                                           recovery.
                        While the report admits that roads/pipeline would
                                                                     a                                           Improper disposal of drilling waste is seriously
                        impede the free movement of tens of thousands of
                        animals in the PCH, little attention is given to a                                  affecting water quality in the vicinity of the Prudhoe
                        subsea pipeline alternative. It is stated that such a
                        route is technically feasible but presents                                          oilfields. The report should have noted that the
                        significantly higher environmental risks than does an
                        onshore pipeline. This may be true in the short run,                                900-square-mile complex contains 500-600 wells, with
                        but given the irreparable damage any onshore route
                        would have on the PCH, it certainly is not the case in                              operations producing approximately 840,000 gallons of
                        the long run. The ADFG agrees. The agency points out
                        that "although the consequences of an oil spill from a                              drilling muds per well per year. State Department of
                        marine pipeline may be catastrophic, the probability of
                        such a spill is very low" (Commissioner Collinsworth,                               Environmental.Conservation (DEC) reports indicate that
                        ADFG comments, Enclosure F, pg 1, para.5).     Further
                        "the long-term environmental consequences of an                                     discharges from 20 out .of 21 major reserve pits that store
                        aboveground onshore pipeline . . are cumulatively much
                        more adverse to fish and wildlife than a marine                                     these wastes violate EPA standards, discharging toxic
                        pipeline." This issue must be more fully developed and
                        discussed in the final report.                                                      chemicals and heavy metals such as arsenic, barium, lead,
                        4)FInally, numerous researchers have reported that                                  manganese, chromium, zinc, and copper, brine, and
                        vehicle and aircraft traffic, noise, people, and
                        general activity is more disturbing to caribou than                                 carcinogens such as aromatic hydrocarbons into aquatic and
                        merely the presence of roads or structures. The 1002

                 The Wilderness Society
                 Page 19                                                                                 The Wilderness Society
                                                                                                         Page 20

                 wetland habitats. The   ADFG is concerned that this practice                            either not been undertaken or are inadequate to make these

                 will continue in the 1002 area and will "result In chronic
                                                                                                         determinations. Meanwhile the industry continues to pollute
                 and/or acute  contamination of wetland organisms by heavy                               unabatedly and hopes to expand the current operation into a
                 metals, hydrocarbons, or salts." The agency also expreises                              national wildli fe refuge.
                 concern over Industry's practice of controlling road dust by                                 There is no mention in the report of the dangers of
                 applying reserve pit supernatant, further spreading these                               hazardous waste spills such as ARCO's contractor, North
                 harmful pollutants to uplands or other wetland areas.                                   Slope Salvage company's 1983 spill involving more than
                        The ADFG concludes that "although the data are                                   10,000 barrels or how this waste might be properly disposed
                 strongly suggestive that impacts to fish and wildlife                                   of should oil development be authorized by Congress.
                 habitat and to lower food-chain organisms are occurring as a                                 The 1002 report also fails to address the contribution
                 result of reserve pit discharges to the surrounding                                     that air pollution from the Prudhoe oilfi  elds is having on a
                 environment, the conclusive link, that of effects on higher                             relatively little understood problem known as Arctic haze.
                 food-chain organism, remains to be proven. However, all                                 Yhe state permits the release of 80,000-100,000 tons of
                 indicators suggest that such impacts can and probably do                                nitrous oxides INOx), but,the effects of this pollutant are

                 occur -- water quality degradation around the pits has been                             unknown since there has been no air quality monitoring in
                 documented, uptake of compounds known to be detrimental to                              the region. What is known is that the once-pristine arctic
                 organisms in laboratory conditions  Ihas been found, an                                 air is becoming increasingly fouled by development in this
                 important aquatic food-chain organism has been effected, and                            and other countries. This may have serious implications for
                 aquatic invertebrate community structure has been changed."                             global air quality and contribute to climatic warming,
                 It is therefore perfectly reasonable to conclude that oil                               commonly known as the "greenhouse effect." Dr. Robert
                 development in the coastal plain of the refuge would                                    Schnell at the National Oceanic and Atmospheric
                 compound the existing pollution problems on the North Slope                             Administration reports that this blanket of soot in the
                 and affect a greater number and variety of wildlife species.                            atmosphere can be as thick as 18,000 feet and may be raising
                 Moreover, the health of humans living in and adjacent to the                            temperatures in the arctic and contributing to the rise of

                 refuge, as well as others in North America who consume                                  average surface temperatures of the entire planet.
                 migratory species, could be affected through consumption of                                  The analysis in the 1002 report of the impacts from air
                 contaminated animals. What is certain is that studies have                              and water pollution are wholly inadequate. Among the many

                  The Wilderness Society                                                                    The Wilderness Society
                  Page 21                                                                                   Page 22

                  questions that must be addressed are: What will be the                                         The most glaring omission of the report Is the absence
                  effect of increased arctic haze from development in the 1002                              of any discussion of the cumulative impacts from development
                  area? Might the temperature inversions, caused or                                         in areas adjacent to the refuge, both on and offshore. Oil
                  exacerbated by the air pollution that inevitably accompanies                              and gas lease sales are scheduled for millions of acres of
                  petroleum development, contribute to local climatic warming?                              adjacent state lands JCamden Bay, Demarcation Point, Prudhoe
                  If so, what could be the long-term effects of such    a warming                           BAY Uplands) and of 21.2 million federal acres (Sale 97)
                  trend? In such a delicate and carefully balanced environ-                                 just offshore in the Beaufort Sea. Sale 97 is scheduled for
                  ment, tho consequences could.be devastating.                                              IJuly 1987 and will be the largest lease sale ever held in
                  THE INADEQUACIES OF THE BIOLOGICAL DATA AND ANALYSIS                                      the Arctic Ocean. Activities in Canada must also be
                       The draft report falls to address or analyze thoroughly                              considered.   The effects of all these activities considered
                  the coastal plain's natUral  en@,i*vtiment and the problems and                           together are surely substantially greater thaij,iif considered
                  impacts posed by exploi;A10h and development. Though the                                  piecemeal.
                  report att=atei4 states that tha.'@Arctic Refuge is the only                                   The report acknowledges the lack of freshwater
                ,s;vh0exvaTian system unit that  protects, in an undisturbed                                supplies in the area and the need for large quantities of
                  condition, a complete spectrum of   the vaXiout arctic                                    water for both exploration mind development. @ Y6t it dod@; not
                  ecosystems In North-Ametica        6115') it fails to                                     adequately explain how Water Will be obtaineolgh:ciwhat the
                  el4cidate the biological  .significance of this fact. The                                 environmental consequences will be, particularly to fish.
                  long-term effects of oil and gas development cannot     be                                Experience at Prudhoe Bay shows that reduction In the
                  understood without an explanation of the complex ecological                               quantity and/or quality of water available to overwintering
                  processes and interrelationships of these ecosystems.                                     fish is likely to have serious impacts on fish stocks.
                       The report also states that the 111002 area is the most                              Therefore water should not be withdrawn from spring areas.
                  biologically productive part of the Arctic Refuge for                                          The report should also note that surface waters in the.
                  wildlife and is the center of wildlife activity on the                                    1002 area differ in character from those in the Prudhoe Bay
                  refuge" 1page 46). The statement is an accurate, but                                      area. Thus comparisons cannot be freely drawn. Also, the
                  somewhat empty, one without further elaboration of the                                    impact of reserve pits on flora and fauna, and their
                  broader consequences of exploration and development In    the                             habitats, are not adequately considered. Research indicates
                  1002 area.                                                                                that reserve pit discharges are making their way into the

                  The Wilderness Society                                                                  The Wilderness Society
                  Page 23                                                                                 Page 24

                  food chain, though the full extent of the harm has yet to be                            resources. First, there is no statement that any or all of
                  documented.                                                                             the proposed mitigation measures would be required under a
                       Another resource essential to petroleum exploration and                            leasing scenario. Second, even if such were made, The
                  development is gravel which, like water, is extremely scarce                            Wilderness Society questions the effectiveness of the
                  in the 1002 area. The report does not adequately address                                proposed measures.
                  the sources of gravel, the-potential for rehabilitation of                                  The conclusion of the report Itself leaves open the
                  materials sites, and the impacts on fish and wildlife. To                               question of the Department's intent regarding mitigation.
                  date, no Prudhoe Bay sites have been returned to a standard                             The description of the area's natural, historical and
                  suitable for fish and wildlife use.                                                     cultural resources is replete with statements recognizing
                       Throughout the report, in regard to virtually every                                the severe harm that will come to these irreplaceable
                  species of wildlife associated with the refuge, the                                     values. For example, the report states if leased, "[t1he
                  inadequacies of, baseline data and information are cited.                               wilderness character of the 1002 area would be destroyed...
                  Without this critical data and understanding, the                                       (page 139). The report also acknowledges that the Porcupine
                  predictions of impacts have very little credibility. It                                 Caribou Herd, and so the people who depend on it, will
                  seems wholly inappropriate for the agency, at one moment, to                            suffer significant harm should the core calving area be
                  cite its own lack of understanding, and, in the next                                    leased. Nevertheless, the proposed recommendation to
                  instant, to state as fact that effects will be minor  or                                Congress is to lease the entire coastal plain, including the
                  moderate. This Is exactly the posture taken by the agency                               critical core calving area.
                  with regard to moose, fox, wolverines, wolves, brown bears                              INADEQUATE CONSIDERATION OF WILDERNESS VALUES
                  and polar bears, among others. Regarding muskoxen, nothing                                  The 1002 report fails  to fulfill the requirements of
                  is known about the effects on Industrialization on the                                  ANILCA section 1004, requiring the review of the area for
                  species (page 113). Muskoxen have already been eradicated                               wilderness designation. Despite the determination that the
                  once from the Arctic Refuge. There would be no excuse for                               area "has outstanding wilderness qualities..." (page 46),
                  repeating the error.                                                                    the report states merely that "the 1002 area could meet the
                  MITIGATION OF IMPACTS ON FISH AND WILMLIFE                                              criteria" lemphasis added, page 46) of the wilderness Act.
                      The report fails woefully and inexplicably to address                               The Arctic Coastal Plain, without question, is eminently
                  the question of mitigation of impacts on fish and wildlife                              worthy of inclusion in the National wilderness Preservation

                   The Wilderness Society
                   Page 25                                                                                         The Wilderness Society
                                                                                                                   Page 26

                   System. The U.S. House.of Representatives       has twice passed                                patterns altered are    not even considered. Moreover there is
                   legislation-to   designate the area as wilderness. in                                           no discussion of how    the various mitigation measures
                   addition, two   separate  Fish and Wildlife Service     studies                                 proposed, e.g. area and seasonal hunting     .prohibitions, would
                   (Thayer 1982;   draft USFWS 1973).concluded that the     area is
                                                                                                                   affect the subsistence way of life. Finally cumulative
                   suitable for designation...
                                                                                                                   impacts of development of adjacent areas must be considered
                         The final report should include a detailed       description,                             specifically in assessing the effects on subsistence.
                   rather than a short listj of     the area's wi IIderness                                             The requirements of ANILCA section 810 should be        met   in
                   qualities, including 4 discussion of the area's        uniqueness,                              the 1002 report, so that Congress may consider its findings
                   its international significance, and its importance       to the                                 in determining the fate of the Arctic Coastal Plain.         The-
                   scientific community.     A half page of description,    of. which
                                                                                                                   report contains the clear implication that the Interior
                   one-quarter consists of    a quotation  from@the Wilderness Act,
                                                                                                                   Department decided to postpone the section 810 analysis,
                   is simply indefenaLble.in    a report  intended to   assist
                                                                                                                   until a lease sale Is actually planned, in the hope of
                   -Congress.and the gene  Iral public in determining   whether the                                evading this important requirement. Such an inference is
                   coastal plainis   Iwilderness should be protected    or foregone                                drawn from the   statement that section 810 compliance will
                   for oil development.                                                                            oIccur prior to  a lease sale, "unless the Congress were to.
                   INADEQUATE   CONSIDERATION  OF EFFECTS ON    SUBSISTENCE                                        exempt the Secretary from that requirement" (page 129). The
                        The report   fails to  adequately describe the.use.of the                                  Department has no reasonable justification for not preparing
                   area for subsistence and    the impacts petroleum development
                                                                                                                   the analysis at this critical juncture.
                   wouldhave on@it- despite the recognition that        the "adverse                               FAILURE TO DISCUSS LAND EXCHANGES
                   effects of petroleum . . . would have major adverse effects on                                       The Department of the Interior has entered into secret
                   subsistence activities" Upage 138). The report acknowl         edges                            land exchangenegotiations with several Native corporations
                   that "caribou is.the most important     food source" (page 41)                                  and the State of Alaska. The Wilderness Society is
                   in Arctic'Village and Old Crow. Nevertheless there in only                                      unequivocally opposed to any land exchanges regarding the
                   a passing discussion of    these villages that are.even more                                    subsurface of   the 1002 area and believes this approach is
                   dependent on the Porcupine Caribou Herd than Kaktovik. Yet                                      wholly inappropriate. An agency charged with preparing an
                   the effects.these communities would suffer should the herd's
                                                                                                                   objective study for Congress should not have simultaneously
                   population be   reduced significantly or its migration                                          been negotiating to trade away the very area it was to

                 The.Wilderness Society                                                                        The wilderness society
                                                                                                               Page 28

                 study. The lack of neutrality and objectivity proven by                                       mandate of NEPA, the Department refused to provide an
                 this effort manifests itself throgghout the report. Despite                                   opportunity for public comment. Thus The wilderness

                 numerous requests from Members of Congress to suspend the                                     Society, and other conservation groups, were forced to sue,
                 negotiations, the Department has chosen to continue them.                                     at considerable expense to the U.S. taxpayer, to claim a
                 Therefore the status and content of this process should be                                    right that should have been accorded by the agency without

                 discussed in detail in the 1002 report.                                                       argument.

                 FAILURE TO RECOGNIEE INTERNATIONAL OBLIGATIONS                                                      Even though it lost the lawsuit, the Interior

                      .The Arctic Coastal Plain is an area of almost                                           Department continued to    seek to prevent effective public
                 unparalleled international significance, but the report                                       participation. First, It provided only a 60-day comment
                 fails to t4cognize this simple fadt. Furthermore the report                                   period that fell over the Christmas holidays, effectively
                 omits anymeaningful discussion     of how international treaty                                reducing the time concerned citizens would have to devote to
                 obligationd.regatding migratory    species would be met in the                                the report. At any time of year, 60 days would be totally
                 face.:;& development.-                                                                        inadequate for a report of this magnitude and complexity.
                      The report contains no mention of the Nofthern Yukon                                     At least 90 days should have been provided. It should Al        do
                 National Park adjoining the refugi 6r of the importance of                                    be noted that a last minute two week extension was hardly an
                 cooperative management of shared    wildlife resources,                                       effective remedy to the problem as there was no way to
                 including caribou, snow geese, polar bears, and muskoxen.                                     notify the general public, outside of Alaska, of the

                 Four-fiftbs of the subsistence use of the Porcupine Caribou                                   extension.

                 Herd is estimated to occur in Canada. Yet the report fails                                          Second, hearings were not scheduled in several places
                 to assess the consequences to the people of Canada should                                     known to be centers of interest and concern about the issue.
                 the herd suffer major declines in number or alteration of                                     One is Fairbanks and another Is Arctic Village, which could
                 its migration pattern. Even more dismaying is that the                                        suffer even greater harm that Kaktovik if the Porcupine
                 agency failed to consult Canada in preparing the report.                                      Caribou Herd is splintered or diminished in size. where
                 This is I nexcusable in any case, but particularly in light                                   hearings were held, they were scheduled to exclude broad
                 of the explicit mandate of ANILCA section 1005 to do so.                                      public participation. The Anchorage hearing, for example,
                 THE EFFORT TO EXCLUDE PUBLIC PARTICIPATION                                                    was held the day after most people returned from the
                      Despite requests from conservationists, and the clear                                    Christmas holidays and was scheduled during the day. The

                 The Wilderness Society
                 Page 29

                 evening session was not announced until the very day of the

                 hearing, providing no notice to the many people who were

                 unable to take a day from work to attend the hearing, but

                 who could have attended in the evening.

                 CONCLUSION

                      Among the many unknowns, one certainty remains:

                 development of the Arctic Coastal Plain would devastate the

                 sensitive and unique wilderness environment and would prove

                 highly detrimental to the wildlife that thrives in the area.

                 in light of the known high degree of harm  threatened by

                 development and the low probability of petroleum, there is

                 no reasonable justification for the Interior Department's

                 full-scale leasing recommendation.

                      The Wilderness Society urges the Department  of the

                 Interior to reverse the draft recommendation of  full-scale

                 leasing and development. The Arctic Coastal Plain is

                 irreplaceable and far too precious to be squandered for what

                 may  at best, be a few months worth of petroleum. It should

                 be given the protection it so richly deserves as a unit of

                 the NationalMilderness Preservation System.

                                               Respectfully,

                                               George T. irampton , Jr.
                                               President
                                                                 z

                                               Randall D. Snodgrass
                                               Alaska Program Director

                 GTF:rds

                                          "R
                                              &
                                                                                                       Comments of The Wilderness Society
                                               3                                                       9 January 1987
                                                                                                       Page 2

                                                                                                            The Wilderness Society believes that the Assistant
                 THE WILDERNESS SOCIETY                                                                Secretary's recommendation for full-scale leasing and
                                                                                                       development of oil resources that may lie within the 1002
                 STATEMENT OF RANDALL D. SNODGRASS, ALASKA PROGRAM DIRECTOR,
                 THE WILDERNESS SOCIETY BEFORE THE U.S. DEPARTMENT OF THE                              area is totally unsubstantiated by the findings in this
                 INTERIOR HEARING'OM THE DRAFT ARCTIC NATIONAL WILDLIFE
                 REFUGE COASTAL PLAIN RESOURCE ASSESSMENT, JANUARY 9, 1987.                            report.

                                                                                                       0    The report concludes that full-scale oil development
                                                                                                            would have a major adverse impact on the 180,000-head
                      My name is Randall Snodgrass and I an the Alaska                                      Porcupine caribou herd and could cause a population
                                                                                                            decline of up to 404i It also admits that mitigation
                 Program Director for The Wilderness Society, a national                                    of the lose of calving habitat is impossible.
                 conservation organization of 160,000 Members dedicated to                             0    Muskoxen habitat values could be lost or greatly
                                                                                                            reduced throughout one-third of their range, with
                 the wise use and preservation of the nation's public lands.                                losses of nearly 75% of the hard's calving habitat.
                                                                                                            The U.S. Fish and Wildlife Service concludes that
                      It should be pointed out at the outset that this                                      "(a]uch a high percentage of loss in valuable calving
                                                                                                            habitat could have a major negative influence an herd
                 hearing is being held today because The Wilderness Society,                                productivity . . . and would cause the population to
                 along with other national and Alaska conservation                                          decrease."
                                                                                                       a    Many other wildlife species -- polar bears, grizzly
                 organizations, filed a lawsuit forcing the interior                                        bears, small mammals, and the millionsof birds that
                                                                                                            utilize the coastal plain for oil-or nesting and
                 Department to solicit public comment on the draft report and                               feeding -- would be adv4raely affected by the
                                                                                                            development.
                 recommendation. At great expense to the taxpayers, the
                                                                                                       0    Internationally signifiqant wilderness values will be
                 Department is currently appealing thi decisions of a federal                               foregone to accommodate the level of development that
                                                                                                            has been recommended in the 1.5 million acre coastal
                 district court judge in Alaska and a panel of judges from                                  plain.
                 the 9th Circuit Court of Appeals in California ordering them                          0    The report fails to address the effects of air and
                                                                                                            water pollution, oil spills, and hazardous waste (such
                 to comply with the Alaska National Interest Lands                                          as drilling muds) on the human and wildlife populations
                                                                                                            of the refuge. The Alaska Department of Environmental
                 Conservation Act and other laws. This is inexcusable and                                   conservation has documented that this environmental
                                                                                                            pollution is considerable in the Prudhoe Bay/Kuparuk/
                 illustrates an arrogant disregard for the public process.                                  Milne Point oilfields. The agency is discovering
                                                                                                            dangerous chemicals (e.g. arsenic, lead, etc.) and
                 The 60-day comment period scheduled during the holidays                                    carcinogens appearing in the food chain.
                 (November 24 - January 23), today's hearing, and two                                  0    The report admits that there is only a one in five
                                                                                                            chance that any economic fields will be discovered In
                 hearings hold earlier this week in Alaska, still do not                                    the 1002 area. Yet the Department's recommendation
                                                                                                             some to ignore this probability. In public
                 provide the general populace adequate opportunity for                                      :nnouncements the agency cites the area's mean

                 analysis or comment.
                     1400 EYE STREET, N.W. WASHINGTON, D.C. 20005
                                      (202) 842-3400

                    Comments of The Wilderness Society
                    9 January 1987
                    Page 3

                         conditional potential   Of 3.2 billion barrels, an
                         estimate that fails to incorporate the risk that no
                         economic finds will be made. if this 19% marginal
                         p                              the potential falls to 606
                          robability is incorporated,
                         million barrels, a 33 day supply of oil at the current
                         rate of consumption. Finally, the study assumes an oil
                         price of $33 per barrel, but most industry analysts
                         predict that prices will not be that high until after
                         the year 2000.

                    0    The hypocrisy of this Administration is evident when
                         you consider that the development-at-all-cost
                         decision was made as President Reagan was vetoing the
                         National Appliance Energy Conservation Act
                         legislation that passed overwhelmingly in both houses
                         of Congress that would have saved more oil than would
                         be produced under the most optimistic scenario in the
                         coastal plain of the refuge.

                         The risk of oil development to this priceless national

                    wildlife refuge and wilderness area in unquantifiable. The

                    Wilderness Society believes that the sacrifice the American

                    people are being asked to make in too great. The Arctic
                    Wildlife Refuge was established in 1960 to protect unique

                    and pristine arctic ecosystems. it is a part of our

                    national heritage and is of inestimable value to future

                    generations. We cannot allow it to be destroyed for a       one

                    in five chance at a 33 day   supply of oil. The Wilderness

                    Society urges the Secretary   of the Interior to recommend

                    wilderness protection for the entire 1.5 million acre 1002

                    area.

                                                                                                                                                                R A
                DO YOU WANT TO HAKE PUBLIC COMMENTS?

                If you would like to speak at the hearing today, please fill in the blanks
                below and turn it in to one of the Fish and Wildlife Staff members present.
                You need not complete this sheet to submit written comments. Thank you.                                       THE WILDERNESS SOCIETY

                Please print                                                                                                  STATEMENT OF                        M-LASKA REGIONAL DIRECTOR, THE
                                                                                                                              WILDERNESS SOCIETY, BEFORE THE FISH AND WILDLIFE SERVICE, ON
                Nam                                                                                                           THE ARCTIC NATIONAL WILDLIFE REFUGE COASTAL PLAIN RESOURCE
                Mailing Address                                                                                               ASSESSMENT, JANUARY 5, 1987.

                                                                                                                                    For over 50 years, The Wilderness Society has been
                                                                                                                              dedicated to the wise management of the federal lands and
                                                                                                                              the preservation of wilderness. The Society's history in
                Check appropriate box belowi                                                                                  Alaska goes back to its very founding by Robert Marshall, an
                  E3 I as have to offer my    own views.                                                                      early explorer of the Brooks Range.
                                 --or-       Wt-c      1,/                                                                          The incomparable and indisputable@ wilderness and
                       I an speaking for                  L       /t/tf-S -f   5         7@-                                  wildlife values of the Arcti. National Wildlife Refuge, and
                                          (please enter name of organization you represent)                                   specifically the coastal plain, have long made it a major
                                                                                                                              focus of The Wilderness Society. The original wildlife
                                                                                                                              range was established in 1960 thanks, in large part, to the
                                                                                                                              efforts of Olaus and Mardy Murie. The late Olaus Murie,
                                                                                                                              President of the organization for 17 years, spent years
                                                                                                                              conducting research in the refuge, and Mardy Murie still
                                                                                                                                                                        e
                                                                                                                              guides the organization as a memb r of our Governing
                                                                                                                              council.

                                                                                                                                    on behalf*of our 160,000 members nationwide, including
                                                                                                                              1,400 in Alaska, I would like to present The wilderness
                                                                                                                              Society's comments on the section 1002 report and recommen-
                                                                                                                              dation to Congress on the coastal plain of the Arctic
                                                                                                                              National Wildlife Refuge. The problems and shortcomings of
                                                                                                                              the report are far too numerous to elucidate at this hearing
                                                                                                                              and will be discussed at length in written comments to be
                                                                                                                              submitted later. Therefore I will focus on just one of
                                                                                                                              those problems: the gross misrepresentation perpetrated by
                                                                                                                              the Interior Department upon release of the report on
                                                                                                                              November 24th and found throughout the report.

                                                                                                                                    Many of the assertions made by the Interior Department
                                                                                                                              in the materials distributed on November 24th -- the
                                                                                                                              Executive summary of the report, the news release, and the
                                                                                                                              fact sheet -- are simply not supported by the report itself.
                                                                                                                              All evidence points to the conclusion that the agency set
                                                                                                                              out intentionally to mislead the public, knowing full well
                                                                                                                              the media would have no choice but to rely on the findings
                                                                                                                              set forth in the abbreviated documents supplied at the press
                                                                                                                              conference. For the record, the 1002 report, itself, was
                                                                                                                              not available on that,day, except by special request.

                                                                                                                                                         ALASKA REGION

                                                                                                                                    519 XXTST STH AVENITE, SUITE 205. ANCHORAGE, ALASKA 99501

                                                                                                                                                                72-9453
                                                                                                                                                          (907)2.

                  The Wilderness Society                                                                     The Wilderness Society
                  Page 2                                                                                     Page 3

                       In stating the oil potential, these documents fail to                                 numbers do not fit because the estimates for the Arctic are
                  report the marginal probability, or risk, associated with                                  contingent upon the one-in-five chance that any economic
                  Arctic Coastal Plain development. Only upon delving deep                                   fields will be discovered, while the other numbers refer to
                                                                                                             proven reserves. To make a meaningful comparison of this
                  into the 1002 report itself does the reader find that there                                ort, the estimates for the 1002 prospects should be explic-
                  is an 81 percent chance that no economically recoverable oil                               S
                                                                                                             itly adjusted downward to account for the differences in
                  at all lies within the refuge. The chances of discovery                                    risk among the-d-l-f-ferent areas. if the Interior Department
                  reported in the Executive Summary and fact sheet are "condi-                               had done this, instead of the highest bar for the.Arctic
                  tional" estimates. The condition is that at least one econ-                                outstripping Prudhoe Bay, it would only reach about as high
                  omically recoverable field will be found. In other words,                                  as Kuparuk. That's a difference of about 7.5 billion
                  the much touted odds that the refuge holds from .6 to 9.2                                  barrels. This report is intended to guide the general
                  billion barrels of recoverable oil only come into play if
                  economically producible oil is discovered. Again, there is                                 public and Congress in reaching a decision on the future of
                  only a 19 percent chance of that occurrence. To put this 19                                the Arctic Coastal Plain. But it requires an economist to
                  percent risk figure in context, the adds of.finding an                                     detect the misrepresentations made by the Interior
                  economic field at Mukluk Island were greater than 70 per-                                  Department.
                  cent. The drilling at Mukluk Island-resulted in a dry hole.                                     What this explanation means is that the probability of
                                                                                                             finding oil in the Arctic Refuge is far smaller than all the
                       The news release and Executive Summary declare the                                    agency hype leads the public to believe. Moreover the
                  Arctic Coastal Plain to be "the most outstanding oil and gas
                  frontier remaining in the U.S." Howevei, though a cursory                                  anticipated harm to the wildlife, particularly the Porcupine
                                                                                                             Caribou Herd, is far greater than the agency admits. For
                  glance at the report may appear to support this statement,                                 example, careful reading of the report reveals such conclu-
                  careful scrutiny fails to substantiate it. This peculiarity                                sions as "Im)'itigation of the loss of caribou habitat in
                  results from a combination of the omission of crucial infor-                               [the core calving area] is not possible" (page 111).
                  mation and the inclusion of incomparable sets of numbers in                                Furthermore the report repeatedly cites the lack of infor-
                  single charts. In effect, the agency has mixed apples and                                  mation and experience required for an accurate assessment of
                  oranges in reporting their analysis.                                                       the impacts.
                       This misleading outcome occurs specifically in the two                                       ong the many unknowns, one certainty remains:
                  charts on page 50 of the report. Table III-I fails to                                           Am
                                                                                                             development of the Arctic Coastal Plain would devastate the
                  report the risks associated with potential oil resources in                                sensitive and unique wilderness environment and would prove
                  a variety of areas around the country. Since many of the                                   highly detrimental to the wildlife that thrives in the area.
                  areas listed are already producing, there is no longer an                                  In light of the known high degree of harm threatened by
                  associated risk. However the range of risks associated with
                  the undiscovered resources vary widely and are all greater                                 development and the low probability of oil, there is no
                                                                                                             reasonable justification for the Interior Department's
                  than the risks associated with proven areas. ff-t-he risk                                  full-scale leasing recommendation.
                  were factored into the probabil-ities for the Arctic, the
                  average quantity of economically recoverable oil expected     to                                The Wilderness Society urges the Department of the
                  occur in the area would be .61 billion barrels, not the 3.2                                Interior to draw the only conclusion demanded by the report
                  billion barrels reported in this table and throughout the                                  and thus, to reverse the draft recommendation. The Arctic
                  report.  .61 billion barrels would supply the nation for                                   Coastal Plain is irreplaceable and far too precious to be
                  just over.one month.                                                                       squandered for what may, at best, be a few months worth of
                                                                                                             oil. It should given the protection it so richly deserves
                       The Interior Department's failure to include a column                                 as a unit of the National wilderness Preservation System.
                  listing the risks in the chart makes it impossible for the
                  public to make any meaningful comparison of the oil poten-
                  tial of the 1002 area with other areas around the country.
                  If the risk information were available, it would likely show
                  that other areas with higher probabilities of discovery,
                  though of lower quantities of oil, actually have more
                  "outstanding" oil potential than the Arctic.

                       The same criticism holds true for Figure 111-2, also     on
                  page 50, a bar graph of the conditional estimates for the
                  Arctic compared to five producing fields. once again, the

                                              IFIEWIENSTION                                                                 1002 EVALUATION PROCESS
                                             OF NILSSON
                                            Vw AMOM AREM of Ow                                       As  stated previously in our public testimony, the coastal plain
                                            Na"W41 Immio F""I"                                       of  the Arctic National Wildlife Refuge must always be viewed
                                                                                                     first as a wildlife refuge. The assessment report recognizes the
                                            February 6, 1987                                         value of this conservation unit when It states (p. 45) "...The
                                                                                                     Arctic Refuge is the only conservation system unit that protects,
                                                                                                     in an undisturbed condition, a complete spectrum of the various
                                                                                                     arctic ecosystems in North America." The important values of the
                                                                                                     coastal plain are also acknowledged by the report's observation
                                                                                                     that '%  * The 1002 area is the most biologically productive part
           U.S. Fish and Wildlife Service                                                            of the Arctic Refuge      for wildlife and is the center of wildlife
           ATTN: Division of Refuge Management                                                       activity on the refuge"   (p. 46).
           2343 Main Interior Building
           18th and C Streets NW                                                                     The establishment of      the refuge In 1960 to preserve its unique
           Washington, D.C.    20240                                                                 wildlife, wilderness,     and recreation values resulted in the
                                                                                                     remainder of Alaska's North Slope and adjacent offshore waters
                                                                                                     being made available      for petroleum exploration and development.
           Re:   Comments and Recommendations Pertaining to Draft "Arctic                            Passage of the Alaska National Interest Lands Conservation Act
                 National Wildlife Refuge, Alaska, Coastal Plain Resource                            (ANILCA) in 1980 created a requirement under Section 1002(h) of
                 Assessment", November 1986                                                          the Act to prepare the Arctic National Wildlife.Refuge Coastal
                                                                                                     Plain Resource Assessment. The analyses and evaluations required
                                                                                                     for the Section 1002(h) Report to Congress are clearly intended
           The Wildlife Federation of Alaska (wrA) is the state     affiliate of                     to provide an assessment of the biotic resources, oil and gas
           the National Wildlife Federation, an organization with 4 112                              production     potential,  and compatibility of exploration and
           million members nationwide, 8,000 of whom are Alaskans. We have                           development in view of impacts to fish, wildlife, and habitats of
           reviewed the above referenced report and recommendation to the                            the area.
           Congress of the United States and the legislative environmental
           impact statement prepared in accordance with Section 10021h) of                           The Department of the Interior, and the Draft Resource Assessment
           the Alaska National Interest Lands Conservation Act JANILCA) and                          before us at this time, would have benefitted significantly from
           the National Environmental Policy Act (NEPA).            The Wildlife                     a more open public process that included conservation groups,
           Federation of Alaska recommends that no oil and gas leasing or                            industry, the State of Alaska, and Canada. Lacking this input,
           development activities be allowed on the Coastal Plain of the                             the   report     exhibits  critical    deficiencies    in adequately
           Arctic National Wildlife Refuge until the iss   'ues and deficiencies                     addressing the requirements of Section 1002(h)(1-6).            We are
           identified in our comments and recommendations are adequately                             particularly concerned that the Secretary's recommendation to
           addressed.                                                                                pursue full leasing of the 1002 area (Alternative A) is not
                                                                                                     supported by the information and analyses presented in the
           The Wildlife Federation of Alaska offers the following comments                           report.    To the contrary, our examination of the baseline
           on the 1002 process, the Coastal Plain Resource Assessment, and                           information, recognized values of fish and wildlife habitatsp and
           the recommendation of the Department of Interior proposing full                           environmental    consequences    of   oil and gas development as
           leasing of the    coastal plain.      We have previously offered                          presented In the Resource Assessment clearly identifies a level
           testimony at a    public hearing on the Coastal Plain Resource                            of   adverse    impact    to national, and international wildlife
           Assessment held   in Anchorage, Alaska, on January 5, 1987. We                            populations which is unaccepatable and clearlynot compatible
           wish to expand    upon selected concerns and issues identified in                         with the purposes for which the refuge was established. We find
           that testimony by addressing the following topics:                                        it incongruous that this report, recognizing the anticipated loss
                                                                                                     of unique wildlife use areas and irreplaceable habitats, still
                 o 1002 Evaluation Process                                                           concludes that this significant level of adverse impacts is
                                                                                                     justified.    while espousing adherence to the Fish and Wildlife
                 o Coastal Plain Resource Assessment                                                 Service Mitigation Policy 146 F.R. 7644-7663, January 23, 1981)
                                                                                                     in the report's assessment process, the Department of Interior
                 o Mitigation                                                                        has   failed    to comply with the criteria for treatment of
                                                                                                     unmitigable impacts to Resource Category 1 habitats. For those
                 0 Recommendations
                                                                                                     WFA Comments on the 1002 Report
                                                                                                     February 6, 1987
                              P.O. Box 103782 - Andmrap, Ala*a 9010                                  Page 2
                                         (907) 278-3M

               habitats, the policy direction is -clear;            "...all losses of                          characteristics..     This short-coming      is particularly important
               existing habitat be prevented as these one-of-a-kind areas cannot                               when evaluating opportunities for maintaining no net loss of
               be replaced..." 146 F.R. 7657, January 23,               1981).    If the                       in-kind    habitat    values, an important consideration in the
               Mitigation Policy is truly an integral part of the 1002 area                                    mitigation process.
               evaluation process and not just a placebo, Resource Category 1
               habitats must not be impacted, and the ecological function and                                  The, Evaluation of Environmental Consequences (Chapter VI) is
               access to these areas must be maintained.                                                       seriously     limited   since    its    assessment     is dependent on
                                                                                                               hypothetical    development scenarios derived from insufficient
               As an organization principally concerned       with maintenance of fish                         geological information.        The general locations of oil and gas
               and wildlife resources and the habitats upon which they depend,                                 development    activities may be reasonably accurate, but the
               the Wildlife Federation of Alaska will attempt to focus their                                   scenarios are dependent on additional information which is not
               comments in this area of primary interest. Howeverp we feel                                     currently available, including the depth of structures containing
               compelled    to briefly express our concerns relating to the                                    oil or gase the type of recovery methodst well spacing, the need
               economic and social issues addressed in the report.                                             for water, injection or. gas lift, and other factors specific to
                                                                                                               the   petroleum      field.    'Lacking more dependable geological
               The Department of Interior predictions of oil and         gas potential,                        information     which   may only be attainable through selected
               estimates    of contribution to domestic energy           supplies, and                         exploratory drilling, the locations, routingv and density of
               projections of net national economic benefits are         subjective and                        development facilities as shown in the proposed scenarios are
               highly speculative.       Lacking exploration confirmation of oil or                            meaningless.
               gas discoveries, location and size of reservoirs, and a highly
               optimistic assumption of $33 per barrel for oil, the economic                                   The evaluation process and analysis of anticipated impacts to
               benefits and national need for exploration and production of                                    fish, wildlife, and habitats as presented in this report is
               petroleum from the 1002 Area Is not well supported.                                             highly    influenced     by   the presence and precise siting of
                                                                                                               facilities in relation to important habitats and use areas,
               This is particularly true in light of the fact            that President                        including migration corridors.          Relatively minor relocation of
               Reagan recently vetoed the National Appliance             Energy Act of                         facilities in the scenario could physically impact comparable
               1986.   Passed overwhelmingly by both houses of Congress, this act                              acreages, but have drastically differing effects on fish and
               would have saved the nation millions of barrels of oil and                                      wildlife populations, their use of habitats, and access to those
               billions of dollars on utility bills by the year 2000. In                                       habitats.     The Evaluation of Environmental Consequences should
               addition, the Reagan Administration has opposed establishment of                                identify  facilities and structures which are not site-dependent
               fuel efficiency standards for automobiles and continuance of the                                and   which    could potentially be relocated as part of the
               55 mile/hour speed limit.                                                                       mitigation process.       The evaluation must acknowledge that a
                                                                                                               significant portion    of the oil and gas development facilities are
               No development in the Coastal Plain should be allowed until the                                 site-dependent and     do not have the flexibilty of relocation to
               concept of national energy security is more clearly defined,                                    minimize adverse impacts to important habitats.
               including a full discussion of economic forecasts, domestic oil
               consumption, the projected need for domestic oil reserves in the                                The Evaluation of Environmental Consequences also suffers from an
               1990's, and national strategies for energy conservation such as                                 excessive dependence on mitigation techiques utilized in the
               efficiency    standards    for home appliances and fuel economy                                 Prudhoe Bay development area (which may not be applicable to
               standards for automobiles.                                                                      resources and habitats in the 1002 area) and the assumption that
                                                                                                               mitigation technology to be developed in the future will reduce
                                                                                                               anticipated impacts to an acceptable level. When considering the
                                COASTAL PLAIN RESOURCE ASSESSMENT                                              irreplaceable values of some of the fish and wildlife resources
                                                                                                               at stake, we are not confident that "...performance standards
                                                                                                               ... developed for safety and environmental requirements rather
               The Description of the Existing Environment (Chapter II) provides                               than   adherence     to   highly    specific design or operational
               a reasonably good summary of available information and research                                 procedures..."    (p.  97) is an appropriate approach to mitigation.
               results for fish and wildlife distributions, populations, and                                   It is perhaps more important to recognize that.a Prudhoe Bay
               seasonal use of terrestrial and aquatic habitats within the 1002                                scale   development may not be acceptable within a national
               area.    However, discussions of the coastal habitats, their                                    wildlife refuge.
               occurrence within and outside the 1002 area, and ecological
               relationships to fish and wildlife populations are generally not                                Consideration of cumulative impacts of oil and gas development in
               adequate   to define specific habitat affinities and habitat                                    the 1002 area with other existing and proposed onshore and

               WFA Comments on the 1002 Report                                                                 WFA Comments on the 1002 Report
               February 6, 1�87                                                                                February 6, 1987
               Page 3                                                                                          Page 4

            offshore developments has not been adquately addressed in the                               and   the ultimate effects of displacement are unknown...".         Under
            Evaluation of Environmental Consequences.           In addition,     the                    the    full   development     scenario,   the FWS has appropriately
            national and international range and human use of migratory                                 recognized that "...mitigation of the loss of caribou habitat in
            wildlife    resources    which are highly dependent on habitats                             Resource Category 1 ... is not possible... t' (p. 111).        Following
            available in the 1002 area has not been adequately recognized for                           the premise (p. 98)       that "... the FWS normally recommends that
            the Porcupine Caribou Herd (PCH) or snow geese. Some of our                                 all   losses of Resource Category I habitat be prevented, as these
            concerns    regarding the treatment of these key species are                                one-of-a-kind      areas  cannot    be    replaced. . . " ,the logical
            presented below:                                                                            conclusion is     that the PCH core calving habitats within the 1002
                                                                                                        area     should   be   justifiably    excluded    in the Secretary's
                                                                                                        recommendation   for oil and gas development.
            PORCUPINE CARIBOU HERD:
                                                                                                        As spring progresses on the coastal plain and the weather warms
            A great deal has been learned about the effects of oil and gas                              following completion of calving activity, conditions are ripe for
            exploration and production on caribou in the Prudhoe Bay area,                              the emergence of swarms of mosquitos. As harassment by these
            e.g. levels of road traffic that can occur without adversely                                insects increases, caribou form dense aggregations and move
            affecting free passage of caribou or the minimum distances                                  rapidly toward the. coast to seek relief in cooler, windswept
            required    to separate roads and pipelines to cause minimal                                areas such as river deltas, mudflats, aufeis, large gravel bars,
            disturbance to caribou.        However, we must be careful not to                           barrier islands, and in the shallows of lagoons (p. 29). At this
            extrapolate    from    all of the Prudhoe Bay conclusions when                              time, parturient cows are particularly stressed from the rigors
            estimating impacts in the Arctic National Wildlife Refuge because                           of pregnancy, migration, birth,        lactation, hair molt, antler
            the refuge must accommodate a very large number of animals in a                             growth, and the the ever-present insect harassment.
            small space.       In comparison, Prudhoe Bay supports a relatively
            small caribou herd in an area of very extensive suitable habitat.                           The Resource Assessment noted that "...the entire 180,000-member
                                                                                                        PCH may use the area in some years, mainly during the late
            The available literature concerning the Central Arctic Caribou                              June/early July insect-relief period..." (p.           105).    The FWS
            Herd suggests that portions of the herd have been displaced from                            observation that "...access to insect relief habitat and forage
            the Prudhoe Bay and Kuparuk areas during part of their annual                               resources    during    this    period   may    be   critical to herd
            cycle with no obvious effect on herd growth. However, within the                            productivity..." (p. 29) recognizes the significant importance of
            Arctic National Wildlife Refuge the Coastal Plain is extremely                              insect relief areas to the post-calving aggregations of the PCH.
            narrow when compared with the Prudhoe - Kuparuk area. The Arctic                            The availability of forage resources and the physical features
            Refuge Coastal Plain is 6 times larger than the Prudhoe Say                                 which make up insect relief areas comprise a specialized habitat
            field, but there are approximately 12 times more caribou in the                             that may not be replaceable. We recommend designation of primary
            Porcupine    Caribou Herd than the Central Arctic Herd.                In                   insect relief habitats in the Coastal Plain of the 1002 area as
            addition, the PCH appears to be reaching maximum herd size. Most                            Resource Category I habitats which are unique and irreplaceable
            large mammal biologists would conclude that a herd approaching a                            components of the Porcupine Caribou Herd use area. In addition
            peak population within its range would occupy essentially all                               to maintaining the function of insect relief areas, access to
            suitable habitat available.         Therefore,   the opportunity for                        these habitats from the core calving area must be assured.
            displacement of the PCH during calving is probably limited, and
            such displacement could result in a net loss to the caribou                                 Contrary to the facts and analyses presented in the Environmental
            population.      Although the projected 20-40% decline in PCH                               Consequences    and    Mitigation    discussions,    the     Secretary's
            population estimated by FWS under a full development scenario (p.                           Recommendation    (Chapter VIII) to make the entire 1002 area
            112) is impossible to verify considering all the variables                                  available for oil and gas leasing, even with the caveat that
            associated with preferred calving and insect relief habitats and                            "...leasing would be phased so the core calving area of the PCH
            migration movement areas, it strongly indicates that displacement                           would be last to be explored and developed..." (p. 170)0 is in
            of the PCH could cause a significant decline in population.                                 direct conflict with the findings of the Resource Assessment and
                                                                                                        the procedures of the FWS Mitigation Policy which "...guided the
            We heartily concur with the designation of approximately 242,000                            assessment    team    in   identifying    appropriate     measures for
            acres of the PCH core calving area as Resource Category 1                                   mitigating    avoidable adverse impacts so there would be no
            habitats,   recognizing that the 1002 core calving area represents                          unnecessary   adverse effects" (p. 97).     In this light, we can only
            approximately 80% of the total core calving area used by the                                conclude that the Secretary has determined "avoidable adverse
            Porcupine Caribou Herd (p. 106). The assessment also notes (p.                              impacts" to the Porcupine Caribou Herd are the "necessary adverse
            108) that "...measuring the probable population decline from                                effects" of oil and gas development.
            complete loss of habitat values in calving areas is impossible

            WFA Comments on the 1002 Report                                                             WFA Comments on the 1002 Report
            February 6, 1987                                                                            February 6, 1987
            Page 5                                                                                      Page 6

              SNOW GEESE:                                                                                areas which are currently designated Resource Category 2. The
                                                                                                         baseline studies for snow geese conducted on the 1002 area do not
              Critical fall staging habitats of snow geese from the Banks                                define the habitat characteristics which were representative of
              Island population have not received adequate attention in the                              preferred staging areas, although they noted a heavy dependence
              report discussions and evaluation of environmental consequences.                           on cottongrass (Erlophorum sp.) and speculated that annual shifts
              The Resource Assessment should be expanded to include greater.                             in preferred staging areas may be related to heavy utilization of
              detail on the importance of fall staging activities to the                                 previously used staging areas.          If this annual shift to allow
              welfare of migrating snow geese, the characteristics of preferred                          recovery of staging habitat vegetation is verified, it would
              staging habitats, and the human use values of this resource                                suggest the necessity of considering all fall staging areas used
              outside the boundary of the 1002 area. An average of 105,000                               by snow geese in the 1002 area as a part of an annual habitat
              snow geese, and as many as 325,000 snow geese, have historically                           rotation.
              staged on the 1002 area in the fall to feed intensively and build
              energy reserves prior to their southward migration. These fat                              The significant segment of the snow goose population which could
              reserves are considered by waterfowl biologists to be necessary                            be adversely affected or displaced by oil and gas development,
              .energy reserves to successfully complete migration, particularly                          the vulnerability of staging snow geese to disturbance, and the
              for' female snow geese recovering from the stress of reproduction                          undefined unique habitat characteristics of traditional staging
              activities.                                                                                areas supports the WFA recommendation to include snow goose fall
                                                                                                         staging areas within the coastal plain as Resource Category 1
              Chapter VI recognizes that "...reduced time spent feeding and                              habitats.
              lost habitat in which to feed would result from petroleum
              development,   adversely affecting-"the accumulation of energy
              reserves essential for migration" (p. 121). In addition, "...a                             PERENNIAL SPRINGS AND FRESHWATER OVERWINTERING AREAS FOR FISH:
              major reduction or change in distribution of snow geese using the
              1002 area could occur through the cumulative effects of direct                             Perennial springs and freshwater overwintering areas for resident
              habitat loss, indirect habitat loss due to disturbance, and                                and anadromous fish have not been adequately addressed in the
              direct mortality" (p. 122).        Based on the report's assumed                           Resource   Assessment.       Suitable    overwintering habitats in
              displacement of snow geese from 45% of their preferred staging                             freshwater systems of the refuge are concentrated at a limited
              habitat, a reduction in the Banks Island snow.goose population of                          number of locations where adequate flow, water quality, dissolved
              5-10% could occur and the number of      snow geese annually staging                       oxygell, Oflu benthic food organisms are available. Perennial
              in the 1002 area could be reduced by     almost 50 percent (p. 122).                       ground water sources (springs) are found on most of the major
              We are not impre ssed by the statement   that "...staging snow geese                       drainages in the 1002 area.
              are highly mobile ... " (p. 121) as it   indicates a lack of insight
              into the concepts of preferred habitat   and carrying capacity.                            Within the Arctic National Wildlife         Refuge, "...overwintering
                                                                                                         habitat is probably the greatest limiting factor for Arctic
              The potential reduction in numbers of Banks Island snow geese                              anadromous and freshwater fish populations..." (p. 37). The
              would be 15-30,000 birds. Approximately 60-70,000 snow geese are                           Alaska Habitat Management Guide for the Arctic Region (Alaska
              harvested annually in the Pacific Flyway with 80-90% of this                               Department of Fish and Game. 1986) notes that in smaller North
              harvest occurring in California.        An additional 30-50,000 snow                       Slope drainages it is conceivable that a single spring-fed site
              geese are harvested annually in Alberta and western Saskatchewan.                          might harbor virtually all members of a particular Arctic char
              A  draft management plan for the Pacific Flyway identifies                                 population from eggs to mature adults during the winter period.
              protection of the Arctic National Wildife Refuge and Yukon
              staging areas as an important need. The potential reduction in                             Due to the limited occurrence of spring-fed overwintering areas
              Banks Island snow geese numbers from loss or disturbance of fall                           for fish and their importance in maintaining anadromous and
              staging habitats in the 1002 area could be equivalent to 50% of                            freshwater fish populations in the 1002 area,            the Wildlife
              the total Pacific Flyway harvest or essentially all of the                                 Federation of Alaska recommends that perennial ground water
              Alberta and western Saskatchewan hunting harvest in a given                                sources which support overwintering fish be designated Resource
              year.   Based on the important value of this species to national                           Category 1   habitats.     Protection of these vulnerable habitats
              and international uses, we would not consider potential impacts                            must also include appropriate protection of the groundwater
              of oil and gas development in the 1002 area to be insignificant.                           source which supplies the overwintering use areas and prohibition
                                                                                                         of water removal for domestic or industrial use during the winter
              The report does not demonstrate the availability of alternate                              period.   We also request that FWS identify the location of known,
              staging habitats which could be utilized for in-kind replacement                           spring-fed overwintering areas,      suspected but unsubstantiated
              of habitat values, an important consideration for these staging

              WFA Comments on the 1002 Report                                                            WFA Comments on the 1002 Report
              February 6, 1987                                                                           February 6, 1987
              Page 7                                                                                     Page 8

             overwintering areas, and necessary mitigation measures to avoid                                           0      lack of relative experience regarding the responses or
             adverse impacts to these irreplaceable habitats.                                                                 adaptability     of    the    PCH to intensive development
                                                                                                                              activities

                                              MITIGATION                                                               0      unknown capacity of the PCH to utilize undisturbed areas
                                                                                                                              in greater concentrations for calving

             The WFA has previously identified             serious concerns with the                                   0      acknowledgement      that EVEN WITH EFFECTIVE MITIGATION
             approach to mitigation of impacts to fish, wildlife, and their                                                   (emphasis added), PCH displacement or reduction could be
             habitats in our January 5,            1987 testimony. We wish to expand                                          as great as 20-40 percent
             upon those concerns and the mitigation process as it applies to
             the resources and proposed           activities identified for the 1002                                   0      recognition that Alternative A development will result
             area.                                                                                                            in a loss ofi at minimum, a significant part of the PCH
                                                                                                                              calving grounds and other use habitats, a limit to
             As examples of the important         fish and wildlife habitat values of                                         continued expansion of 1002 area muskoxen herds, and a
             the 1002 area, the report recognizes intensively used calving,                                                   loss of notable staging habitats for internationally
             postcalving,     and insect-relief habitats for a significant portion                                            important migratory snow geese.
             of the Porcupine Caribou Herd and sensitive fall staging areas
             for a large segment of the Banks Island, Canada, snow goose                                           A summary of biological effects of Alternative A on the 1002 area
             population.       The sensitivities of these species and the unique                                   identifies major effects on caribou (PCH), muskox, and snow geese
             factors     of    the    habitats     they    utilize     are     documented.                         1p.   149).     Major environmental effects were previously defined
             Approximately     78 percent of the PCH core calving area is within                                   4p.    96)    as    "...Widespread,       long-term     change in habitat
             the 1002 area, and disturbance of the cow-calf groups on the                                          availability      or   quality which would likely modif                natural
             calving     grounds may interfere with bond formation and can                                         abundance or distribution of species using the 1002 areayl.
             increase calf mortality (p. 28).
                                                                                                                   The Secretary's Recommendation (p. 170) to make the entire 1002
             In addition,      the limited availability of these habitats is                                       area available for oil and gas leasing includes the control of
             acknowledged with statements such as "...Geography apparently                                         development by imposition of appropriate mitigation measures to
             limits     the availability of suitable alternative calving or                                        insure "...no unnecessary adverse effects on the refuge's fish
             insect-relief. habitats for the herd..." (P. 6) and "...Access to                                     and    wildlife     and their     populations..." and with assurance
             insect-relief habitat and forage resources ... may be critical to                                     "...that any unavoidable habitat losses are fully compensated"
             herd productivity" 1p. 28).                                                                           Jp.    .170).       Additionally,      the     Secretary     indicates that
                                                                                                                   "...Development would proceed with the goal of no net loss of
             Summary statements       also reflect the importance of the f002 area                                 habitat quality...", a goal discussed in greater detail in
             to a wide spectrum       of wildlife resources by stating "...The 1002                                Chapter VI, Environmental Consequences.
             ,area is the most        biologically productive part of the Arctic
             Refuge for wildlife      and is the center of wildlife activity on the                                The    Fish    and Wildlife Service Mitigation Policy                (46 F.R.
             refuge" 1p. 46).                                                                                      7644-7663, January 23, 1981) recognizes four resource categories
                                                                                                                   with corresponding mitigation planning goals to insure that the
             The evaluation of        Irreversible and Irretrievable Commitments of                                level of mitigation is consistent with the fish and wildlife
             Resources for Alternatives A and B recognizes the s@gnificant                                         resource values involved. Within the 1002 area, the FWS analysis
             impacts attributed to oil and gas development:                                                        designated the PCH core calving area as Resource Category 1 based
                                                                                                                   on its unique and Irreplaceable values; the remainder of the 1002
                  �     declines in population, herd vigor, and behaviorial                                        area has been designated Resource Category 2 for its importance
                        patterns due to disturbance and displacement of PCH 1p.                                    to five evaluation species used in the analysis.
                        142)
                                                                                                                   Resource Category 1 is defined as habitat of                  high value for
                  �     long     term    losses in fish and wildlife resources,                                    evaluation     species which is unique and irreplaceable on a
                        subsistence use, and wilderness values as the inevitable                                   national basis or in the ecoregion. The commensurate Mitigation
                        consequence   of long term development                                                     Planning Goal is no loss of existing habitat value. Development
                                                                                                                   of the rationale for mitigation planning goals (46 F.R. 7645,
                                                                                                                   January 23, 1981) included a fundamental principal "...that
                                                                                                                   avoidance or compensation be recommended for the most valued

             WFA Comments on the 1002 Report                                                                       WFA Comments on the 1002 Report
             February 6, 1987                                                                                      February 6, 1987
             Page 9                                                                                                Page 10

              resources..." and that "...the degree of mitigation requested                                adequately addressed.    In summary, these include the following:
              correspond to the value and scarcity of the habitat at risk".

              The Secretary's Recommendation (Chapter VIII) proposes making the                                0     National energy security should be clearly defined,
              entire 1002 area available for oil and gas leasing based on the                                        including    a full discussion of economic forecasts,
              assumption that most adverse environmental effects would be                                            domestic    oil    consumption,    the projected need for
              minimized or eliminated through mitigation based on information                                        domestic    oil reserves in the 1990's, and national
              from prior oilfield development at Prudhoe Bay, or through                                             strategies for energy conservation such as efficiency
              additional, ongoing studies and assessments conducted during                                           standards for home appliances ahd fuel economy standards
              phased leasing. The FWS Mitigation Policy Guideline for Resource                                       for automobiles.
              Category 1 habitats states "...The Service will recommend that
              all    losses   of    existing    habitat    be   prevented as these                             0     Decisions on the use of the coastal plain should be
              one-of-a-kind areas cannot be riplaced" (46 F.R. 7657, January                                         delayed until biological research on the characteristics
              23,   1981).   *Where there is like y to be a significant fish and                                     of the Porcupine Caribou Herd calving habitat can be
              wildlife resource loss (Resource Category 1), the FWS Mitigation                                       clearly   defined.      The conclusions of our nation's
              Policy (46 F.R. 7659, January 23, 1981 ) provides criteria to be                                       leading   caribou    biologists at a workshop entitled
              addressed in evaluation of projects. Of significant importance                                         "Demography and Behavior of the Central Arctic and
              is criteria 12) to select the least environmentally damaging                                           Porcupine    Caribou    Herds in Relation to Oil Field
              reasonable alternative, and criteria (4) which states "...All                                          Development"    conducted     in  October     1986 was that
              important recommended means and measures have been adopted with                                        scientists do not yet have a clear understanding of the
              GUARANTEED    IMPLEMENTATION (emphasis added) to satisfactorily                                        ecological attributes of caribou calving areas on the
              compensate for unavoidable damage or lose consistent with the                                          Arctic Slope.      (This workshop was sponsored by the
              appropriate mitigation goal."         Since the mitigation goal for                                    Alaska Oil and Gas Association and the Alaska Department
              Resource Category 1      is no loss of existing habitat value and no                                   of Fish and Game.)         Until critical calving habitat
              means and measures have been identified to achieve that goal in                                        boundaries can be delineated, all land use decisions
              the 1002 report, we believe that any proposal to permit oil and                                        within the 1002 area'should be    deferred.
              gas development in or adversely affecting Resource Category I
              ..abillalls is not in compliance -with the FWS Mitigation Policy.                                0     Insect relief habitats used by the Porcupine Caribou
                                                                                                                     Herd in the Coastal Plain         of the 1002 area should be
              Finally,   the mitigation measures identified in Chapter V1 (p.                                        designated Resource Category       I  habitats with specific
              145) are more appropriate for protection of discrete location                                          provision made for adequate       access by the PCH to these
              habitats and use areas which can be addressed by development                                           use areas.
              buffers, timing of activities, and performance criteria within
              the scope of technical concerns addressed in prior North Slope                                   0     Fall staging areas for snow       geese in the Coastal Plain
              oil   and    gas    developments.      In particular,     the calving,                                 of the 1002 area should be designated Resource Category
              post-calving, and insect relief        habitats of the PCH are more                                    1 habitats.
              extensive, and currently available information indicates unique
              characteristics which may not be replaceable or available in                                     0     The Coastal Plain Resource        Assessment should clearly
              alternate habitats. The important Issue of free movement between                                       describe    appropriate    mitigation    measures for each
              seasonally-important use areas of the PCH has not been adequately                                      development alternative that would result in no net loss
              addressed in the evaluation process.            Wildlife movements and                                 of critical fish and wildlife habitat. How will the
              migration are recognized as a part of habitat values which must                                        Department of Interior determine whether appropriate
              be addressed during the mitigation process (46 F.R. 7645, January                                      technology is available to restore or revegetate plant
              23, 1987).                                                                                             communities    which    occur   on , the     coastal     plain,
                                                                                                                     particularly    those    which    comprise caribou calving
                                                                                                                     habitat, caribou insect relief habitat, and snow goose
                                         RECOMMENDATIONS                                                             staging habitat?

                                                                                                               0     The following criteria should be incorporated into the
              The wildlife Federation of Alaska recommends that no oil and gas                                       mitigation process for all oil and gas development
              leasing or development activities be allowed on the coastal plain                                      alternatives considered:
              of the Arctic National wildlife Refuge until the issues and
              deficiencies identified In our comments and recommendations are                                             no net loss of caribou calving or insect relief
                                                                                                                          habitat is justified in any of the alternatives;
              WFA Comments on the 1002 Report
              February 6, 1987                                                                             WFA Comments on the 1002 Report
              Page 11                                                                                      February 6, 1987
                                                                                                           Page 12

                           free passage of caribou must be provided to all
                           insect relief.habitats;

                           no net loss of snow goose fall staging habitats is
                           Justified in any of the alternatives;

                  0   The  wildlife Federation of Alaska opposes any land trade
                      actions that precede or circumvent -completion of the
                      1002 process or any land trade actions that would remove
                      Resource Category I habitats (including caribou calving
                      and insect relief areas, snow goose staging areas, and
                      fish   overwintering areas)     from the Arctic National
                      Wildlife Refuge.
             If  these issues and deficiencies are    addressed in the context of
             an  open public process, then the        Fish and  Wildlife Service,
             conservation groups, the oil industry    and Congress would have the
             tools necessary to make well-reasoned    decisions about oil and gas
             development   and    the   protection    of   wildlife, recreation,
             subsistence, and wilderness values       on the Coastal Plain of the
             Arctic National Wildlife Refuge.

             Thank you for your consideration of these comments.

                                                Sincerely,
                                               4Ann @@IR. @ePre@.ident@@
                                                WILDLIFE FEDERATION OF ALASKA

             cc:  Senator Ted Stevens
                  Senator Frank Murkowski
                  Congressman Don Young
                  Jay Hair, National Wildlife Federation
                  Bruce Apple, National Wildlife Federation

    			Wildlife Management Institute

    			Suite 725, 1101 14th Street, N.W., Washington, D.C. 2005 202/371-1808

    DANIEL A. POOLE
    President
    _. R JAHN
    Vice-President
    _. _. WILLIAMSSON
    Secretary
    WESLEY M. DIXON, Jr.
    Board Chairman

    									February 5, 1987

    U.S. Fish and Wildlife Service
    Attn:  Division of Refuge Management
    2343 Main Interior Building
    18th and C Streets, N.W.
    Washington, D.C.  20240

    Gentlemen:

    	Re. the resource assessment of the coastal plan of the Arctic national
    Wildlife Refuge.

    	Institute staff has reviewed the draft assessment, which, from the stand-
    point of identification of the refuge's biological environment and discussion
    of environmental effects of development, we find reasonabley well done.  Our
    review of these aspects will continue.

    	Our primary concern at this point centers on the Secretary's Recommendations,
    Chapter VIII.  We strongly urge that the Secretary incorporate the following
    suggestions in his final report ot Congress:

    	1.  	That the preferential formula whereby the State of Alaska
    		currently recieves 90 percent of oil and gas royalties be reduced
    		to no more than are received by other states--50 percent maximum
    		to the state and 50 percent to the federal government.

    	2.	That a substantial portion of the federal share be credited
    		directly to the Migratory bird Conservation Fund to implement
    		the North American waterfowl Management Plan.

    	3.  	That a lesser amount be credited to the Fish and Wildlife
    		Service for satisfaction of the payments-in-lieu of taxes
    		requirement.

    	4.  	That some of the money be made available for refuge operations
    		and maintenance.  We would object, however, to any significant
    		commitment of money for O&M until after the needs of the North
    		American Waterfowl Management Plan have been satisfied.

    					DEDICATED TO WILDLIFE SINCE 1911

    U.S. Fish and Wildlife Service		-2-			February 5, 1987

    	5.	Finally we are inclined to believe that oil companies would
    		find favor with the imposition of a small surcharge per barrel
    		in support of the fish and wildlife program.

    	We request that this letter be included in the Secretary's final report to
    Congress.

    									Sincerely,

    									Daniel A. Poole
    									President

    DAP:dt

                                                                0-482

                                                                                Comments from Industry (1)

                                                                                                                                                  Page

                                                    Alaska Biological Research          .............................................................................

                                                    ARCO Alaska Inc        . ..........................................................
                                                                                                                       ..................................

                                                    Arctic Adventurers       ............................................................................................ 10

                                                    BP Alaska Exploration, Inc         .............................................................................. 11

                                                    BP North America Exploration, Inc           . ...................................................I............ 18

                                                    Chevron USA Inc        . ............................................................................................. 20

                                                    Conocoinc      . ...................................................... ....................... ............ 21

                                                    Exxon Company USA            ...................................................................................... 32

                                                    Geophysical Service Inc        . ................................................................................. 52

                                                    Standard Alaska Production Company               .......................................................... 76

                                                    Shell Western E & P Inc         . ................................................................................ 82

                                                    Standard Oil Company           ..................................................................................... 84

                                                    Tenneco Oil Company Exploration & Production                   ........................................  190

                                                    Texaco USA        ........................................................................................................  193

         ABK                                                                                              CARIBOU
         ALASKA BIOLOGICAL R1:S1:.1kCf1
                                                                                                          1.    p. 28   Paragraph 3.
         Biological and Natural                                                                           It  would be appropriate to explain the criteria/rationale used
         Resource Scien(e Studics                                                                         loc delineating the core calving area based on occupancy during 5
                                                                                                          ot  14 years (3h%). Concentration areas obviously exist, but 5 of
         P.O. Box 81934 * Fairbanks, Alaska 99708                                                         14  years seems arbitrary and thedetinition of core calving
             (907) 455-6777.- 155-6778              2 February 1987                                       radically inliuenceB the projected impacts.     It would be more
                                                                                                          appropriate to compile a table listing the number of acres that
               U.S. Piaih and Wildlife SeIrvice                                                           comprise each of the concentration areas (i.e., concentration
                                                                                                          areas used in only I year = ____ acres; 2.years = .... acres,
               Division of Refuge Management                                                              etc.). This table could then be expanded for impact analyses
               2343 Main Interior Bldg.                                                                   that would provide estimates of habitat losses for all of the
               18th and '!C" Street, N.W.                                                                 years of use, not just 5 of 14 years.
               Washington, D.C. 20240
               To whom it may concern:                                                                    2.    P. 28   Paragraph 5.
               We have reviewed the draft 1002 Report, particularly those                                 Thizs:ction   document tehitte in calving areas due to natural
                                                                                                          fac r . Do    data exi: on productivity and recruitment during
               sections dealing with terrestrial biology. Our specific comments                           any of these  years? These data would be very important for
               are attached.  In general, the baseline data collected in ANWR                             understanding the effects of displacement.
               for 1002-related biological studies are of high scientific merit,
               summarized in a brief (understandably), but informative fashion,
               and should be of great value in the decision-making process and                            3.    P. 106   Paragraph 1.
               for assessing development-related impacts.    In our opinion, most                         It is debatable whether Prudhoe Say was ever a calving area of
               issues regarding potential impacts have been adequately defined,
               with the exception of the Probabilitv for direct loss of habitats                          any consequence, but undoubtedly some caribou have been displaced
                                                                                                          from
                                                                                                          f . this area. However, in the Kuparuk Field, where th@
               and populations.  Sections  on "The Eifects on the Biological                              development is more state-of-the-art (and presumably more similar
               Environment", especially in regard to loss of coastal insect                               to an ANWR development scenario) and where a good data base for
               relief for caribou and staging habitat for snow geese, need                                pre- and post-construction calving densities exists, the data
               considerably more support from existing data. At a minimum,     more                       indicate that access to calving areas and overall densities have
               detailed explanations of the criteria and rationale used for                               not been affected.    As in ANWR, there is natural annual varkation
               estimating habitat loss, amounts of displacementi and population                           in calving densities, presumably due primarily to snow cover.
               declines are necessary. Without these elements, the impact
               assessments lack credibility.
                                                                                                          4.    p. 107   Paragraph 2.
               Thank you for the opportunity  to comment. Both reviewers have                             The secondary  habitat modifications described are   accurate, but
               field experience with many of  the species described in and                                their effects  on caribou are not supported by data.      Impounded
               adjacent to the ANWR Coastal Plain. We both agree that the                                 areas are undoubtedly lost as caribou habitat, but road-Bide
               international wildlife values of the 1002 area warrant careful                             dust, for example, accelerates snow melt in spring and we have
               and protective strategies for any resource development and we                              observed pregnant cows in May selecting road-side areas for
               wish you the best of luck in completing the final report to                                foraging.
               Congress.
               Sincerely,                                                                                 5.    p. 107   Paragraph 2-4.
                                                                                                          Very dogmatic with no citations.
                      'J

               Robert J. Ri tchie
                    n'
                      Mwz ; @Yjl -
               RJR:slk
               Attachments

                                                                                                              Caribou
                   Caribou                                                                                    vaje illree
                   Page Two

                                                                                                              10.  P. III    Mitigation #5.
                   6. P. 108    Paragraph 2.,                                                                 "Separate pipelines and roads as necessary* is too vague.
                   In this paragraph the term *displacement'  is used to   imply that                         Pipelines and roads should be.separated when possible on all
                   caribou will completely abandon the core calving area and move to                          "haul" and "spine" roads (i.e., roads with regular traffic).
                   suboptimai-habitats. In subsequent.text, the 2 mile *sphere of
                   ,influence* is used to describe displacement. These are radically
                   different concepts and we suggest using more precise terminology,                          11. p. 112     Paragraphs 3 and 4.
                   such as major displacement versus localized displacement.       In                         We appreciate the need to develop quantitative estimates for the
                   this context, there are no data from the CAN that demonstrate                              decigion-making process, but the estimates generated here,
                   major displacement.                                                                        whether they are high, low, or accurate, have not been adequately
                                                                                                              supported. Furthermore, a population decline and a change in
                                                                                                              distribution are very different impac    .to.and to quote the same
                   7. p. 108    Paragraph 6.                                                                  range of figures for both and not to distinguish between the two
                   The ABR representative to the FWS workshop, and others we                                  is at beat confusing.
                   suspect, were using available evidence (Dau and Cameron 1985) and
                   agreed that localized displacement would occur.
                                                                                                              12. p. 132     Paragraph 2. Same as above

                   8. P. 109    Paragraph 6.
                   This impact analysis for the insect season requires more                                   13. p. 134     Paragraph 2.
                   justification. We think that use of the 2 mile "sphere of                                  Once again, the 2 mile 'sphere of influence"      is probRbly
                   influence" derived from data acquired during calving is probably                           inappropriate for analyaos of impacts during      the 3nEiect season.
                   inappropriate for insect season analyses. The authors state on
                   p. IU'/, paragraph 5 that calving is the time of greatest
                   v
                   Inerability to disturbance, yet this worst-case situation is                               14.  p. 134    Paragraph 2.
                   u
                   used to delineate insect-season impacts.    We agree that the CAN                          "Over 80 percent of coasts.!,-Insect-relief habitats would remain
                   and PCH are not 100% comparable, yet there are extensive insect-                           unavailable under limited. leasing.*     As stated without any
                   season data available on caribou movements, reactions to                                   qualification, this otatpment is misleading.       This degree at
                   disturbance, and the effectiveness of mitigation from the CAN                              habitat loss is not ouy:ported by data from the [,AM experience;
                   experience that apparently were not included in this impact                                this should be noted.
                   analysis. In the Kuparuk Oilfield virtually no insect relief
                   habitat has been lost to development. Access to the coast may be
                   delayed for large mosquito-harassed groups, but these groups                               15.  p.   134   Paragraph S.
                   evt-ntually get to the coast. Therefore_ the relevant issue is                             For the CAN there is projected 5-10 percent population decline or
                   energetic stress resulting from paralleling linear structures and                          distribution change.    These are extremely different levels of
                   increased exposure to mosquitoes.   Recent advances in mitigation                          impact and estimates should be presented for each input Bepar-
                   theory, such as separations of pipelines and heavily traveled                              ately.
                   roads, have only recently been implemented and should further
                   improve the situation.

                   9. P. 110    Paragraph 7.
                   Ilf.-Ui.l hi.rvest of CAM caribou has been increasing in recent
                   years and, in our opinion, there is tremendous potential for
                   negative demographic impacts. Enforcement along the TAPS
                   corridor would be the most effective "mitigation' for this
                   secondary effect at industrial development. I'his experience
                   should weigh heavily in decisions regarding au-cee!3 into an
                   expanded road system into ANWk.

                 RAPTORS (including the threatened Peregrine Falcon)

                                                                                                           Raptore
                 1.   P. 38    Paragraph 3.                                                                Page Two
                 The text states that the 'arctic peregrine lalcon is the only
                 threatened or endangered species known to occur in the 1002
                 area." I would reword this to state that the peregrine is the                             5.    p. 123   Paragraph 9.
                 only threatened species known to occur in the IUU2 area.                                  This paragraph mentions high density raptor nesting habitat used
                 Currently, the arctic peregrine (tundrius) is classified as                               by, among others, peregrine falcons.     I have been in both areas
                 threatened, not endangered.    Its recent reclassification (from                          and do not feel the Saddlerochit area, at least that within the
                 endangered) was due to signs of a population recovery.      Also, 1                       1002 area, qualifies as high density raptor habitat.      Maybe this
                 think it is at least worth noting that the 1002 area occurs                               should be clarified and note that high density habitat. ties south
                 within the range of the endangered Eakimo.curiew.                                         of the 1002 area.

                 2.   p. 38    Paragraph 4.                                                                G.    p. 124   Paragraph 7.
                 1 do not disagree that peregrines arrive at their northern aeries                         Golden eagles are opportunistic and are abundant at other North
                 between April 21 and May 7, nor that egg-laying and incubation                            Slope sites.   If caribou do decline in or shift from the 100'2
                 can occur as early as 15 May.    I do feel, however, that the use                         area, eagles probably will also.     However, I think the use of the
                 of the word cenerally is not appropriate.     I think the reference                       terms *decline moderately" is unwarranted.      "Change distribution*
                 used for these dates (HPR-A Task Force 1978) is not the beat                              is more appropriate and should be the essence of the statement.
                 source of information. A better reference would be USFWS 1982.
                 In that status report the first week of June is given as normal
                 egg-laying for tundrium                                                                   7.   p. 126    Paragraph 4.

                                                                                                           Minor point: the text.states that arctic peregr3nes are absent
                 3.   p. 38    Paragraph 6.                                                                from the 1002 area "through April*. Elsewhere (e.g., p. 126,
                 This section on peregrines ends by noting that several sightings                          paragraph 8) the text mentions 15 April as arrival dates.       I
                 of ppregrines during June and July have been made in the 1002                             would use the former date (end of April, 1 hay).
                 area, and vot the nionificann@ of thta In un@_IaAr_ Two thl-a
                 come to mi@d.   First. as peregrines increase as breeders on Zhe                          Also in this paragraph, the report states that loss of suitable
                 North Slope, non-breeders will also.    Second, peregrine identifi-                       nesting  habitat as a result of facility placement would be minor,
                 cation is problematic, especially when gyrfalcons occur in the                            since facilities would not be permitted within 2 miles of an
                 neighborhood.   Although some observations have been veil docu-                           aerie in potential nesting habitat.     Earlier (p. 124, paragraph
                 mented in the baseline studies,    at least some observations could                       5) recommended restrictions use I mile as a buffer zone.
                 be of gyrfalcons, not peregrines..                                                        Properly developed, at least some facilities have bepn con-
                                                                                                           structed within 2 miles (Pump Station No. 2, TAPS; Elliott
                                                                                                           Highway, Grapefruit Rocks Aerie) of aeries.
                 4.   p. 123    Paragraph S.
                 The report uses two cases to depict how variable the reactions of
                 raptors are to disturbance. I am not sure it the reports' intent
                 was to contrast variability between species or individuals. A,
                 fjeaAt apal Qt variation occurs in both cases. However, the
                 examples described are not clearly related to the phenomenon of
                 disturbance. Specifically, rough-legged'hawks are cyclic in
                 their nesting and although probably more easily sensitized during
                 years of low prey, they often abandon sites during these lows,
                 regardless of disturbance.

                                                                                                        MUSKOXEN
                BIRDS
                1.   p. @5 Paragraph 3.                                                                 1. p. 113 Paragraph 6.
                                                                                                        In describing mitigation for muskoxen, the authors state that
                Snow geese "move westward Lnto.the IOU2 area as tar as the                              "standard atipulations@ will be employed.    However, a question
                Huiahula River."  Maps in the text (p. I.-IB) designate use  areas                      not asked is *what will muBkoxen do when they confront roads and
                on the Canning River Delta and Katakturuk Plateau.                                      elevated pipelines?"   Will they cross like caribou ur will other
                                                                                                        mitigation be required.

                2.   p. 35 Paragraph 3.
                'The average number of (snow) geese using the 1002 area is
                105,000, approximately 15-20 percent of the Banks Leland
                Population.* 'I could not find a reference in the baseline
                studies on how this figure was derived. Since this figure    is
                applied to concluding remarks regarding possible reductions in
                the Banks Island Population (p. 122, paragraph 2), 1 think it
                deserves more of a reference.

                3.   p. 119 Paragraph 9.
                While the general statement that "the responses of birds to human
                disturbance... are highly variable' is true, there is more
                information avaklable on this topic than is cited. Recent
                research, such as 'The Effects of the Lisburne Development
                Project on Geese and Swans* thurphy et mi. 1986), are relevant to
                this topic. This study. cited in the Seabirds and Shorebirds
                section, but not in the Swans, Geese, and Ducks,section., provides
                data on the effects of ciifieid development on nesting densityo
                nesting success, distribution in the oilfieid from June-
                September, and the behavior of geese and swans experiencing
                different types and intensities of human activity. These data,
                combined with findings from the 1986 field season (not available
                at the time the IOU2 Report was finalized), indicate that there
                7ere interepecific, seasonal, and sex-related differences In
                 eactionB to disturbance.

                4.   p. 121 Paragraph 4.
                *Disturbance... could extend up to 3 miles from the source
                (compressor simulator)." The assumption is made that other
                sources (ouch as structures) will displace geese as veil.    Snow
                geese may accommodate to roads and pads and their associated
                tangential or stationary stimuli at much closer distances than
                they would to a noisy compressor station.

                5.   p. 121 Paragraph 6.
                Hampton and Joyce (1985, p. 4-7) concluded that *,snow geese and
                Brant displayed accommodation to oillield development and were
                not significantly disturbed.'

                  ARCOAlaska, Inc.                                                                      U S   ish & Wildlife Service
                      Posl Office Box 100360                                                            F b  ary
                                                                                                         e r..., 2, 1987
                      Anchorage. Alaska 99510-0360                                                      Page 2
                      Telephone 907 276 1215

                                                                                                        During the period of 1980 to 1985, ARCO expenditures for
                  February 2, 1997                                                                      manufactured goods on the North Slope totaled $3.6 billion.
                                                                                                        This expenditure was for the purchases made from companies
                                                                                                        and small businesses throughout the 50 states. Although we
                                                                                                        generally find the resource potential/estimates to be of the
                  U.S. Fish & Wildlife Service                                                          proper magnitude, the only way to evaluate an area's
                  ATTN: Division of Refuge Management                                                   resource potential accurately is to drill wells. Sound
                  2343 Main Interior Building                                                           decisions in the national interest concerning ANWR must be
                  18th and C Streets, N.W.                                                              based on a complete picture of its subsurface resources, as
                  Washington, D.C. 20240                                                                well as its surface values.

                  RE: Draft Arctic National Wildlife Refuge, Alaska                                     Attachment I provides specific comments on the ANWR Coastal
                      Coastal Plain Resource Assessment                                                 Plain Resource Assessment. Do not hesitate to call me at
                                                                                                        (907) 265-6123 if you have any questions.
                  Gentlemen:
                                                                                                        Finally, ARCO supports the written commentary that is being
                  ARCO has reviewed the Draft Arctic National Wildlife Refuge                           submitted separately by the Alaska Oil and Gas Association.
                  (ANWR), Coastal Plain Resource Assessment and has comments
                  to offer for your review and consideration. we welcome this                           Siff rely,
                  opportunity to participate in the further development of
                  this document that, when finalized, will allow the Secretary
                  of Interior to make a recommendation to the Conaress based
                  on the best available scientific and technical information.                              iM. Posey
                                                                                                         anager
                  We support expeditious leasing of the ANWR Coastal Plain for                          Issues Advocacy
                  oil and gas exploration, production, and development. To
                  further this support, we are committed to the exploration of                          JMP/RO535:sm
                  ANWR, provided we gain the access to explore through any
                  congressionally mandated process. To delay leasing in order                           Attachment I - Specific Comments
                  to conduct further studies would not be in the best interest                          Attachment II - List of Exhibits
                  of the Nation or the State of Alaska in our view. Current-
                  ly, there is sufficient data to make a prudent decision
                  regarding leasing.

                  We firmly support the Department of Interior's Section
                  1002(h) recommendation for the leasing, exploration, and, if
                  oil is found, production on the ANWR Coastal Plain. Our
                  experiences at Prudhoe Bay and Kuparuk, where oil is
                  produced in an environmentally sound manner, convinces us
                  that development at ANWR would accrue significant benefits
                  to the Federal, State, and local governments. These bene-
                  fits include reduced dependence on foreign oil imports
                  (enhancing our national security and balance of payments)
                  and more jobs (directly in Alaska on ANWR and elsewhere in
                  the construction of facilities/modules and the manufacturing
                  of pipe and other oil field goods).

                      ARCO A-k1.

                                             ATTACHMENT I

                                                  ARCO

                                   Specific Comments on the Draft
                              ANWR Coastal Plain Resource Assessment

                                                                                                                    Page  77    4th full paragraph      Exploratory Drilling
                   Chapter 2,
                                                                                                                          The statement that"...the     well is Arctic packed and
                   Page  28 - 3rd paragraph      Caribou                                                                  suspended." should recognize that the well only needs
                                                                                                                          to be filled with a non-freezeable material for suspen-
                         "The-core calving area is a location to which pregnant                                           sion. The space between the surface casing and next
                         cows have shown a strong fidelity as traditionally                                               casing string only needs to be sealed with Arctic pack
                         favored calving habitat. Those concentrated calving                                              preceded with cement when the well is completed and the
                         areas used in at least five years during the 14 year                                             pumpable fluids from the reserve pit have been
                         study were identified as the core calving area." Does                                            injected.
                         five out of 14 years reflect a strong fidelity? We
                         think not. A strong fidelity would be utilization of                                       Page  80 - Drilling Pads and wells
                         an area greater than 50% of the time (See Exhibits 3
                         and 17).                                                                                         The pad size of 20-35 acres may be exaggerated. For
                                                                                                                          example, the average Kuparuk pads is in the range of
                   Chapter 3                                                                                              10-11 acres. Pad size will vary according to the
                                                                                                                          number of wells to be drilled, as well as other perti-
                         In general, this chapter downplays the tremendous        value                                   nent field considerations.
                         of potential natural gas reserves. Future need may
                         make development of the national reserves viable.                                          Page  81 - lst paragraph - Drilling Pads and Wells
                         Besides conventional natural gas production, these
                         reserves could be produced as natural gas liquids or                                             The statement that indicates that liquids "...pumped
                         condensate.                                                                                      into a mud disposal well. Solids must be removed..."
                                                                                                                          should be expanded to demonstrate that clearly the mud
                   Chapter 4                                                                                              should be injected into the annular channel between the
                                                                                                                          surface casing and the protective casing. For example,
                   Page  76 - 2nd paragraph - Exploratory Drilling                                                        the mud from the drilling process will be injected
                                                                                                                          between the 13-3/8" and 9-5/8" casings in the previous
                         The statement that "The drilling rig ... usually                                                 development well.
                         requiring 110 to 180 C-130 loads,..." should take into
                         account that a modular wheeled rig could be barged to a                                          Consideration should also be given to onsite disposal
                         beachhead in the summer and moved to the location via                                            of the cuttings in an approved manner. Large drill.
                         ice road. This would accelerate mobilization and                                                 sites with numerous wells will generate sufficient
                         reduce the number of multiyear wells required to                                                 cuttings to make onsite disposal a desirable,
                         evaluate the potential prospects. Secondly, a modular                                            environmentally proper alternative (see Exhibit 16).
                         rig.could drill more than one moderate depth well per
                         year (See Exhibits 14, 15, and 16).                                                              Finally, flare stacks are not generally used at a drill
                                                                                                                          site.
                   Page  77 - lst full paragraph - Exploratory Drilling
                                                                                                                    Page  81 - 5th paragraph - Field Roads and Pipelines
                         The statement that "...the rig is placed on pilings or
                         timbers." should consider that an alternative of a                                               Pipeline sizes vary between 8" and 24". Also, change
                         stable rig footprint is a gravel pad. This is essen-                                             the sentence regarding vertical support members (VSMs)
                         tially beneficial for a multiyear location for a deeper                                          to read "They are commonly placed on elevated Vertical
                         abnormal pressured prospect (See Exhibits 14, 15, and                                            Support Members." This will give us flexibility and
                         16).                                                                                             not tie us to a five foot (5') steel VSM.

                                                                                                                                                        2

                                                                                                                   any reference to it should not be included as part of
                  Page 82   Pipelines                                                                              this document (see Exhibit 2).

                       In general, this discussion on the technical aspects                                  Page  107 - 5th paragraph - Production, Transport!ition, and
                       and concepts of pipeline design and utilization is                                    Development
                       appropriate; however, certain aspects need further
                       clarification. The discussion of the Kuparuk, Prudhoe                                       The sentence "Whitten and Cameron (1985) found consis-
                       Bay and TAPS pipelines are taken in a singular context,                                     tently low numbers" should be rephrased to read
                       when in reality a pipeline that may be designed and                                         "Whitten and Cameron (1985) found consistently low
                       constructed forfuture ANWR development would incorpo-                                       numbers of caribou and generally low percentages of
                       rate the best characteristics of each. There should                                         calves in the Prudhoe Bay oil field from 1976 to 1982.
                       not be any implications that only elevated pipelines                                        One of several explanations offered is possible dis-
                       will be acceptable, orIatlApe in;            utilize a                                      placement by oil field activities. Gavin (1979) also
                                                     u7
                                                       d V_
                       common pipe support or             e  gewstiltlo have the                                   found very low percentages of calves and total caribou
                       pipe!!:? Eijrall I the road. The terrain, as well as                                        in the Prudhoe Bay,oil field area prior to and during
                                     ".Le-L
                       the     d   Je and development criteria, will determine                                     initial oil field development (1970-1979). White,
                       engineering design. In other words, there may not be                                        et.al. (1975) suggests that the high percentage of wet
                       any one best design for the entire project; rather, a                                       and moist areas near Prudhoe Bay makes this area less
                      ,.case =by-Zase evaluation will determine the best design                                    attractive to caribou." (see Exhibit 3).
                       for each segment.
                                                                                                                         2nd paragraph    Production, Transportation, and
                                                                                                             PH       ment
                  Page 84 - Airfields for Constructiontamps                                                  D V:I!:8

                       "Air development' should read "ai-rf--IA development.-                                      Th-e st.--ement ---isplacement of the PCH from a core
        4                                                                                                          calving area to a less desirable"area would be expected
                  Page 99 - last paragraph    Consequences of Exploratory                                          to reduce caribou productivity" confuses the term "less
                  Drilling                                                                                         desirable area" with less important. No proof exists
                                                                                                                   to illustrate that the core calving area is more
                       Your reference to "traces of oils used    during drilling                                   important, productive or valuable; it is only used more
                       to Islicken' up the drill bit;" is not    in keeping with                                   often. The entire ANWR and Canadian coastal      plain is
                       current drilling technology utilized on the North                                           used for calving, and there is no data that shows the
                       Slope. Fresh water-based mud systems are currently                                          entire plain to be more or less important than the core
                       used to drill wells on the North Slope.                                                     areas (see Exhibit 3).
                       jn13@;Jrd full paragraph      Vegetation, Wetlands, and                               Page  108 - 6th paragraph - Production, Transportation, and
                  P:7:a                                                                                      Development
                  T

                       Impoundment concerns can   be mitigated with culverts                                       We consider this paragraph to be an exaggeration.      it
                       (see Exhibit 4 and 17).                                                                     should be reworded to reflect that "the FWS.was examin-
                                                                                                                   ing a hypothetical oil field development, that was
                 ...Page 103 - 4th paragraph- Vegetation, Wetlands, and Terrain                                    three times the size of Prudhoe Bay and situated
                  Types                                                                                            entirely within the calving areas."

                      .'Impoundment concerns can  be mitigated  with  culverts                               Page  108 -7th paragraph    Production, Transportation, and
                       (see Exhibit 4 and 17)..                                                              Development

                  Page 103   5th paragraph  - Vegetation,  Wetlands,  and Terrain                                  The statement "Based on the work of Dau and Cameron
                  Types                                                                                            (1985), caribou are displaced approximately two miles
                                                                                                                   out from development" misrepresents the information
                       The Meehan (1986) Report is a   draft  report that con-,                                    actually found in their report. The information from
                       tains a significant number of   ;irrors; this report and

                                                   3                                                                                           4

                       the Dau and Cameron report for the 1982-85 period is as
                       follows:                                                                              Page  121   last paragraph     Conclusion
                                    Within 1000M of the Road                                                       A decline in waterfowl populations has not been docu-
                                                                                                                   mented in the Lisburne operational area. This fact is
                                              Total              Total                                             counter to the supposition made that a decline in
                                              Caribou            Calves                                            waterfowl could occur as a result of development.
                             May                1,568               417                                      Page  130 - 4th full paragraph - State and Local Political
                             June               2,965               546                                      and Economic Systems
                             July             20,132             3,986
                                                                                                                   The statement that"...permanent jobs would be filled by
                                     Within 100M of  the Road                                                      commuters ... with residences outside Alaska." is abso-
                                                                                                                   lutely erroneous. Essentially all ARCO personnel live
                                              Total              Total                                             in the greater Anchorage area.
                                              Caribou            Calves
                                                                                                             Page  143 - Table VI - 8 - Irreversible and Irretrievable
                             May                   78                25                                      Commitments of Resources
                             June                 208                33
                             July               3,422               757                                            The chart indicates under "Artifacts at Development
                                                                                                                   Sites" that all would be lost in the full and partial
                       Based on this data, it is incorrect to assume a                                             leasing alteFn-atives. Current law requires that an
                       two-mile impact/avoidance zone near roads in a calving                                      archaeological survey of an area must be performed
      do               area. An important shortcoming was its failure to                                           prior to exploration.   Important archaeological sites
                       account for the effect of lakes and ponds on the                                            are avoided, studied or removed to prevent damage to
                       available calving habitat adjacent to the Milne Point                                       archaeological resources. A more accurate statement
                       Road.                                                                                       would be that present survey mandates should preclude
                 Page  108-109   Production, Transportation, and Development                                       any significant loss of artifacts.
                                                                                                             Page  145-148 - Summary of Recommended Mitigation for the
                       In general, clarification is needed with regard to                                    1002  Area
                       references by S. Murphy and/or J. Curatlo on ramp and
                       crossing studies. As presented, this information is                                         We recognize the need for meaningful mitigating mea-
                       confusing (see Exhibit 6).                                                                  sures, and many of those listed are presently utilized
                                                                                                                   in the North Slope oil fields. During the last ten
                 Page  120 - Ist paragraph - Swans, Geese, and Ducks                                               years we have found that some of the mitigation mea-
                                                                                                                   sures that were put in place, without a firm technical
                       One study that should be referenced is the Murphy,                                          or scientific basis, at the onset were unnecessary,
                       et.al. 1986 "Lisburne Terrestrial Monitoring Program                                        ineffective or in some cases proved to be detrimental
                       (1985). The effects of the Lisburne Development                                             to the environment (i.e., more tundra was covered by
                       Project on Geese and Swans." The results of this study                                      gravel for caribou crossings, roads, and pipeline
                       indicated that there was little effect on the nesting                                       routes that were unnecessary). We recommend a more
                       and area use by geese, swans and ducks in the Lisburne                                      general/flexible case-by-case option to mitigate the
                       development area.                                                                           concerns of the present, using past experience as the
                                                                                                                   guideline for mitigation, which would allow for future
                 Page 120 - 2nd paragraph - Swans, Geese, and Ducks                                                innovative methods that may be developed (see Exhibit
                                                                                                                   17).
                       Your reference to "some poaching could also occur." is
                       contrary to oil field practices. The prohibition on
                       firearms in the oil fields is strictly enforced.

                                                    5                                                                                         6

                                           ATTACHMENT II
                                                                                                                Exhibit 10:   Breakup 1984, Sagavanirktok and Putuligayuk
                                           EXHIBIT LIST                                                                       Rivers, Prudhoe Bay, Alaska

                                                                                                                Exhibit 11:   Pile Driving and Load Tests    in Permafrost for
                                                                                                                              the Kuparuk Pipeline System,    Victor Manikian,
                  The following exhibits have been submitted to the U.S. Fish                                                 1983.
                  and Wildlife Service as supplementary information to our
                  ANWR Draft Legislative Environmental Impact Statement                                         Exhibit 12:   Design Evaluations in Support of Offshore
                  Commentary:                                                                                                 Facilities and Gravel Islands in the Arctic.
                  Exhibit 1:    Critique of draft,USFW report "The Effects of                                   Exhibit 13:   Offshore Seawater Treating Plant, Waterflood
                                Prudhoe Bay Reserve Pit Fluids on the Water                                                   Project, Prudhoe Bay.Oil Field, December 1984.
                                Quality and Macroinvertebrates of Tundra
                                Ponds." Correspondence from ARCO to USFW, July                                  Exhibit 14:   Prudhoe Bay Unit, Lisburne Development_
                                22, August 24, 1985 and USFW reply on August 6,                                               Geotechnical Investigations, Winter, 1983,
                                1985.                                                                                         Vol. 1, Engineering, Harding Lawson Associates,
                                                                                                                              June 1983.
                  Exhibit 2:    Critique  of R. Meehan's "North Slope Guidance
                                Manual." Letter to Robert Jacobsen, Assistant.                                  Exhibit   15: Prudhoe gay Unit, Lisburne Development,
                                Regional  Director, USFW from T.R. Fink, Manager                                              Geotechnical Investigations, Winter,      1983,
                                of Environmental Conservation, ARCO Alaska,                                                   Vol. 2, Field Data and Laboratory Testing,
       V_                       October 9, 1986.                                                                              Harding Lawson Associates, June 1983.
                  Exhibit 3:    Coastal Oil Development and its Effects on                                      Exhibit   16: Prudhoe Bay Unit, Lisburne Development,
                                Caribou Migration and Population Patterns in                                                  Geotechnical Investigations, winter, 1984,
                                the Prudhoe Bay region of Alaska's North Slope,                                               Vol. 3, Engineering Field Data and Laboratory
                                1969-1979, by Angus Gavin and D.W. Chamberlain,                                               Testing, Harding La@.on Associates, August
                                September 1980.                                                                               1984.
                  Exhibit 4:    Prudhoe Bay Unit, Lisburne Development, Drain-                                  Exhibit   17z Petroleum Development in Arctic Tundra
                                age and Erosion Control, Design and Criteria                                                  Wetlands, Gary F. Smith, Scott B. Robertson,
                                Manual, May 1985.                                                                             Delivered National Wetland Symposium, New
                                                                                                                              Orleans, October 8-10, 1986.
                  Exhibit 5:    Prudhoe Bay Unit,   Lisburne Development,
                                Large-Scale model   Study of Arctic Slope Pro-
                                tection, Tekmarine, Inc., Sierra Madre,.
                                California, June 1984.

                  Exhibit 6:    Department of the Army, 45th Meeting of the
                                coastal Engineering Research Board, Fairbanks,
                                'Alaska, May 14, 1986.

                  Exhibit   7:  -Lisburne Development,  1985 Su mmer Hydrology.

                  Exhibit   8:  Lisburne Development,   1984 Summer Hydrology.

                  Exhibit  9:   Lisburne Development,   1983 Summer Hydrology.

                                                                                                                                                 2

                                 THE ARCTIC ADVENTURERS
                                     P.O. BOX 91107
                             ANCHORAGE, ALASKA 99509-1107

                                                            January 15, 1987

        U.S. Fish and Wildlife Sot-vice; Division of Refuge Management
        2343 Main interior Building
        18th and C Streetsq Northwest
        Washington, D.C. 265140

        Res Comments an Draft 1002,Report

        Mr. Horns

        We are writing to comment an the draft report submitted by   the U.S.
        Fish and Wildlife Service which concernis the Coastal Basin  of the
        Arctic National Wildlife Refuge. We are in support of alternative E
        which would designate this area as wilderness. We have taken this
        stand primarily an the grounds that we feel the reserve of recoverable
        oil in this region does not justify the risk that would be incurred by
        developing this area. We do not feel the Coastal Basin should be
        permanently closed to development, but that development should be done
        at a time when our technology has further developed providing adequate
        protection for the wildlife and flora.
      Is,
        We have concerns with the proposed way hazardous waste would be
        disposed of which could greatly endanger the fragile &go system    of
        this area. The porcupine caribou herd aloo possm management problems
        which the proposed development of this area does not address. Using
        the Central Alaskan herd as a prototype is not feasible. Along with
        these concerns is the insufficient scope that the draft focused on
        which, in our beliefv does not identify the full impact that
        development would have on the Arctic regions i.e. Canadian concerns    as
        ,@#ell as impact an native subsistence.

        We feel this area of our country and world in of major national
        importance to every American and therefore should be preserved     in its
        natural state. After being to this area ourselves we have seen     the
        grandeur that the coastal basin offers and the wildlife that it
        supports. For the sake of future generations as well as the present
        ones we would strongly recommend that this area be designated as
        wilderness thus protecting its beauty and greatness. He are not
        advocates of "hard line" conservation, for we are all professional men
        that only desire the chance for our children and grandchildren to
        enjoy the beauty of nature, if for no other reason than "Because itlis
        there". Please feel free to contact us for further comment.

        Sincerely Yourel

                               --The Arctic Adventurers---
        GIg !!yMed (Spokesman)        Tim Forsythe         Greg Scott
        Larry Brown                  Steve Spalding        Scott Luse
        John Landry                  Larry Longhurst       Steve Jackson
        Fred Whipple                 Pete Norseth          Pete Faber

    		DO YOU WANT TO MAKE PUBLIC COMMENTS?

    If you would like to speak at the hearing today, please fill in the blanks
    below and turn it in to one of the Fish and Wildlife Staff members present.
    You need not complete this sheet to sumbit written comments.  Thank you.

    Please print

    Name	John Miller
    Mailing Address	550 W. 7th Suite 1840, Anchorage, AK 99501
    			BP Alaska Exploration Inc.

    Check appropriate boc below:

    	I am here to offer my own views.
    			-or-
    	I am speaking for BP Alaska Exploration Inc.
    				(please enter name of organization you represent)

    						TESTIMONY OF THE

    				DRAFT LEGISLATIVE ENVIRONMENTAL IMPACT STATEMENT

    				"ARCTIC NATIONAL WILDLIFE REFUGE, ALASKA

    					COASTAL PLAIN RESOURCE ASSESSMENT"

    						Anchorage, Alaska

    	I am John Miller, area manager for BP Alaska Exploration Inc.  We

    welcome the opportunity to offer testimony on the U.S. Department of Interior

    1002 (h) reprot.

    	BP Alaska strongly support the U.S. Department of Interior's recommendation

    that the entire 1002 coastal plain area be authorized for oil and gas leasing,

    exploration and production.  The national interest is best served by congressional

    authorization of the Department of Interior's recommendation.  Only then can

    a factual assessment of the petroleum reserves be made by exploratory drilling

    of this highly prosepctive area.  However, this cannot be done at any cost.

    Stipulations that increase coasts without compensating benefits should, at most,

    be selectively applied.  For example, the prohibition of all explroatory activity

    from May 1 to November 1 is not justified by past north slope upland exploratory

    experience.  conversely, it could require shud down and re-start of operations

    to finish the well in a second year, thereby expanding threasts to well safety

    and the environment, and increasing costs.  Another example is the stipulation

    that wells not exceeding 10,000 feet in depth be drilled form ice pads.  This

    decision should be site specific based on available pad materials, timing, terrain

    and other current and lcoal conditions.

    	BP Alaska support leasing under reasonable environmental stipulations.

    We agree with the DEIS comments that explrotion and development  experience at

    Prudhoe Bay indicates minimal impact on wildlife  resources and hence it is

           Page 2
                                                                                                                    Page 3
           reasonable to assume coastal plain development can also proceed with similar
           minimai.effects; and that most adverse effects would be minimized or eliminated                          from abouL 3,000 animals in 1975 to its current day size.of over 13,000 animals.
                                                                                                                    This experience Indicates that development in the ANWR coastal plain should not
           through carefully applied mitigation, using experience and technology acquired
                                                                                                                    have a negative effect on the calving success of the Porcupine Caribou Herd    or
           from Prudhoe Bay development and construction or the trans-Alaska   pipeline.
                                                                                                                    its population.
           Actually,. the Prudhoe Bay and TAPS experience and technology has   been further
                                                                                                                         Opening the ANWR coastal plain to leasing is crucial to our national interest.
           enhanced through subsequent developments of Kuparuk, Milne Point,   Lisburne and
           Endicott fields along with many attendant  Ienvironmental studies.  But exploration                      The U.S. produces 8.5 million  BOPD and imports 6 million BOPD or 41% of pof con-
                                                                                                                    sumption. Alaska provices 20% or domestic oil production. Domestic production
           and devetopment of these arctic north slope fields has been very   costly. So,
           leasing, exploration and development of commercial prospects can   occur under                           is forecast to decline to 4 million BOPD by the year 2000 and imports are estimated
                                                                                                                    at 12 million BOPD or 75% of our consumption. Alaska north siope production
           currently projected economic conditions in this high cost region   in an environmentally
           responsible manner;.but only if cosU are controlled by imposing    onli prudent                          will also decline from 1.9 million BOPO in 1987 to an estimated 0.7 million BOPD
           stipulations that are fully justified and  .carefully crafted.                                           in the year 2000. Our dependence on foreign imports is likel@ to double by the
                A great deal of emphasis has been placed on the possible detr  .imental effects                     year 2000 under current conditions. The down side of this is that foreign supplies
                                                                                                                    to rill the gap aren't guaranteed. National fuel crises occurred in 1973 and
           that discovery and development of a commercial oil field In the coastal plain
        L                                                                                                           1979 due to events in the Middle East beyond our control. The question is not
           will have on the Porcupine Caribou Herd's calving ground and habitat. This is
           a legitimate concern. BP Alaska agree with the DEIS conclusion that the total                            whether or not we want another crippling fuel crisis. Of course we.don't. The
                                                                                                                    question is how to avoid It. Obviously, developing reliable domestic petroleum
           available habitat has never been fully occupied, that it is not currently limiting
           the growth ofthe herd and that loss of habitat represented by likely 1002    area                        producing capacity expeditiously is imperative. Looking in the most promising
                                                                                                                    place to find ierqe casexuas is the first logical step. Few will argue that
           oil development will not impact caribou growth or productivity. Also, a major
           oil development would not do irrepairable damage to Porcupine Caribou calving                            the ANWR                                              al. Due to long lead times
                                                                                                                    to develop -Frantier Alaska a4+-fields,                                        t
           grounds. The ANWR coastal plain Is but a portion of the calving grounds of the
           Porcupine Caribou Herd. A discovery of world ranking size woul     d only involve                      -p&aducLi=,a coastal plain discovery today would not likely sta     rt production
           a small portion of the coastal plain. The herd's calving range extends into                              before the year 2000.
           the Brooks Range foothills to the south of the ANWR coastal plain andleastward                                In conclusion, SP Alaska support Alternate A; full leasing.of the 1002 area
                                                                                                                    coastal plain under reasonable environmental stipulations. We believe that
           into Canada to the MacKenzie Bay area. Experience with the Central Arctic Herd
           shows that development at Prudhoe Bay, Kuparuk and Milne Point I   In the calving                        industry has the proven technology and experience to explore for and develop
                                                                              I                                     commercial deposits in an environmentally responsible manner, an4 that this endeavor
           range@ of that herd has not had a negative effect an the herd. The herd has grown
                                                                                                                    is vital to our national interest.

            Page 4
                 Thank you for t.hfs opportunity to present testimony on the draft 1002 (h)

            report.

    						STATEMENT FOR PUBLIC HEARING

    						ARCTIC NATIONAL WILDLIFE REFUGE

    						U.S. FISH AND WILDLIFE SERVICE

    					DRAFT REPORT AND RECOMMENDATION TO CONGRESS

    My name is Sally DiDomenico and I am speaking on behalf of BP Alaska
    Exploration Inc.  BPAE strongly supports the opening of the Coastal
    Plain for oil exploration and development.

    BP Alaska Exploration is taking a position on this issue based on its
    long-standing interest in Alaska.  BPAE or its parent company, British
    Petroleum, has been actively involved in exploration activities on the
    North Slope since the early 1960's.  BP was the original lease holder of
    a considerable portion of the Prudhoe Bay Field.  BPAE owns a 29%
    interest in the Kuparuk River Oil Field, currently producing 260,000
    barrels of oil per day we also hold a number of other onshore and
    offshore oil and gas leases in Alaska.  BPAE is proud of our involvement
    in the exploration of thee North Slope and proud of our record of
    operating in an environmentally safe manner.

    BP Alaska Exploration has been, is, and always will be aware of and
    concerned for the environmental resources of this State.  We believe the
    environmental resources must be protected.   We also believe that it is
    imperative that the United States assess its remaining, untapped sources
    of oil and gas.  At present this country imports about a third of its
    daily oil requirements.  We cannot afford to increase our reliance on
    imported oil.  We also cannot afford to assume that a particular
    domestic area has potential and that it can be explored whenever
    national oil supply conditions make such exploration necessary.  The
    Mukluk well in the Beaufort Sea is a prime and costly example of how
    disappoint a "promising' area can be.  The only means by which the
    productivity of an area can be know is through drilling.'  BPAE believes

    that promising areas such as the Coastal Plain should be explored, and
    we believe that at the same time the environmental resources in the area
    can be protected.  It is possible to do both.  The oil industry has
    proved it at Prudhoe Bay.  BPAE has proved it at the Kuparuk Field.

    BPAE supports the U.S. Fish and Wildlife Service in its Draft 1002
    Report recommendation that the Coastal Plain be opened for exploration
    and development.  However, we have some concerns regarding the general
    tone of the report.  While we appreciate the difficulties involved in
    the thorough study which was required for this area, we believe there
    are many instances within the Report in which an environmental issue has
    been treated in a less than factual manner.  This Report will be the
    basis for intensive study by the concerned public and by the Congress of
    the United States.  It is imperative that the environmental issues be
    given a balanced and careful assessment.  All aspects of the issue
    should be presented so that concerened parties can consider the
    importance of the resources and are also informed of the demonstrated
    successful protective measures which can be taken to conserve these
    resources.

    I will cite a few specific examples of concern:

    On Page 6, the report states, "Oil and gas development will result in
    widespread, long-term changes in wildlife habitats, wilderness
    environment and native community activities.  Changes could include
    displacement and reduction in the size of the Porcupine caribou herd".
    These two statements are made in spite of the fact that the very next
    statement is "The amount of reductiont and its long-term significance for
    herd viability is highly speculative."  We believe that it is factual
    and fair to state that the effect of oil development on caribou herd is
    highly speculative.  There is no evidence of the detrimental effect
    which exploration and production has had on caribou.  However, we do
    have proven experience that 18 years of oil industry operation at
    Prudhoe Bay and Kuparuk River have had only minimal impact on the
    Wildlife resources - and no detrimental effect on the caribou herd.

    						-2-

                                                                                                                              There are, howevor, two mitigat!nq measures       11tems 25 and 26     which
                     Ti-,erefore, our track record shows that oil operations and caribou are                                  we consider both unwise and unwarranted.       Time and area closures in
                     compatible. We urge. that a more balanced discussion of the effect of                                    order to protect wildlife resources should not be a pre-establighed
                     oil operations on caribou be incorporated Into this Report.
                                                                                                                              stipulation.   Such decisions should be made as the need arises and
                     Another example of our concern with the Draft Report is#                                                 Should be based on a consideration of all aspects of the situation. A
                                                                                                                              temporary closure to protect the wildlife In the area is acceptable.
                                                                                                                              However, if such a closure would result In a detrimental effect to a
                     On page 80 under the tcpl(, of Production infrastructure  is the statement                               critical operating procedure or could affect the safety of industry
                     *The drilling pad .... covers 20-33 acres....requires       160,000-285,000                              personnel, then a compromise solution must be found by the governmental
                     cubic yards of gavel." In BP's experience these           figures are not                                agenciese
                     representative of drilling pads currently used in the Arctic area.

                                                                                                                              Th ere are other, similar areas of concern to us regarding the mianner in
                     At ID.Varuk, using the latest technology,  a well pad comprising 24   wells                              which the issues are discussed. We are su@mitti.V comments which will
                     and a reserve pit is located on an 11.5   'acre site. Only 46,000     cubic                              cover these concerns in detail.
                     yards of ;ravel were- reqjired to construct the pad. These molls are on
                     a 25 foot spacing allotmenti but even with a reduction in well spacing,                                  In.summari. 8? Alaska Exploration is concerned about the protection of
                     which would result in a drill pad for 40          50 wells (the suggested                                the environmental resources. kL- do believe industry has proved that we
                     development scenario in the report) only slightly larger pods than those                                 Can Operate on the North  . Slope in an environmental safe manner.        we
                     in use at Kuparuk would be necessary. Improved industry technology not                                                                                                    AP Maska
                     only benefits industry@ it also benefits the environment in which                                        believe exploration of AMR Is in the national interest.
        U1                                                                                                                    Exploration supports the opening of the Coastal Plain for oil
                     industry operates.    It is imiportant that such beneficial aspects be
                                                                                                                              exploration and development.@
                     presented in the Report.

                     one last example, and again, this is a concern regarding important
                     information which  is not presented to the public. Pages 145 - 147 list
                     a surmary of 32 recommended mitigating measures for the protection of
                     environmental resources. The Report does riot state that out of the 32
                     measures recommended, at least half of those measures are either
                     standard, established industry practice, or they represent action which
                     any reasonable North Slope operator would take as a mAtter of course.
                     many of the other items refer to environmental monitoring.         Industry
                     presently conducts similar monitoring programs for other North Slope
                     projects.  In the interest of presenting factual information, it should
                     have been clearly stated that many of the recommended mitigating
                     measures for the Coastal Plain are already being carried out by industry
                     elsewhere in the Arctic.

                                                                                                                                                           4
                                                  3

                                                                                                                                                              2 -

                                       STATEMENr OF FREDERICK DORET
                                  R12VESENrIAG BP ALAM EXPIOLAMCN INC-                                                    First Development an the North Slope has been of enormous benefit to
                                               FAMARDMG THE                                                               the people of the United States and the free world. we all know that
                                  DRAr 00ASTAL PLAIN REMME ASSESSHM                                                       oil production there is about 1/5 of the entire American supply. The
                                                  or THE                                                                  tax revenue and jobs provided are critical to the native population on
                                  ARCTIC NATICHAL WILDEME REFOOR, ALASMR                                                  the North Slope and the entire State of Alaska. The billions of dollars
                                              January 9, 1987                                                             of development work have also supported thousands of jobs in the U)Wer
                                                                                                                          48. Many other American jobs have been su tained by transportation and
                                                                                                                          refining of the oil produced in Alaska. Thew benefits would never have
                                                                                                                          existed if we had listened to the voices that said "Don't build the
                I am Frederick Dorey, General Counsel of BP Alaska Exploration Inc.                                       Trans Alaska Pipeline" or "Don't allow any change in the environment of
                BFAE is the wholly-owned subsidiary of the British Petroleum Company                                      the North Slope*. if we are lucky enough to find a large reservoir of
                which carries out oil and gas exploration and production in the United                                    oil In the ANNR Coastal Plain the same tangible benefits will develop.
                States. I am pleased to represent BPAE today to support the conclusion                                    If there is oil there but we can't discover or develop it - these
                of the draft 1002 report that the Coastal Plain of the Arctic National                                    tangible benefits - of jobs, taxes and economic improvement - will be
                Wildlife Refuge be opened for oil leasing, exploration and development.                                   lost to the country. We will Import more oil and export more dollars.

                BPAE is taking a position on -this issue based on a long history of                                       Secondly There have always been gloom-and-doom predictions regarding
                involvement on the North Slope of Alaska. Affiliated companies of BPAE                                    the environmental and wildlife effects of North Slope oil development
                began work in Alaska 27 yews ago, and were the original lease holders                                     and pipeline construction. But in 25 years of development, with
                of a major portion of the Prudhoe Bay Field. BPAE affiliates began the                                    appropriate regulation,     the dire predictions have been wrong
                development of Prudhoe Say and still own a portion of Trans Alaska                                        time-after-tims.   The caribou herds were not decimated by the TAPS
                pipeline. BPAE Is now the second largest owner of the Kuparuk River                                       Pipeline.   The caribou herd whose habitat Includes Prudhoe Bay has
                Unit. That field produces almost 300,000 barrels of oil per day from                                      tripled in size since development began there years ago.        The draft
                the am adjacent to Prudhoe Bay. SPAE is proud of its record, and the                                      recommendation is correct when it says, "Even though the billions of
                record of the rest of the industry, for clean and environmentally                                         barrels of oil reserves have been brought on line and the infrastructure
                sensitive development on the North Slope.                                                                 developed to bring that oil -to U.S. markets, the fish and wildlife
                                                                                                                          resources of the Prudhoe Bay area remain extremely healthy.* It is now
                During the years of our involvement in Alaska we have also participated                                   clear that oil and caribou can coexist in Alaska.
                in the debate about the benefits and problems of development on the
                North Slope. Several of the lessons we have learned from that debate                                      Thirdly It is surprising to learn that many of the people who object to
                over the past 25 years would be of value to the Secretary when he                                         development have little understanding of the enormous geographic extent
                considers his final recommendation to Congress regarding development on                                   of the North Slope and the high environmental standards of the oil
                the ANWR Coastal Plain.                                                                                   companies working there. The most common reaction of first-time
                                                                                                                          visitors to the area is astonishment at how vast and desolate the North
                                                                                                                          Slope is and how little Impact the oil operations actually make an the
                                                                                                                          environment or the landscape. " people seem to have an image of oil

                                                                                                                                                                  4 -
                                                       3 -

                                                                                                                              roads and over 30 percent less for other roads. Thus, more accurate
                   drilling and development that is derived from   1930's movies about Texas                                  facts would show that development In ANWR will use less land and
                   wildcatters. Yost visitors are surprised at     how clean, well organized                                  displace substantially less gravel than predicted in the report.
                   and compact the North Slope facilities are and haw much care Is given to
                   minimizing  effects on the tundra, water, and environment.                                                 Additionally. the authors of the report seem to ignore the fact that
                                                                                                                              development of a large. oil field is a phased project.. Prudhoe, Kuparuk
                   if we look  at just the 1002 area we find It is larger than the   State of
                                                                                                                              or a major ANWR field, could take 10-20 years to reach its maximLxn size.
                   Delaware.   The need to maintain this perspective will be Important when                                   Consequently, the introduction of isolated drilling activities on the
                   evaluating  statements about the 1002 report. For example, many of the                                     wildlife habitat is a gradual process.           It is not a sudden, or
                   possible problems listed in the Environmental Consequences section of                                      single-season event.
                   the report are insignificant, or very unlikely, or would occur only in
                   isolated locations of a few acres in the 1002 area - an area that is                                       This allows wildlife populations to adapt gradually to the limited
                   one and a half million acres, within a wildlife refuge that to 19                                          changes in their habitat. 7his Is an Important point because much of
                   million acres.                                                                                             the Environmental Consequences section of the report          assumes that
                                                                                                                              changes in the extent or characteristics of habitat will have
                   The 1002 report has already become the object.of public interest. When                                     detrimental effect on key AMM %miss.           7here is ample scientific
                   it is submitted to Congress the scrutiny will be intense. We firmly                                        evidence that most species can adapt well to a change in the geographic
                   believe that an objective analysis of the environmental and wildlife                                       extent of their habitat or a     limited low-density intrusion into that
        -4         issues and all the relevant facts will support leasing, exploration and                                    habitat. Experience at Prudhoe   am Kuparuk has proved that the orderly
                   development on the Coastal Plain.      To that end we have a number, of                                    development of oil field operations has had little detrimental effect an
                   specific comments about items in the report which we'will submit to the                                    wildlife.
                   Department of Interior in writing by January 20th.
                                                                                                                              in conclusion let an reiterate that SPAE supports the Secretary's
                   However, let me, at this po int, give just a couple specific examples of                                   recommendation to lease the 1002 area for exploration and development.
                   inaccurate facts in the report that could lead to inaccurate                                               The logic of the draft recommendation is inescapable.        If the Coa tal
                   conclusions-                                                                                               Plain is opened there is the possibility of enormous national benefits -
                                                                                                                              thousands of jobs, added tax base, and additional oil supply. If it is
                   on Page 8.0 under "Production Infrastructure' the report states the                                        not opened there is no chance for these benefits.         About 18 million
                   drilling pads will cover 20-35 acres and require 160,000-285,000 cubic                                     acres of the Arctic National Wildlife Refuge would remain untouched. On
                   yards of gravel. BP's experience in the Kuparuk field shows that these                                     the Coast al Plain oil development and wildlife protection are not
                   figures are excessive and not representative of current or future                                          mutually inconsistent. Leasing and development should be recommended to
                   development in the Arctic area. Currently pads are built on only 11 1/2                                    Congress.
                   acres and use only about 1/5 the gravel cited in the report.            With
                   reduced well spacing, 40-50 wells could be put on a pad this size.                                         As I indicted,    we will be submitting additional detailed written
                                                                                                                              comments for the  record.
                   Similarly, on Page 81, the report describes gravel roads with a width of
                   35 feet. The Kuparuk Unit standard width is 10 percent less for main                                       lbank you.

               BP Alaska Exploration Inc.         100 Pine Street San Frandwo. CaNornia 94M s Telephone (415) 951-4325t6                                        2

                                                                                                                         The final report prepared by your agency will be the basis of discussion
                                                                                                                         by the Congress and by the general public. The opening of the coastal
                                                                                                                         plain is a controversial issue. it is imperative that all aspects be set
      CHMS S. GIBSON-SMITH                                         February 6, 1987                                      forth in a balanced mariner. We are concerned that some statements in the
      P-@                                                                                                                Report do not reflect an appropriate balance of the interests involved.

               U.S. Fish and Wildlife Service                                                                            Regarding the oil and gas potential as set forth In Chapter 111, we
               Division of Reftqe Managemiant                                                                            appreciate the difficulties involved in presenting this material in a
               2343 Main interior Bldg.                                                                                  layman's language.     kb suggest it might be helpful to illustrate the
               l8th and C Sts. N.W.                                                                                      prospectivity of the coastal plain by comparing it with a known field,
               Washington, D.C. 20240                                                                                    such as Prudhoe Bay. i.e. - state that the coastal plain has the potential
                                                                                                                         for another giant oil field comparable to Prudhoe Bay, and that 20% of
                                                                                                                         this country's oil production comes from the Prudhoe Bay Field.
               Re: Comments on Draft   Report - Arctic National Wildlife Refuge, Alaska,
                   Coastal Plain Resource Assessment                                                                     In light of the current oil import situation, we believe it is important
                                                                                                                         to emphasize the potential of this area.
               Gentlemen:
                                                                                                                         in addition there is a need for a clear perspective regarding the vastness
               RP Alaska Exploration Inc. appreciates this opportunity to submit comments                                of the area involved. The 1002 area is larger than the State of Delaware.
               on the Draft Report and Recommendation regarding the Coastal Plain of the                                 This perspective must be maintained throughout the Report.
               Arctic National Wildlife Refuge in Alaska.
                                                                                                                         Furthermore, the  Report seems to ignore the fact that the development of a
               Affiliated corTipanies of BFAE have been active on the North Slope of Alaska                              large oil field  is a phased project. Under the climatic restrictions of
               for almost 30 years, and were the original lease holders of a major                                       the North Slope, the development must be even more gradual since major
      CID      portion of the Prudhoe Bay Field. At present BPAE owns a 29% interest in                                  components must   be sea-lifted in during the open water seasons.          The
               the Kuparuk River Oil Field and holds a number of other onshore and                                       development of a North Slope project is not a sudden event. ibis slaw,
               offshore leases in Northern Alaska.                                                                       gradual pace allows wildlife populations to adapt to the limited changes
                                                                                                                         which may occur in their habitat. it is our understanding that scientific
               with this perspective we have read    the Draft Report on the coastal plain                               evidence shows that wildlife species can adapt well to gradual changes in
               with great interest. We command your Agency for the intensive studies and                                 their habitat.
               the detailed analyses which were carried out in the preparation of this
               important document.                                                                                       More detailed concerns are as follow:

               SPAE fully supports the recommendation of the Fish and Wildlife Service                                   Page 6
               that the entire 1002 area be made available for oil and gas leasing.
                                                                                                                         The Report states, "The Department did not include gas in its recoverable
               There is justifiable concern regarding the increased dependence on                                        calculations as it was determined that the gas resources were unlikely to
               imported, foreign oil, and the decreased domestic oil exploration and                                     be economic at any point in the  30-year period considered in the Report."
               production. It is imperative that the United States find and develop the
               hydrocarbon potential which exists in this country.                                                       We disagree with this blanket assumption.        Given the estimated large
                                                                                                                         quantities of gas in the area, the continued pressure for construction of
               The coastal plain is a highly prospective area for    hydrocarbons. it also                               an Alaskan gas line, and the     technological potential over the next 25
               .contains significant environmental resources.        kb believe that the                                 years, the economic viability    of gas resources should at the least be
               industry has proven that we can explore and operate In an environmentally                                 listed as an uncertain factor.
               safe manner on the North Slope.

               it was in this spirit of concern for the environment and faith in the
               excellent environmental record of industry that we participated in tw) of
               the public hearings held by the Department of Interior.        we now submit
               these detailed comments on the Draft Report, for your consideration.

                                                        3 -                                                                                                        4

                 Also on Page 6                                                                                             Page 81
                 The Report states, "Oil and gas development will result in widespread,                                     Marine Facility  '     "construction of a marine fac       ility to service
                 long-term changes in wildlife habitats, wilderness environment and native                                  Te-velopment... @A:x Id be necessary because long hauls... from Prudhoe     Bay
                 community activities. Changes could include displacement and reduction in                                  are impractical."    This is confusing.    A marine facility is
                                                                                                                                                                                             required   for
                 the size of the Porcupine caribou herd".                                                                   major equipment sealifts in sumer open water seasons.             Tra,nsport of
                                                                                                                            services year-round including drillsite facilities (truckable) would be
                 These two statements are not compatible with the very next statement that                                  via Prudhoe Bay.
                 "lbe amount of reduction and its  long-term significance for herd viability
                 is highly speculative."    W believe that it is factual and fair to state                                  Page 83
                 that the effect of oil development on the caribou herd is highly
                 speculative.    There is no evidence of a detrimental effect which                                         "Access to valves, which require frequent maintenance..."         ibis is not
                 exploration and production has had on caribou. However, we do have proven                                  the case, although on the rare occasion when a valve. is automatically
                 experience that 18 years of oil industry operation at Prudhoe Bay and                                      closed it may need to be reopened manually.
                 Kuparuk River have had only minimal impact on the wildlife resources -
                 and no detrimental effect on the caribou herd.                                                             "A pump station is required    every 50-100 miles... 2 or 3 pump stations
                                                                                                                            probably would be required.... 1he first would be located near the oil
                 Industry's record shows that oil operations and caribou are compatible.                                    field." - This is incorrect.      For 150 miles of pipeline no intermediate
                 W urge that a more balanced discussion of the effect of oil operations on                                  pump station is necessary.      The first and only pump sCation would be
                 caribou be incorporated into this Report.                                                                  located at the oil field., A pipeline of this length would certainly not
                                                                                                                            be desidn;d with 2 or 3 pump, stations; it would most likely have one
                 Page 80                                                                                                    station and a diameter sufficient for the anticipated maximum flow. An
                                                                                                                            intermediate pump station could then be added if unexpectedly high
                 "Tae drilling
                                pad... covers 20-35 acres... requires 160,000-285,000 cubic                                 throughput were to be required.
       W         yards of gravel." In BP's experience these figures are not representative
                 of drilling pads currently used in the Arctic area.                                                        Communications - "Maintenance continuous control of the pipeline... would
                                                                                                                            require a complex communication system". - ibis language is misleading,
                 At Kuparuk, using the latest technology, a well pad comprising 24 wells                                    the communi-Fa-tion control system is standard technology.
                 and a reserve pit is located on 11.5 acres. only 46,000 cubic yards of
                 gravel were required to construct the pad. These wells are on a 25 foot                                    "Each ranote station typically includes...         a heliport".       ibis is
                 spacing allotment. With a reduction in well spacing, which would result                                    incorrect, only a helipad would be required.
                 in a drill pad for 40 - 50 wells (the suggested development scenario in
                 the Report), only slightly larger pads than those in use at Kuparuk would                                  We hope the above comments will be helpful to you as you prepare the final
                 be necessary. Improved industry technology not only benefits industry, it                                  Report for Congress.
                 also benefits the environment in which industry operates. It is important
                 that such beneficial aspects be presented in the Report.                                                   in conclusion, we appreciate the efforts of your agency in presenting this
                                                                                                                            inforTmtion.    BPAF strorygly supports the recommendation that the entire
                 Page 81                                                                                                    1002 area be opened for exploration and development. W_ believe Congress
                                                                                                                            will recognize the urgency and the importance of allowing this step
                 Similarly, the Report describes gravel roads with a width of 35 feet. The                                  forward.
                 Kuparuk Unit standard width is 10 percent less for main roads and over 30
                 percent less for other roads.     Thus, more accurate estimates would show                                                                                      sincerely,
                 that development in ANWR will use less land and displace substantially                                                                                                A
                 less gravel than predicted in the Report.
                                                                                                                                                                                 C. S. Gibson-Smith

                                                                                                                            SD/ti
                                                                                                                            (8.6)

           Chemn                                                                                                                      Director,
                     Chemn U.S.A. Inc.                                                                                                U.S. Fish and Wildlife Service                    -2-                              February 4. 1987
                     6001 Bollinger Canyon Road, San Ramon, CA 94583-2398
                     Wd Aft- P. 0. Ou W42. S. P@, CA 94583 0947
                                                                                                                                      While the report raises some concerns regarding water and gravel resources In the 1002
                                                                                                                                      area, we believe this concern is overstated. All the valleys of larger streams are underlain
           R. E. Kfoprhot                                   February 4, 1987                                                          by large quantities of coarse sand and gravel. Further, data from thousands of shallow
           =: Z.-                                                                                                                     shot-holes throughout the 1002 area show much of the area is underlain by near surface
           won Rvm                                                                                                                    gravels. While fresh water may not be readily available in much of the 1002 area during
                                                                                                                                      the winter (as Is the case generally in the Arctic) fresh water can be obtained from takes,
                                                            Comments - DRAFT                                                          river gravel, storage of summer run-off, and by melting snow and ice as has been the practice
                                                            Arctic National Wildlife Refuge, Alaska                                   for the numerous exploratory wells drilled throughout the Arctic and in Prudhoe Bay.
                                                            Coastal Plain Resource Assessment and
                                                            Legislative Environmental Impact Statement                                The environmental effects described for "Alternative A" assumes that three portions of
                                                                                                                                      the 1002 area are developed concurrently. We believe the 1002 area will be developed In
                                                                                                                                      a sequential manner that will have considerably less impact than stated In the report. There
           Director, U.S. Fish and Wildlife Service                                                                                   are numerous examples of successful wildlife-oil interfaces, both In Alaska and the Lower 48
           Division of Refuges                                                                                                        States including the Aransas National Wildlife Refuge in South Texas, the Delta National
           2343 Main Interior Building                                                                                                Wildlife Refuge In Louisiana and the Kenai National Wildlife Refuge in Southern Alaska.
           l8th and "C" Streets, N.W.
           Washington. D.C. 20240                                                                                                     We agree with the conclus    ton that "Most adverse effects would be minimized or eliminated
                                                                                                                                      through carefully applied mitigation, using the lessons learned and technology acquired from
           Dear Sir:                                                                                                                  development at Prudhoe Bay and from construction of the Trans-Alaska Pipeline System."
           Chevron U.S.A. Inc. appreciates this opportunity to comment on the draft report/LEIS.                                      The Secretary's plan of following operations and watching for unexpected Impacts and then
                                                                                                                                      preventing serious effects through special conditions (of each project on a case-by-case
                                                                                                                                      basis is realistic and sensible. Blanket restrictions can result in inefficient patterns of
           Chevron supports the Secretary's recommendation "Alternative A - Full Leasing of           the 1002                        development and preclude opportunities to learn the best way to mitigate the effects of
           Area .. ..... It Is assumed that Congressional action would allow all Federal subsurface                                   Industry activity. Proposed restrictions should receive complete and fair review by all the
           ownerships of the 1002 area to be available for exploration and development through a leasing                              parties involved.
           program administered by the Department of the Interior ... and would open to oil and gas
           development and production the private lands within the refuge."                                                           We question the requirement for impact compensation. This requirement is (Tom USFWS
           We believe the report accurately describes the large oil and gas potential of the 1002 area                                mitigation policy which has no authority in statute and Is used to guide negotiations under
                                                                                                                                      the Fish and Wildlife Coordination Act. Compensation may be appropriate In Individual
           by stating: "Despite Its remote location and hostile environment, the 1002 area Is the most                                cases, but should not be codified.
           attractive onshore petroleum exploration target In the United States today. Development
           of Its potential oil and gas resources could make a significant contribution to the economy                                Chapter VII of the report aptly summarizes the uncertain condition of our country's oil and
           and security of this nation, and could be done in an environmentally responsible manner..."                                gas future, and we agree with the reasons for full leasing of the 1002 area. In addition to
                                                                                                                                      the economic benefits cited for Alaska and the Federal government, literally all states will
           Our experience on the North Slope supports the report's conclusion that Industry bag the                                   benefit by contracts to supply goods and services as they did in the development of Prudhoe
           ability to explore, develop and produce In an arctic environment with a minimum Impact                                     Bay Field and construction of the TAPS.
           on wildlife, resources and habitat.
                                                                                                                                      In conclusion, we agree with the Secretary's recommendation for "Alternative A."          Legislation
           The geological/geophystcal portion of    the report is a complete and thorough analysis of the                             must be Inacted that grants the Secretary authority to Initiate a leasing and development
           petroleum geology of the 1002 area. The discussions on the prospective sediments, source                                   program that is fully compatible with the purposes of the Arctic National Wildlife Refuge.
           rocks, oil generation and prospect types are consistent with the data at hand and are a realistic
           appraisal of the geology and the petroleum potential.                                                                      Although our comments In this letter are brief and deal only with OUT major viewpoints,
                                                                                                                                      there are details of the report which concern us. These topics are described by AOGA in
           It is important to recognize that other Interpretations of the geology may be valid. Experience                            their comments on the 1002 report. As a member company of AOGA, we participated In
           shows that different Interpretations are common In Federal OCS Sales as evidenced by wide                                  the identification and draft of comments which were submitted to the Director. We ask
           variations in tract bids. Areas Identified in the report as non-prospective may be considered                              that you consider these comments In your preparation of the final draft of the 1002 report.
           attractive by other Interpreters and may be sites of subtly defined petroleum traps. In
           Chevron's opinion, full leasing of the 1002 area ("Alternative A") ensures the best opportunity                                                                              Very truly yours,
           for an objective and thorough evaluation of the petroleum potential since all concepts could
           be tested. None of the other alternatives presents such opportunity.

           The statistical techniques used to determine the probabilities and the reserve ranges are                                                                                    R. E. Krop.
           similar to the methods used by much of the Industry in assessing the resources of large
           unexplored basins. We believe the report's resource estimates are within the range of values                               JJA/EKE:pac
           that knowledgeable earth scientists agree upon.

    James C. Patterson							Conoco Inc.
    Vice President								_00 N. Dairy Ashford Road
    North American Exploration						P.O. Box 21_7
    										Houston, TX 772_2

    February 5, 1987

    U.S. Fish and Wildlife Service
    Division of Refuges
    U.S. Department of the Interior
    Room 2343, Main Interior Building
    18th and C Streets
    Washington, D.C. 20240

    Gentlemen:

    Coastal Plain Resource Assessment
    Arctic National Wildlife Refuge Alaska

    Conoco Inc.  appreciates the opportunity to comment on the draft Coastal

    Plain Resource Assessment (1002 Report) for the Arctic National Wildlife

    Refuge (ANWR) which the Department issued Novemer 24, 1986.  We commend

    the Department for the fine job it idid in assembling the report and making

    its recommendation.  We recognize a great effort on the part of the many

    researchers, scientists and technical support staff that went into the

    compilation of the report.  Conoco, as a North Slope operator with a

    long-standing commitment to exploration in Alaska, recongnizes the

    significance of this draft assessment and the potential for oil and gas

    underlying the coastal plain.  Further, we appreciate having had the

    opportunity to comment at the public hearings held in Anchorage and

    Washington, D.C.  A copy of those comments is attached.

    Conco agrees that the potential contribution of the oil production from

    the 1002 Area would make tangibile positive contributions to the nation

    because it will create jobs, help to provide adequate energy supplies at

    reasonable costs, reduce our dependence on imported oil, enhance national

    CONOCO INC.
    February 5, 1987

    security, promote a favorable balance of international trade, and provide

    state, local and federal revenues.

    I.  CONOCO SUPPORTS FULL LEASING

    Conoco firmly endorses Alternative A, which proposes full leasing of the

    1002 study area, since it most readily meets the needs of the national

    interest and the vast majority of Americans.  We believe there is no

    justification for Alternative B, which suggests partial leasing, since

    proper mitigation measures will adequately protect the wildlife.  Likewise,

    Alternative C, allowing further exploration, does little to enhance the

    geophysical and geological information already available.  Confirmation of

    the hydrocarbon potential of the area can only be verified by drilling the

    existing geologicial structures.  Neither the Alternative D, permitting no

    action, nor E, which proposes wilderness designation, would allow for

    careful, reasoned planning and exploration and development of the coastal

    plain.  Those elitist proposals would deny the nation the benefits which

    would accrue from ANWR oil and gas production in which nearly all Americans

    would share.

    II.  CONOCO SEES HIGH GEOLOGIC POTENTIAL

    We concur that the area is clearly the most outstanding oil and gas

    frontier remaining in the United states, and could contribute substantially

    to our domestic energy supplies.  The Draft 1002 Report Assessment of Oil

    and Gas Potential is a thorough and substantial analysis of the available

    geological and geophysical data which further supports Conoco's own

    evaluation of the potential of the coastal plain.  our preliminary geoligic

    and geophysical studies carried out over the past several years indicate

    						-2-

            CONOCO INC.                                                                                                  CONOCO INC.
            February 5, 1987                                                                                             February S. 1987

            that the coastal plain possesses major hydrocarbon potential.           Its                                  million barrels per day   and is forecast to fall as low as four million
            location. between two major oil provinces at Prudhoe Bay and Canada's                                        baIrrels per day by the    end of the century.     Alaskan crude plays a
            MacKenzie Delta, at well as favorable on site geology, suggests a good                                       significant role in our   energy supply by providing the U.S. with 20% of its
            probability that additional hydrocarbon accumulation& of similar size may                                    total production.
            also be found in the coastal plain.       We attach a high priority to the
            opportunity to explore for and develop economical hydrocarbon reserves that                                  IV.   CONOCO EXPERIENCE IN ARCTIC AND ENVIROWMEN7ALLY SENSILIVE _OPERATIONS
            may underlie the area.      It is Imperative that industry be allowed to                                     A. Milne Point North Slope Oil Field
            explore for oil and gas  on the coastal plain and be permitted to develop it                                 Conoco has owned leases at Milne Point since 1969 and our operations there
            in a safe and environmentally sensitive manner to help ensure a secure                                       were planned in an environmentally sound and safe manner.          The actual
            domestic supply of energy for the future.                                                                    operations bear this out. No significant adverse effect has been detected
                                                                                                                         and. in fac t. It has been documented that the Central Caribou herd which
            111. CONOCO RECOGNIZES THE NATIONAL SECURITY ISSUE                                                           calves in the area has increased    almost threefold.
            We can no longer ignore the vulnerability of the United States to energy
            disruptions. The examples of that vulnerability are all too recent to be                                     B. Aransas Pass. Rome of the Whooping Crane
            forgotten. Conoco's leases on the Alaska North Slope at our Milne Point                                      Since 19 .37. Conoco has operated in another environmentally sensitive area
            Field were purchased In 1969. Production from those leases did not begin                                     known as The Aransas National Wildlife Refuge. This Refuge. in the coastal
            until late 1985. Because of the necessarily long load time from Initial                                      marsh of southern Texas. is the winter home of the endangered Whooping
            exploration to  .actual production (10 to 15 years). we must begin                                           Crane. During the past SO years. Conoco has taken measures to insure that
            exploration of the ARWR coastal plain now. We cannot afford to wait 15                                       Its personnel conduct site work with the welfare of the Whooping Cranes in
            .years after a crucial need airim for ANWR oil.                                                              mind. Since 1939, Conoco has drilled 74 wells in Aransas, 40 of which have
                                                                                                                         been producers. When Conoco begins a new well. it works with the Refuge
            The United States Is rapidly depleting Its domestic reserves of oil and                                      Manager to decide where to put in a road and what material to use to build
            gas.   Forecasts predict that domestic crude and oil production from                                         It. Seismic and drilling activity Is scheduled for those periods when the
            existing fields will decline from the nearly nine million barrels per day                                    birds are not using the Refuge, The floc@.has grown from an all time low
            average in 1985 to slightly more than s,ix million barrels per day In 2991.                                  of 15 cranes In 1941 to 110 bird& today.        In 1951, Conoco received the
            This is based on predictions that prices will remain at $15.00 per barrel.                                   Citation of Merit from the National Audubon Society in recognization of
            Current U.S. production has already fallen to nearly eight and a half                                        cooperation with conservation agencies in furthering the protection of the

                                                                                                                                                                -4-

                    CONOCO INC.                                                                                            CONOCO INC.
                    February 6, 1987                                                                                       February 5, 1987

                    Whooping Crane. This experience exemplifies the abi    .lity of Industry to                            Rainey Wildlife Refuge. the Aransas National Wildlife Refuge. and the
                    conduct oil and gas operations In extremely sensitive habitats with good                               donation of Sao Dock property to the Texas Nature Conservancy
                    results from both economic and environmental perspectives.

                                                                                                                           V. CONOCO IS SENSITIVE TO ENVIRONMENTIAL AND WILDLIFE IMPACTS
                    C. Paul J. Rainey Wildlife Refuge With Audubon Society                                                 A. Caribou
                    Another positive example of joint use of a wildlife refuge's resources Is                              There is  much concern over the effects of exploration and development
                    our exploratory drilling for oil and gas in the Paul J. Rainey Wildlif    .9                           activity on caribou In the 1002 area. We have concern for the welfare not
                    Refuge in the marshes of South Louisiana. The Refuge Is oper ted by the                                only of  Caribou, but all wildlife on the coastal plain.       However, we
                    National Audubon Society which issued the oil and gas,leases t: Conoco. We                             believe  that we have demonstrated our ability to operate in such an
                    operated under stipulations designed to protect the dallefte marsh. This
                                                                                                                           environment with no significant adverse impact to the habitat or the
                    relationship between the protection   of environment and conduct of oil                                associated wildlife.
                    operations was portrayed in the film aReflactionso featured at the
                    Petroleum Pavilion at the New Orleans Wo    rid's Fair in 1984.     Whiie                              The main calving areas  for the Central Arctic herd have remained unchanged
                    xploring there. Conoco worked with Refuge Management to improve    the marsh.
                                                                                                                           with the. development at Prudhoe Bay, Kuparuk River. and Milne Point.
                     weir system was put in place on the Refuge to control water        levels.                            Caribou have never used the Prudhoe Bay area for significant calving
                    Conoco used four acres of prime wetlands for drilling operations and then                              activity. but calving activity in the' Kuparuk River area has continued
                    worked together with Refuge and Audubon Society Managers to bring 1,200                                while two oil developments have taken place. The major factors determining
                    :
                    cres previously void of marine productivity Into the vibrant life cycle of                             calving location are snow, cover and predator avoidance.
                    he marsh, further demonstrating our consciousness and commitment to the
                    preservation of the environmentally special habitats In which we work.                                 Resource Category I designation  ,as described in the  National Environmental
                                                                                                                           Polity Act should not be applied to the coastal plain's core calving area;
                    D. Conoco Operating Awards                                                                             this area does not meat the "unique and Irreplaceable" criteria.         For
                    In 1985. Conoco was one of three major oil companies honored by the U.S.                               instance. concentrated calving In the Jago Highlands has occurred In only
                    Commerce Department for "Outstanding Contribution to the Conservation of                               five of the the last fourteen years. Also. there are no data that Indicate
                    Marine U.S. Fisheries." Conoco was cited for Its efforts involved In the                               calf mortality Is greater or herd recruitment is lower when calving does
                    conservation and management of valuable coastal wetlands in the Paul J.                                not occur In the core    calving area.    The calving habitat is more

                                                                                                                                                                 .6-

                CONOCO INC.
                February S.  1987                                                                                             CONOCO INC.
                                                                                                                              February 5.  1987

                appropriately represented as a continuum across the Arctic coast. and a
                portion of this region lies within the 1002 area.                                                             Porcupine herds resulting from oil development Are pure speculation and         not
                                                                                                                              supported by any actual data or theoretical models.

                Research models at the University of British Columbia Indicate forage
                'habitat does not become A factor In the Porcupine hard population until                                      The Central Arctic herd has not been displaced from Its traditional use
                herd size exceeds one million Animals; the loss In forage fron. potential                                     areas by Any North Slope oil field development. During the two or thrie
                oil development is insignificant.                                                                             week calving season, there may be a re-distribution of maternal caribou to
                                                                                                                              avoid areas of human activity. There have been disturbances to caribou
                The caribou study by Dau and Cameron at Milne Point did not distinguish                                       movement. particularly the combination of a pipeline Adjacent to A road
                between maternal And nonmaternal females during the surveys.             The                                  with heavy vehicle traffic.      Work by J. A. Curatolo has shown that a
                distribution of maternal females was extrapolated using the total number        of                            roadway/pipline separation of 400-800 feet will minimize this disturbance.
                caribou and the number Of CAlVeS. The authors noted that 'the latter I$         An
                A posteriori analysis. and the results should not be granted-the some level                                   The report states OC&ribou populations appear to fluctuate unpredictably
                of objectivity as the other results.*         This study should not be                                        over the long tem. The long term maximum and minimum population of the
                characterized as "the most systematic study of caribou displacement by oil                                    PCH and..the carrying capacity of the PCH are unknown.'           There Is a
                development' because the conclusions cited in the 1002 report are based on                                    "...qentral lack of relevant information concerning probable reactions of
                extrapolated and correlated rdats. not on actual measured-data. The results                                   that speciftc herd (KH) to oil development ... " In discussing the Central
                presented in the 1002 report were for a two-week period in June. During                                       Arctic herd, the report states "no recognizable long-tem effect upon the
                May, July. and August there Is no measurable difference in habitat use,                                       Central Arctic herd as a result of displacement by oil development in the
                Including habitat within 100 meters of the road, and distance from the                                        central Alaskan Arctic has been documented to data." The above does not
                road.                                                                                                         support the contention that a ZO-40% decline or distribution change of the
                                                                                                                              Porcupine Caribou hard is an "unavoidable impact.*
                There is no evidence that calving outside the core calving areas has
                reduced herd productivity with either the Central Arctic herd or the                                          The interactions between caribou      and oil field development have been
                Porcupine Caribou herd.(PCH).      Positive correlations between calving                                      studied for nearly ten years on the Worth Slope.         The information gained
                location and calf mortality and/or hard recruitment have never been                                           each year has been incorporated into subsequent development activities. The
                published.  The population decline estimates for the Central Arctic and                                       more recent developments at Kuparuk and Milne Point have Incorporated this
                                                                                                                              learning with revised construction end operation practices.           This Is a

                 CONOCO INC.
                 February S.  1987                                                                                              CONOCO INC..
                                                                                                                                February 5.  1967

                 dynamic process that Is continually     being  refined as new knowledge      Is                                other North  Slope fields.
                 incorporated.   The petroleum Industry has     spent millions of dollars In
                 studies and mitigation measures an the North Slope and the efforts are
                                                                                                                                At Milne Point, Conoco presently has the capability of providing some          850
                 working.   The Central Arctic herd. the fastest growing hard In Alaska.
                                                                                                                                barrels a day of desalinized water for operations. The 3 existing brackish
                 shares traditional calving and insect relief habitat with oil field
                                                                                                                                water wells produce from a horizon some 3.000 feet below the surface. With
                 development,
                                                                                                                                a larger deselinization plant we believe that these 3 wells could provide
                                                                                                                                as much as 15.000 barrels of fresh water per day. We have no information
                 The knowledge gained on the North Slope concerning caribou end oil field
                                                                                                                                to believe that this technology cannot be used at ANWR although the Draft
                 development can be directly applied to development on ANWR. Necessary and
                                                                                                                                Report Indicates that water resources are     limited and surficially confined
                 reasonable mitigation measures have been developed over the past ten years                                     In the 1002 area.
                 which foster the multiple surface utilization of both caribou and oil
                 development in existing fields. The same cohabitation is possible at A            NWR.
                                                                                                                                The bulk of  the water volume needed is not for the direct drilling of the

                                                                                                                                well. but for the associated Ice pad, Ice road, and/or Ice airstrip.
                 0. Water
                                                                                                                                Hence. much of the required water volume will decrease as permanent
                 The first  paragraph under   WATER RESOURCES on Page 21 of the Draft Report
                                                                                                                                infrastructure replaces temporary Ice structures.
                 ignores the fact that Conoco routinely uses subsurface water wells at its
                 Alaska North Slope Milne Point Field to obtain brackish water which Is                                         C. Gravel
                 processed through a desalinization plant for the generation of fresh water
                                                                                                                                There has been concern expressed regarding the availability of gravel           in
                 which is used in our operations there. These desalinization plants are                                         the 1002 area. However, on page 20. the report indicates: OThe valleys of
                 commonly used all over the world In both offshore and desert environments                                      larger streams are underlain by large quantities of coarse sand and gravel.
                 where fresh water might otherwise be unavilable.. When this existing                                           These Include the valleys of the Canning. Tamayarlak, Katakturuk.
                 technology Is applied to ANWR coastal plain operations in concert with the                                     Sadlerochit. Hulahula. Okpilek. Jago, 0     'kerokovik. Kogotpak and Alchilik
                 existing surface fresh and salt water resources. we belie     ve that there will                               Rivers.  These rivers. especially the Canning, Sadlerochit, Hulshula, Jago
                 be more   than adequate supplies of water to sustain oil and gas operations                                    and Aichilik. are heavily braided and have extensive unvegetative gravel
                 without   significantly affecting local environmental demands for fresh                                        bars.  Gravel also occurs In the south part of the 1002 area between the
                 water.    Gravel borrow pits. If authorized in the coastal plain, could                                        Canning River and Marsh Creek &I   ong tops and flanks of ridges between the
                 provide   another fresh water reservoir source from run off as they do at                                      Katakturuk and Sadlerochit Rivers and on spits and bars along the coastline

                                                        -9.

                CONOCO INC.                                                                                                CONOCO INC.
                February S. 1987                                                                                           February S. 1987

                of the Beaufort Sea.   This is an apparent contradiction to the portion of                                 effects on coastal fish through lost or reduced habitat values,      inhibited
                the executive summary which says "water and gravel necessary for                                           movements, and direct mortality.*      We have seen significant positive
                construction and development are in very limited supply in the 1002 area."                                 effects on coastal fish and fisheries related to oil and gas development in
                                                                                                                           the Gulf of Mexico. While there are significant environmental differences
                Figure 11-2 on page 16 Indicates abundant surficial deposits of sand and                                   between the Gulf and the Beaufort Sea. we cannot find any Infermation in
                gravel.  Although figure 11-2 indicates surface materials only, it Is                                      the resource assessment to justify or support the conclusion that coastal
                unlikely that these gravel deposits are strictly surficial in nature.                                      fish will be necessarily adversely affected by properly conducted oil and
                particularly since similar deposits are widespread and abundant across the                                 gas operations.   Gravel borrow pits can provide overwintering habitat for
                entire North Slope Coastal Plain. In fact. not only do abundant sources of                                 many species of fish. At Milne Point a bridge over the only fish bearing
                gravel seem to be available in the 1002 area along the major stream                                        stream in the area was designed to insure clear passage upstream for the
                valleys, but pages 99-100 indicate that the taking of gravel from areas                                    coastal fish population.
                such as river bar&. river terraces, and cutbanks can be done with minimal
        rb      adverse impacts. Furthermore. two side benefits could result from these                                    VI. CONOCO AGREES WITH LEASING AUTHORITY RECOMMENDATION
                types of borrow pit:   deep holes could be created for the overwintering of                                The Draft Report's recommendation that leasing authority be granted by
                fish; and water reservoirs would be created. thus helping to alleviate the                                 Congress  to the Fish and Wildlife Authority and The Bureau of Land
                water supply problem.                                                                                      Management similar to authorities     already existing in the National
                                                                                                                           Petroleum Reserve in Alaska (NPRA)     Is a reasonable and useful way of
                Further Indications of the availability of gravel comes from the shot holes                                establishing a Teasing process for    the coastal plain. The experience of
                created by drilling which was done throughout the 1002 area over the                                       the BLM in the leasing process coupled with oversight by the Fish and
                seismic shooting seasons of 1984 and 1985.      Data frorn holes drilled then                              Wildlife Service will make the leasing process meet the special needs of

                indicate that there was an abundance of very near surface gravel.        We do                             this province.

                not expect the availability of gravel to present a problem In the
                exploration and development of the coastal plain.                                                          VII. MITIGATION
                                                                                                                           Naturally. with respect to operating on the coastal plain of ANWR

                D. Fish                                                                                                    reasonable mitigation measures must be taken.        The oil Industry has

                We also take issue with the conclusion in the resource assessment that                                     demonstrated willingness and ability to mitigate environmental impacts on
                "Development of KIC/ASRC lands or offshore areas could result In moderate                                  the North Slope.    Examples of mitigation at Conoco's Milne Point Field

                                                       -11-                                                                                                       .12-

                CONOCO INC.
                February 5, 1987

                include but are not limited to: power lines were configured to minimize
                danger to Raptors; traffic minimization, stock piling of materials. the
                delay of major construction projects during Caribou calving and insect

                harrassment. season$,. continuing educational programs- for Conoco and
                contract personnel to insure that wildlife and environmental harrament is -                                                ATTACHME14T To CONOCO INC.
                avoided; prohibition of fire arms and hunting on the lease, pipeline and                                         COMMENTS ON COASTAL PLAIN RESOURCE ASSESSMENT
                flow lines are elevated to allow Caribou to pass underneath and burial of                                           ARCTIC NATIONAL WILDLIFE REFUGE. ALASKA
                pipelines to allow Caribou to cross over; trash containment to avoid                                                        DATED. FEBRUARY S. 1987
                attraction of wildlife.  There are of course many other examples of

                reasonable mitigation measures used at Milne Point. We concur with the
                ANWR Coastal Plain Resource Assessment's general recognition that
                exploration and production can be accomplished without unacceptable changes                              CONOCO TESTIMONY ON DRAFT COASTAL PLAIN RESOURCE ASSESSMENT
                to physical. biological or socioeconomic resources.                                                                ARCTIC NATIONAL WILDLIFE REFUGE, ALASKA

                                                                                                                                        DEPARTMENT OF INTERIOR HEARING

                Vill. CONCLUSION

                In closing. Conoco Inc. again commends the Department on the effort
                undertaken in preparing the draft coastal plain Resource Assessment. We
                believe the report squarely frames the Issues related to the opening of the
                coastal plain.  We are confident we tan meet our commitment to the
                environment and a strong secure domestic energy future through carefully
                planned exploration and development and strongly support the Department's
                recommendation to open the coastal plain to full leasing.

                Respectfully.
     4:;@/J@ames C. @PatltersA
                               On
                RLLZ/dm 024 (DEM)
                                                   :13-

             CONOCO INC.                 ATTACWMENT
             February 5,., 1987                                                                       February 5, 1981
             MY NAME IS JAMES C. PATTERSON. I AM A VICE PRESIDENT AND                                 WE ARE A MAJOR OPERATOR IN THE NORTH SEA, INDONESIA AND DUBAI.
             GENERAL MANAGER FOR CONOCO INC., WITH RESPONSIBILITY FOR                                 AND ARE ACTIVELY PURSUING PROMISING EXPLORATION OPPORTUNITIES
             EXPLORATION IN NORTH AMERICA@     WE WELCOME THIS OPPORTUNITY TO                         IN EGYPT, WEST ArPICA AND LATIN AMERICA,       GENERALLY SPEAKING,
             APPEAR   BEFORE   YOU,    CONOCO   SUPPORTS   WHOLEHEARTEDLY     THE                     THE SIZE OF RESERVES TO BE DISCOVERED ABROAD IS MUCH LARGER
             RECOMMENDATIONS    CONTAINED     IN   THE    DEPARTMENTS*     DRAFT                      AND LESS COSTLY TO DEVELOP THAN THOSE BELIEVED TO REMAIN I'll
                                                                                                      THE UNITED STATES.
             LEGISLATIVE ENVIRONMENTAL IMPACT STATEMENT, TERMED THE SECTION
             1002 REPORT, WHICH FAVORS OPENING THE COASTAL PLAIN OF THE
             ARCTIC NATIONAL WILDLIFE REFUGE (ANWR) TO OIL AND GAS LEASING.                           YET, WE REMAIN CGMMITTED TO EXPLORING FOR PETROLEUM IN THIS
             OUR POSITION IS PREMISED ON OUR ASSESSMENT OF THE GEOLOGICAL                             COUNTRY.   PROXIMITY TO OUR     DOWNSTREAM OPERATION, THE LARGE
             POTENTIAL OF THE COASTAL PLAIN AND OUR FIRM BELIEF THAT OIL                              DOMESTIC MARKET FOR PETROLEUM PRODUCTS AND THE RELATIVELY
             AND GAS EXPLORATION AND DEVELOPMENT CAN BE CONDUCTED IN A                                FAVORABLE AND STABLE INVESTMENT CLIMATE REPRESENTED BY THE,
             MANNER FULLY COMPATIBLE WITH PROTECTION OF THE ENVIRONMENTAL                             UNITED STATES ARE AMONG THE.MANY     .. REASONS FOR OUR CONTINUED
             RESOURCE.S.OF THI.S FRAG.I.LE AREAo                                                      W&VEMENT     IN DOMESTIC OIL EXPLORAT16N.

        0"   HYPRQCARBON POTENTIAL OF HE COASTAL PLAIN                                                MOST OF .THE EASILY ACCESSIBLE* LARGE RESERVES OF PETROLEUM       IN
         D
             T14E DEPARTMENT'S ESTIMATES OF THE HYDROCARBON POTENTIAL OF THE                          THIS COUNTRY HAVE  @l ALREADY BEEN DISCOVERED AND DEVELOPED.      IN
                                                                                                      ORDER TO REPLACE DOMESTIC RESERVES THAT ARE BEING DEPLETED        AT
             COASTAL PLAIN HAVE BEEN WELL-PUBLICIZEDs WE ALSO BELIEVE THE
             AREA TO BE GEOLOGICALLY ATTRAC71VE HAVING THE POTENTIAL FOR                              A IAPID RATE. OUR        INDUSTRY MUST FOCUS      INCREASINGLY    ON
             MAJOR HYDROCARBON ACCUMULATIONSi     FROM THE PERSPECTIVE OF AN                          "FRONTIER    AREAS'   WHERE   THE   POSSIBILITY    Of   MAJOR     NEW
             INTEGRATED PETROLEUM COMPANY ENGAGED IN THE FULL RANGE OF OIL                            DISCOVERIES STILL EXISTS,     THERE ARE VERY FEW FRONTIER AREAS
             AND GAS OPERATIONS, I WOULD LIKE TO EXPLAIN WHY WE URGE THAT                             THAT CONOCO REGARDS AS PARTICULARLY PROMISING.            THE ANWR
             THE  POTENTIAL   OF THE COASTAL PLAIN BE DETERMINED MORE                                 COASTAL PLAIN IS ONE OF THEM.
             PRECISELY* AND AT THE EARLIEST OPPORTUNITY*

             CONOCO'S EXPERIENCE IN FINDING AND DEVELOPING SIGNIFICANT NEW
             PETROLEUM RESERVES IS INTERNATIONAL IN SCOPE,

                                                                                                                                       -2-

               CONOCO INC.                  ATTACHMENT
               February 5, 1987                                                                         'CONOCO INC.                  ATTACHMENT
                                                                                                        February 5, 1997
              CONOCO ATTACHES    HIGH PRIORITY TO THE OPPORTUNITY To EXPLORE                            THE U.S. DEPENDS ON FOREIGN SOURCES     FOR ABOUT ONE-TI41RD OF ITS
              FOR AND DEVELOr    ECONOMICAL HYDROCARRMIN RESERVES THAT MAY BE                           UIL.    THe AMOUNT or IMrOftTEb OIL WILL CONTINUE TO Rl".$
              PROVEN TO EXIST    IN THE COASTAL PLAIN.    PRELIMINARY GEOLOGICAL                        HOWEVER* NEW DISCOVER19S AT HOME CAN HELP IN ALTERING THIS
              AND GEOPHYSICAL STUDIES CARRIED OUT OVER THE PAST SEVERAL                                 TREND.   AMERICA'S ENERGY SECURITY DEPENDS ON FINDING NEW LARGE
              YEARS INDICATE     14AJOR HYDROCAR  iBON POTENTIAL.    THE COASTAL                        HYDROCARBON RESERVES   .AT HOME,
              PLAIN'S LOCATION, BETWEEN TWO MAJOR OIL PROVINCES AT PRUDHOE
              BAY AND     IN   CANADA'$ MCKENZIE DELTA.        SUGGESTS   A GOOD                        OPENING THE COASIAL PLAIN TO OIL AND GAS          EXPLonATION WOULD
              PROBABILITY THAT ADDITIONAL HYDROCARBON ACCUMULATIONS OF                                  ALSO STIMULATE ECONOMIC ACTIVITY IN ALASKA AND THE REST OF THE
              SIMI.LAR SIZES MAY'ALSO BE FOUND IN THE COASTAL    PLAIN.                                 COUNTRY.    PROJECTS CONDUCTED ON ALASKA'S NORTH SLOPE SINCE
                                                                                                        1974 REQUIRED $36 BILLION IN INVESTMENTS BY THE OIL INDUSTRY,
              WE CANNOT KNOW FOR CERTAIN THAT THE COASTAL PLAIN CONTAINS OIL                            APPROXIMATELY $10.5 BILLION WAS SPENT IN THE LOWER 48 FOR
              OR GAS ACCUMULATIONS UNTIL EXPLORATION DRI      .LLINA TAKES PLACE.                       ALASKAN PETROLEUM ACTIVITIES BETWEEN 1980 AND 1985.                 IF
              THE ALASKAN NORTH-SLOPE IS A 'HIGH COST OPERATING ENVIRONMENT.                            EXPECTATIONS ABOUT' THE COASTAL PLAIN ARE REALIZED* SIMILAR
              DISCOVERIES MUST BE LARGE TO JUSTIFY DEVELOPMENT AND ALLOW
                                                                                                        LEVELS OF INVESTMENT AND THE CREATION OF SEVERAL THOUSAND JOBS
          C2  RECOUPMENT OF NLAVY EAPITAL INVE3TMCNT3 REQUIRED FOR SUCH                                 CAN BE EXPECTED,
              PROJECTS, THE PETROLEUM INDUSTRY IS ACCUSTOMED TO HIGH RISKS,
              IN ANTICIPATION OF THE REWARDS FHAT COMMERCIAL DISCOVERIES
                                                                                                        If ECONOMIC DISCO41RIES Artr MADE IN THE COASTAL PLAIN, ltnTH
              BRING.   THESE REWARDS EXTEND FAR BEYOND SPECIFIC COMPANY                                 THE. LOCAL AND FEDERAL GOVERNMENT WILL BENEFIT FROM INCREASED
              PROFITS.    A    FEW  EXAMPLES   RELATED   TO   CURRENT     PETROLEUM                     REVENUES IN TAXES AND ROYALTIES.         OIL-RELAIED INCOME IS A
              OPERATIONS ON THE NORTH SLOPE ARE WORTH NOTING.        OIL PRODUCED                       MAJOR FACTOR IN T  HE ALASKAN ECONOMY.     RECEIPTS FRO14 PETROLEUM
              IN ALASKA PRESENTLY ACCOUNTS FOR APPROXIMATELY 200,. OF TOTAL                             ACTIVITIES  ON PUBLICALLY-OWNED LANDS 13 THE SECOND LARGEST
              DOMESTIC PRODUCTION.     THIS IMPORTANT SOURCE IS EXPECTED TO                             SOURCE OF FEDERAL      REVENUES,    AFTER   INCOME   TAXES.     THUS,
              START DECLINING THIS YEAR. AS EXISTING FIELDS BEGIN TO BE                                 SUCCESSFUL   PETROLEUM DEVELOPMENT IN THIS AREA WOULD SERVE
              DEPLETED.   NEW DISCOVERIES ON THE SLOPE WOULD HELP MAINTAIN                              BROAD U.S. ECONOMIC INTERESTS# AS WELL AS ENERGY SECURITY
              AND EXPAND ALASKA'S CONTRIBUTION TO DOMESTIC OIL PRODUCTION.                              NEEDS,

                                                -3-

            CONOCO INC.                 AIIALMrtNi
            February 5. 1967
                                                                                                     -CONOCO INC.                 ATTACHMENT
            ENVIRONMENTAL COMPATMILITY OE PE-TRQLIEUM OPERATIONS                                     February b. 1987
            EARLIER I MENTIONED THE HIGH DEGREE OF RISK THAT AN ENERGY                               IN KEEPING wiym    THE FINDINGS OF THAT STUDY,       THE 11.5 MILE
            COMPANY LIKE CONOCO ASSUMES 'WHEN UNDERTAKING EXPLORATION IN                             PIPELINE WE BUILT TO CONNECT WITH THE TAP's SYSTEM INCLUDED
            FRONIIER AREAS SUCH AS THE ALASKA NORTH SLOPE.           CONOCO I S                      SEVERAL CARIBOU CROSSINGS.     AT SEVERAL POINTS ALONG THE LINEs

            BOVALLY - JARF OF ENVIRONMENTAL RESPONSIBILITIES IMPOSED BY                              THE PIPE IS BURIED, AND A GRADUAL SLOPE COVERS IT, AtLOWING
            OPERATING IN AREAS AS FRAGILE AS THE COASTAL PLAIN.                                      THE ANIMALS TO WALK OVER. ELSEWHERE. THE PIPELINE IS ELEVATED
                                                                                                     TO PERMIT CARIBOU TO PASS UNDERNEATH. - DURING THE SUMMER
            THE DEPARTMENT'S STUDY OF THE COASTAL PLAIN INCLUDED DETAILED                            MONTHS, WHEN THE CARIBOU CALVE IN THE AREA, ROAD TRAFFIC IS
            ANALYSES OF THE BIOLOGICAL ENVIRONMENT OF THE AREA AND NOW IT                            RESTRICTED TO AVOID NOISE *DISTURBANCE.        SIMILAR DESIGN AND
            MIGHT BE AFFECTEil BY PETROLEUM OPERATIONS.          THERE IS' NO                        OPERATING PROCEDURES WOULD BE INCORPORATED' INTO PROJECTS
            QUESTION THAT SPECIAL PRECAUTIONS WILL NEED TO BE TAKEN TO                               PLANNED FOR THE COASTAL PLAIN TO ENSURE COMPATIBILITY WITH

            PROf9tT THE UNIGUL ELULU61 OF THE COA3TAL PLAINs              CONOCO                     WILDLIFE SPECIES THERE* SUCH AS CARIBOU# MUSK OXEN AND
            BELIEVESo' -H*OWEVER, .. THAT 'EXPERIENCE   GAINED -THROUGH      OUR                     MIGRATORY BIRDS.    CONOCO HAS BEEN PRODUCING PETROLEU     14 IN THE
            OPERATIONS ON THE SLOPE, AND THE COMMITMENT TO ACCOMMODATE                               ARANSAS NATIONAL WILDLIFE REFUGE IN TEXAS FOR MORE THAN 40

            ENVIRONMENTAL   CONCERNS   WILL   ENABLE    US  TO   CONDUCT     OUR                     YEARS WITHOUT HARMING THE ENVIRONMENT OR ENDANGERING THE

            ACTIVITIES IN A MANNER FULLY COMPATIBLE WITH THE SPECIAL                                 WILDLIFE.
            CHARACTERISTICS-OF  THE -COASTAL  PLAIN.   AGAIN, A FEW EXAMPLES
            FROM THE ESTABLISHED RECORD ARE   ILLUSTRATIVE,                                          OTHER OPERATIONAL CONCERNS IN THE COASTAL PLAIN RELATE TO THE
                                                                                                     TUNDRA AND PERMAFROST BENEATH THE SURFACE. AGAIN, WE REFER TO
            PROTECTION OF THE CARIBOU HABITAT IN ANWR 15    A CENTRAL CONCERN                        EXPERIENCE IN NEARBY AREAS. AT EXISTING FIELDS ON THE SLOPE,
            REGARDING THE POSSIBLE IMPACT OF PETROLEUM      ACTIVITIES ON' THE                       FACILITIES ARE ELEVATED TO MINIMIZE SURFACE IMPACT.         DRILLING
            COASTAL PLAIN.    IN IMPLEMENTING OUR MILNE POINT PROJECT,                               AND PRODUCTION OPERATIONS ARE CONSOLIDATED ONTO SPECIALLY
            CONOCO ENCOUNTERED THE NEED TO COEXIST WITH CARIBOUs IN THIS                             DESIGNED AND CONSTRUCTED UNITS     THAT PROTECT THE SURFACE AND
            INSTANCE THE CENTRAL ARCTIC HERD.       CONOCO ENGAGED WILDLIFE                          REDUCE THE TOTAL AREA OCCUPIED.      MoST FACILITIES USED ON THE
            EXPERTS FROM THE UNIVERSITY OF ALASKA TO STUDY THE MOVEMENTS                             SLOPE ARE PREASSEMBLED AT LOCATIONS IN THE LOWER 48.             THIS
            OF CARIBOU IN THE MILNE POINT AREA AND DESIGNED FACILITIES SO                            APPROACH MEANS T14AT LESS ACTIVITY IS REQUIRED IN THE IMMEDIATE

            AS TO MITIGATE INTERFERENCE WITH THE HERD.                                               AREA OF ACTUAL OPERATIONS.

                                            -5-

                                                                                                                                     -6-

             CONOCO INC.                 ATTACHMENT
             February 5. 1987
                                                                                                    'CONOCO INC.                  ATTACHMENT
             ANOTHER POTENTIAL PROBLEM AREA IS THE RELATIVELY LIMITED                                February 5, 1987
             NATURAL SUPPLY OF FRESH WATER AVAILABLE ON THE COASTAL PLAIN,                          CONOCO COMMENDS THE DEPARTMENT FOR ITS TIMELY REPORT ON ANWR
             WHICH IS TECHNICALLY CATEGORIZED AS AN ARCTIC DESERT WITH LESS                         AND STANDS READY TO ASSIST         IN EFFORTS TO IMPLEMENT ITS
             THAN 6 INCHES OF PRECIPITATION A YEAR.         TECHNOLOGY FOR THE                      RECOMMENDATIONS-    I WOULD BE HAP PY TO RESPOND 10 ANY QUESTIONS
             GENERATION   OF   FRESH WATER     TO    SUPPORT  EXPLORATION     AND                   YOU MAY HAVE.
             DEVELOPMENT ACTIVITY 10 ARID AREAS IS WELL KNOWN.         AT 14ILNE
             TOINT, CONOCO USES A TECHNIQUE KNOWN AS DESALINAZATION.         THIS

             TECHNIQUE IS COMMONLY USED IN OFFSHORE OPERATIONS WORLDWIDE#

             THE TRACK RECORD BUILT. BY OIL COMPANIES OPERATING ON THE NORTH

             SLOPE OVER THE PAST 15 YEARS IS VERY POSITIVE. FROM THE

             STANDPOINT   OF   ENVIRONMENTAL    PROTECTIONt   THERE   ARE    MANY
             EXAMPLES OF INDUSTRY'S ABILITY TO INNOVATE AND ADAPT IT'S

             T6CHNOLOGIES     IN     RESPONSE     TO    LOCAL      ENVIRONMENTAL                    AWD/SPCH/013
             CHARACTERISTICS. NEW    PETROLEUM PROJECTS ON THE COASTAL PLAIN                        12/29/86
             WILL BENEFIT FROM PROVEN TECHNOLOGY ON THE SLOPE.       A DECISION
             BY CONGRESS TO ALLOW OIL AND GAS LEASING ON THE COASTAL PLAIN

             WILL  ALLOW THE      INDUSTRY TO    PLAN    FOR  EXPLORATION     AND

             DEVELOPMENT IN THE MOST EFFECTIVE AND EFFICIENT MANNER.           IT

             WILL ALSO PROVIDE US VALUABLE TIME IN WHICH TO DESIGN

             APPROPRIATE FACILITIES FOR THIS SPECIAL ENVIRONMENT.              IF
             CONGRESS DELAYS OPENING THE COASTAL PLAIN, THE INDUSTRY WILL

             BE UNABLE TO RESPOND IN A TIMELY MANNER TO AN ENERGY CRISIS

             WHEN IT OCCURS,

                                             -7-

                                                                                                                           Mr. William P. Horn                      -2-                        February 5, 1987

               E-"^N COMPANY U.S.A.
               POST OFFICE BOX 4279 - HOUSTON. TEXAS 77210-4279                                                            Coastal  Plain,  but there should be no comfort in estimates alone.                The
                                                                                                                           potential significance of the reserves possible in ANWR dictate that this
                                                                                                                           nation determine with certainty if oil exists in ANWR.          Accordingly, it is
               EXK(MATIONDEPARTWNT                                                                                         vital that Congress authorizes comprehensive and timely oil and gas exploration
               OFFSHOW/ALASKA(XVISION                                                                                      and development in the ANWR Coastal Plain.
               MANAGI 11                                     February 5, 1987                                              We are not impressed by criticisms that have appeared in the press regarding
                                                                                                                           the Department's resource estimates and discovery probabilities; for the
                                                                                                                           record, we wish to observe that the probabilities of discovery of hydrocarbons
                                                                                                                           are a matter of interpretation, as are the estimates of oil reserves.          A wide
                                                                                                                           range of interpretations of existing geological and geophysical data is
                                                                                                                           possible among competent explorationists.         If the odds of a commercial
                                                                                                                           discovery are close to 19% as estimated in the report, those odds are very good
               Mr. William P. Horn                                                                                         for a previously undrilled geologic area.        Other criticism of the resource
               U.S. Fish and Wildlife Service                                                                              estimate distorts the significance of the potential reserves to be found in the
               Division of Refuge Management                                                                               coastal plain    To say that the mean resource estimate of recoverable reserves
               2343 Main Interior Building                                                                                 cited in the @eport will supply the nation with only six months of oil fails to
               18th and C Streets, NW                                                                                      recognize that over 80% of all fields ever discovered in this cou                 ntry
               Washington, OC 20240                                                                                        individually would have been less than a one day supply of oil and gas.        If the
                                                                                                                           DOI ANWR Coastal Plain estimates ultimately prove to be correct, the amount of
               Dear Mr. Horn:                                                                                              oil would be very significant.
               Exxon Company, U.S.A., a division of Exxon Corporation,      is pleased to provide                          Fears of environmental degradation have been raised as if not previously
               comments on the draft Arctic National Wildlife Refuge,       Alaska, Coastal Plain                          investigated or resolved.     These fears have inordinately dominated the ANWR
               Resource Assessment.   Our overview of key ANWR issues and detailed comments on                             access issue to date. We believe these fears misrepresent the facts by ignoring
               the draft are attached, along with the testimony we presented in Anchorage on                               nearly 20 years of environmentally safe operations on the coastal plain of
               January 5, 1987, and in Washington, DC, on January 9, 1987.            Additionally,                        Alaska's North Slope.     Based on extensive industry, academic, and resource
               Exxon endorses the comprehensive comments of the Alaska Oil and Gas Association                             agency research, there are no detectable adverse impacts on population size or
               and the American Petroleum Institute.                                                                       dynamics of any species that inhabits the area.      Energy resource development in
                                                                                                                           the ANWR Coastal Plain and protection of environmental values are not mutually
               Exxon strongly supports the Department of Interior's proposal that "...Congress                             exclusive.
               authorize the Secretary to lease the        entire 1002 area for oil and gas
               exploration and development."     We urge that the Secretary of Interior adopt                              Although we strongly support the recommendation for leasing of the entire
               this proposal in the final 1002(h) report when he submits his recommendations                               coastal plain of the Arctic National Wildlife Refuge, we are critical in our
               to Congress later this year.    This proposal Is clearly justified on the basis                             attached comments of some impact descriptions that are highly speculative and
               of national energy needs and environmental compatibility.                                                   we object to several of the mitigating measures that are unjustifiable and very
                                                                                                                           restrictive.   Nevertheless, we have tried to make constructive comments based
               The 1002(h) report describes the national importance of leasing in ANWR and                                 on our operating experience and a careful review of research findings.
               properly identifies several events faced by our nation during this decade
               including a lack of major exploration successes and declines in both proven                                 Oil and gas exploration and development in the coastal plain of the Arctic
               domestic reserves and domestic oil and gas production.          Contrary to these                           National Wildlife Refuge is an important national issue.            The land access
               production declines, domestic oil demand is increasing.            If such trends                           decisions made today could have a profound impact on national and energy
               continue,  our nation will      become increasingly dependent on potentially                                security, on our nation's balance of trade, and indeed on the lifestyle and
               unreliable sources of foreign oil.                                                                          livelihood of Americans.    The right to regulate and legislate the use of this
                                                                                                                           nation's public lands imposes a trust obligation upon the members of Congress
               The anticipated resource potential of ANWR cited in the report is cause for                                 as well as the Department of Interior.           If Congress fails to authorize
               optimism.   All of the geologic parameters necessary for the accumulation of                                reasonable    exploration   and   development    in   ANWR,     notwithstanding    the
               commercial quantities of oil and gas appear to be present under the ANWR                                    demonstrated environmental compatibility of oil and gas operations, then there
                                                                                                                           will have been an obvious breach of trust of the American people.

                A DIVISION OF E X XON CORFOIIA I ION

              Mr. William P. Horn                      -3-                       February 5, 1987

              In summary, we would like to acknowledge the five years of extensive field
              investigation, data collections and analyses by over 50 trained professional
              scientists, including wildlife and fishery biologists, botanists, zoologists,
              chemists, geologists, and resources specialists behind this report.          Further,
              we applaud the authors of the draft report for the conclusions that the entire                                                     EXXON COMPANY, U.S.A. REVIEW COMMENTS
              ANWR Coastal    Plain should be open to exploration and development;              and                                                      DOI - 1002(h) REPORT
              unequivocally believe that energy development and economic well-being are
              compatible with a safe and enjoyable environment.

                                                             Sincerely,                                                   Following a detailed review of the Department of the Interior's 1002(h) report,
                                                                                                                          Exxon Company, U S.A. endorses the 001 recommend:tJon to support leasing of the
                                                                                                                          entire 1002(h) c@astal plain area for oil and ga development. Our endorsement
                                                                                                                          of the DOI recommendation to open leasing is based on the following overview
                                                                                                                          and detailed comments.
              MGJ.DTS.pl
              2b.DTS(pl2)
                                                                                                                                                                OVERVIEW

                                                                                                                          Prudhoe Bay

                                                                                                                          Often the NEPA-mandated EIS process is forced to predict environmental
                                                                                                                          consequences of new developments with little or no previous field experience to
                                                                                                                          guide the predictions. Clearly, for the ANWR Coastal Plain, the test case has
                                                                                                                          already been run at Prudhoe Bay.           Collectively, the experience of the
                                                                                                                          regulatory agencies and industry is captured in the DEIS on page 2:               @The
                                                                                                                          evidence generated during the 18 years of exploration and development at
                                                                                                                          Prudhoe Bay indicates minimal impact on wildlife          resources.   Hence, it is
                                                                                                                          reasonable to assume that development can proceed on the coastal plain and
                                                                                                                          generate similar minimal effects."

                                                                                                                          Furthermore, we support the statement, also on page 2 of the DEIS, that "most
                                                                                                                          adverse effects would be minimized or eliminated through carefully applied
                                                                                                                          mitigation, using the lessons learned and technology acquired from development
                                                                                                                          at Prudhoe Say and from construction of the Trans-Alaska Pipeline System
                                                                                                                          (TAPS).'

                                                                                                                          Trans Alaska Pipeline
                                                                                                                          Indeed, we would like to point out that all of the environmental activists'
                                                                                                                          unwarranted predictions of 15 years ago, prior to the construction -of TAPS,
                                                                                                                          have subsequently been proven false.         The demise of major caribou herds,
                                                                                                                          alterations in water quality and major losses of habitat simply have not
                                                                                                                          occurred. Conversely, the development of Prudhoe Bay and TAPS has allowed the
                                                                                                                          State of Alaska to enjoy a period of unprecedented economic prosperity in
                                                                                                                          harmony with a high quality environment and thriving wildlife populations.

                                                                                                                          Habitat and Carrying Capacity

                                                                                                                          Numerous sections of Ch   apter II and VI are devoted to discussions of research
                                                                                                                          on the behavior and movements of caribou in and around oil field development.
                                                                                                                          The main problem with this discussion and the conclusions drawn is that the
                                                                                                                          balance of the scientific community does not consider habitat to be a limiting

             Comments                                  -2-                                                                 Comments                                 -3-

             factor for any of the stages of the caribou life cycle. Therefore, conclusions                                We would also like to highlight and support the statements in Chapter VIII of
             regarding displacement of maternal cows or bulls carry little, if any,.                                       the report which conclude that "...the fish and wildlife resources of the
             significance for the continued growth and survival of the herd.        Since habitat                          Prudhoe Bay area remain extremely healthy. The Central Arctic Caribou Herd has
             is not limiting, loss of access to small portions of available habitat due to                                 increased substantially during the period that development has occurred within
             oil field development is not important.                                                                       the heart of its range.."
             We readily agree that some degree of modified behavior and displacement has
             occurred in response to habitat alterations in the Prudhoe field.             However,                        Resource Estimates
             habitat is not limiting caribou population growth for any Alaskan herds at the
             present time.    Therefore, a degree of habitat loss as a result of development                               Exxon believes the 001 applied a reasonable method in analyzing all available
             on the coastal plain will be inconsequential to growth and productivity of the                                information to develop resource estimates; therefore, we do not challenge these
             herd.                                                                                                         001 estimates or probability of discovery. However, there Is a potential for
                                                                                                                           such a wide range of interpretations among competent geologists that it would
             In the management of wildlife populations, the concept of habitat carrying                                    be fruitless to debate the accuracy or precision of the resource estimates and
             capacity is the key to defining management goals for a herd.                It is an                          discovery probabilities.     In general, DOI analysis indicates that all of the
             established fact that neither the Central Arctic Herd (CAN) nor the Porcupine                                 necessary geologic factors appear to be present for the accumulation of
             Herd approach the carrying capacity of their ranges. Indeed, Skoog (1968)                                     commercial volumes of oil and gas.        These estimated volumes are significant
             stated that, "It seems likely that the Alaskan caribou population has remained                                compared to:    their potential impact on domestic energy needs, the size of
             far below range carrying capacity and that the total habitat has never been                                   prior discoveries in the United States, and potential discoveries.
             fully occupied.     In reality, caribou populations seem to have maintained
             densities much lower than the maximum dictated by food alone, and hence the                                   In response to criticism that has been voiced, the following observations may
             reduction in total range becomes less meaningful.' Thus, we agree with Skoog's                                be helpful. The 001 resource estimates are based on substantial data that in
             early conclusion and those of Bergerud et a]. 1984, that habitat is not                                       many cases are more complete than the pre-drilling data available in other
             currently limiting the growth of the Porcupine Caribou Herd (PCH) and that the                                frontier areas, such as the Alaskan outer continental shelf and the North Slope
             loss of habitat represented by likely development in the 1002(h) area will not                                (prior to the discovery of Prudhoe Bay).       For example, ANWR is bounded on the
             impact growth or productivity of resident caribou.                                                            east and west by known petroleum provinces.       Rock outcrops on the ANWR Coastal
                                                                                                                           Plain and immediately south indicate that the necessary source and reservoir
             Caribou Calving Habitat                                                                                       rocks exist. Oil seeps and oil stained rocks on the coastal plain are direct
                                                                                                                           evidence that oil did form.          Extensive geophysical     information has been
                                                                                                                           collected and there are several companies that have proprietary well data which
             The "core calving area" is assumed to be critical to (PCH) herd demographics                                  undoubtedly are a factor in their support for exploration and development of
             and, therefore, any displacement from this area would necessarily impact
             productivity.                                                                                                 the ANWR Coastal Plain.
                                                                                                                           All of this data, though voluminous, is only indirect evidence that oil and gas
             We are concerned that the report. places undue emphasis on a core-calving                                     may exist in commercial quantities.          Collecting additional     indirect data
             concept when, in fact, the historical data for calving use do not support                                     through more concentrated geophysical surveys as suggested in Alternative B
             fidelity to a "core calving area."        Historical data for calving distribution                            will not Improve the resource estimates or reduce the uncertainty inherent in
             clearly show that the coastal plain from the Babbage River in Canada, across                                  these estimates.    A limited drilling program may yield additional information,
             the 1002(h) area to the Canning River.has been used for calving.        Thus, calving                         but most likely would not answer the two most important questions: Are oil and
             habitat is more correctly referred to as a continuum across the coastal plain                                 gas present in ANWR, and are they in large enough quantities to economically
             rather than a specific core area.                                                                             produce?   Only a well planned and comprehensive exploration drilling program
             Chapter 11, page 28, correctly points out that wide year-to-year variations in                                will be able to answer these questions.
             calving distribution can occur due to weather influences and the arrival of
             spring snow-melt.    This acknowledged effect of weather further erodes the core                              To the public, criticism of the Department's resource estimates may seem
             calving   area   concept   and   points   out  the wide    annual   variability     and                       plausible and persuasive at first glance, but in fact these criticisms are very
             adaptability of caribou. During 1983, 1984, and 1985, calving estimates varied                                misleading and grossly distort the exploration and production process.              For
             from 74% to 35% and 82%    respectively in the 1002(h) area,      These data clearly                          several reasons, it is very misleading to say that the 001 mean resource
             show the adaptability of    the PCH to yearly variations in weather conditions and                            estimate, if produced, would supply the nation with only 200 days of oil.
             point out that calving distributions do vary widely.                                                          First, all of the recoverable oil in a field is not,' and cannot, be produced in
                                                                                                                           a matter of days.     Fields produce for tens of years.      Prudhoe Bay may produce
             Therefore, we strongly recommend that conclusions regarding the relative                                      for another 30 years.     Second, the 200 days of oil is calculated by dividing
             importance of a "core calving area" concept be de-emphasized throughout the                                   the mean resource estimate by total U.S. daily consumption (approximately 16
             report.                                                                                                       million barrels).     If ANWR ever produces oil, it obviously won't offset all

              Comments                                 -4-                                                                  Comments                                -5-

              domestic production and imports for      200 days.    However, it could offset a                                                               DETAILED COMMENTS
              significant percentage of oil imports    every day for a long   time. Prudhoe Bay,
              for example, could on average offset     approximately 13% of   foreign oil imports                           Chapter II   Existing Environment
              every day for 30 years (assuming 10 billion barrels recoverable reserves and 7
              million barrels per day imports).     If the DOI estimate is accurate, the volume                             Page 2. paragraph 1:    The point from this paragraph is the bottom line
              is truly significant, considering that over 80% of all the fields ever                                        conclusion of the entire 1002(h) study.       We would like to re-emphasize our
              discovered in the United States would individually have supplied only one day's                               support for this position.      We concur that adverse effects resulting from
              worth of oil and gas.                                                                                         development can be minimized or entirely eliminated through proven mitigation
                                                                                                                            measures, lessons learned and technology acquired from the Prudhoe Bay
              It may be intuitively appealing for opponents of ANWR leasing to combine the                                  development and from construction of the Trans-Alaska Pipeline System (TAPS).
              DOI probability of discovering oil with the estimated amount of oil by saying
              there is a "...one in five chance at a 33 day supply of oil"* (600 million                                    Page 6. column 2. paragraph 5: This paragraph states that "changes in wildlife
              barrels), but this statement is incorrect.        It is intuitively appealing only                            habitat and wilderness environment could include displacement and reduction in
              because it is always appealing to have a simple explanation for a somewhat                                    the size of the Porcupine Caribou Herd.         The amount of reduction and its
              complex concept.    The 19% chance of discovery says that there is one in five                                long-term significance for herd viability is highly speculative" (emphasis
              chances that there is it 1jig one oil accumulation (or field) that can             be                         added).
              commercially developed.     (DOI says a field must be 440 million barrels          or
              larger before it will be economic to develop)       And, there are four chances    in                         We strongly agree that many of the subsequent environmental consequence        's are
              five that there aren't any fields that big in the ANWR Coastal Plain.                                         indeed highly speculative.      References to the speculative nature of these
                                                                                                                            consequences are obscure and need to be solidly emphasized for each of the
              If exploration succeeds in finding this "threshold" size field, then it            is                         environmental consequences.    As currently written, many of the conclusions of
              almost certain (95%) that at least 600 million barrels will be found. There        is                         severe impacts and concerns for caribou populations are stated as fact, when in
              a small chance (5%) that exploration will be extremely successful and find over                               actuality, they are ultra-conservative speculations not supportable by the
              9 billion barrels, but the most likely amount to be found, if exploration is                                  Prudhoe Bay or any other experience.
              successful, is about 3 billion barrels.
                                                                                                                            Inus, we ask that the authors of the report reconsider the speculative,
              Detailed review comments on the report    follow.                                                             worst-case" statements; at a minimum, we ask that the authors emphasize the
                                                                                                                            highly speculative nature of the conclusions in the environmental consequences
                                                                                                                            section by including appropriate caveats and cautionary statements to avoid
                                                                                                                            further proliferation of these speculative consequences as statements of fact.

                                                                                                                            Page 23, column 2. last paragraph, also Rage 104:      We feel that undue emphasis
              *Statement of Randall D. Snodgrass, Alaska Program Director, The Wilderness                                   is placed on the plant, Thlaspi arcticum. Although the plant is known to occur
              Society before the U. S. Department of the Interior Hearing on the Draft Arctic                               in the 1002(h) area, its status and distributional ecology are not well
              National Wildlife Refuge Coastal Plain Resource Assessment, January 9, 1987.                                  understood.   Currently, the plant has no status either as threatened or
                                                                                                                            endangered, and yet it is treated as an endangered species throughout the
                                                                                                                            report. More information must be developed on the occurrence and distribution
                                                                                                                            of this    species   before   stipulations   and   set-back   requirements   can    be
                                                                                                                            promulgated.
                                                                                                                            Page 28. paragraph 1: "The long-term maximum and minimum population of the PCH
                                                                                                                            and the carrying capacity of the PCH are unknown."
                                                                                                                            This is a key point not mentioned again in the entire report.         We agree that
                                                                                                                            the habitat and range carrying capacity for the Porcupine Caribou Herd (PCH)
                                                                                                                            are indeed unknown.    However, it is an accepted fact that the PCH and most
                                                                                                                            circum-polar caribou herds do not approach the carrying capacity of their
                                                                                                                            ranges based on food, calving habitat, Insect relief or any other habitat
                                                                                                                            basis.
                                                                                                                            Since habitat is not limiting growth, the obvious conclusion is that ample room
                                                                                                                            exists to' accommodate development interests in the 1002(h) area without
                                                                                                                            potential for impacts on the size or growth of the PCH.        Habitat and carrying

              Comments                                -6-                                                                 Comments                                -7-

              capacity relationships are fundamental tenets of caribou biology and we would                               Pages 27-33, Other mammalian species.     Population size and distribution data
              like this relationship to be much more strongly emphasized in, the net                                      for other  mammalian species in the 1002(h) area are summarized is follows:
              conclusions of the 1002(h) report.
                                                                                                                                     Species                             Population Density in 1002(h) Area
              Page 28. paragraph 3:   "The core calving area is a location to which pregnant
              cows have shown a strong fidelity as traditionally favored calving habitat.                                            Muskox                              Approx. 476 individuals
              Those concentrated calving areas used in at least 5 years during the 14-year
              study were identified as the core calving area.                                                                        Moose                               Does not exceed 25
              We disagree that use in 5 of 14 years illustrates "strong fidelity".        Instead,                                   Dall Sheep                          Very rare
              we believe that a minimum of 1/2 of the historical record is necessary to
              suggest fidelity in any sense. (See general commenton calving habitat above.)                                          Wolves                              Does not exceed 5-10 individuals
              Page 28, column 2. paragraphs 2 and 3: We are concerned that the report places                                         Arctic Foxes                        Common with annual fluctuations
              undue emphasis on a core-calving concept when, in fact, the historical data for
              calving use do not support fidelity to a "core calving area." Historical data                                          Wolverines                          Few - accurate figures are
              for calving distribution clearly show that the coastal plain from the Babbage                                                                              unavailable
              River in Canada, across the 1002(h) area to the Canning River has been used for
              calving.   Thus, calving habitat is more correctly referred to as a continuu                                           Brown Bear                          Approx. 108 individuals
              across the coastal plain rather than a specific core area.
                                                                                                                          *Population density statements   taken from 1002(h) report, pages 29-33.
              Paragraph 2 correctly points out that wide year-to-year variations       in calving
              distribution can occur due to weather influences and the arrival of spring                                  As can be  clearly seen from these data, very few individuals of these species
              snow-melt. This acknowledged effect of weather further erodes the core calving                              are found  in the 1002(h) area.    The report conclusions should be strengthened
              area concept and points out the wide annual variability and adaptability of                                 to point out the extremely low density of use for these species, and thus the
              caribou.                                                                                                    low potential for any impacts on these species due to development.
              Paragraph 3 clearly shows this annual variability.         During 1983, 1984, and                           Page 34, paragraphs 3 and 4: The report does not consider the results from the
              1985, calving   estimates varied from 74% to 35% and 82% respectively in the                                highly successful 1986 whaling season.     During this season, Kaktovik took three
              1002(h) area.   These data clearly show the adaptability of the PCH to yearly                               whales and Nuiqsut took one whale, thus filling their respective quotas             as
              variations in  weather conditions and point out that calving distributions do                               established by the International Whaling Commission.        These successful hunts
              vary widely.                                                                                                took place while offshore drilling and drillship activity were allowed to occur
                                                                                                                          durin
                                                                                                                              ry a portion of the fall bowhead migration.           We feel this experience
              Therefore, we strongly recommend that conclusions regarding the relative                                    clea y documents the compatibility of offshore drilling activity with
              importance of the Jago highlands as a core-calving area be de-emphasized                                    subsistence whaling.
              throughout the report.                                                                                      We .ask that these data be added to this section of the report.
              Page 29, paragraph 3:    Similar to calving distribution, caribou demonstrate
              wide variation in their selection and use of insect relief habitat.         Although                        Page 45, column 2:    Statistics on recreational use of the. 1002(h) area seem
              many groups move towards the coast, the report correctly points out that many                               unduly inflated.   Permit data on file with the USFWS indicate that 1983, 1984,
              also move to higher foothill and mountain areas for relief. We feel the report                              and 1985 had only 6, 33, and 33 permitted users respectively for the 1002(h)
              does not sufficiently recognize the wide variation in acceptable insect relief                              area.
              habitat, and thus places undue emphasis on the coastal areas.        We acknowledge
              the relative importance of insect relief areas.       We also point out that the                            We ask that these figures be included in the report to emphasize the low
              Prudhoe Bay development pads and roads have actually created insect relief                                  frequency of recreational use for the area.
              habitat and have not prohibited CAM access to coastal areas for insect relief.
              This section should clearly point out the favorable experience at Prudhoe Bay.                              Page 46, paragraph 2:    "The 1002(h) area is the most biologically productive
                                                                                                                          part of the Arctic Refuge for wildlife and is the center of wildlife activity
                                                                                                                          on the refuge."
                                                                                                                          This statement is contrary to the wildlife population data cited in the
                                                                                                                          preceding parts of this chapter which point out the relatively low abundance of
                                                                                                                          wildlife species and the relatively short period of use of the 1002(h) area.

             Comments                                -8-                                                                Comments                                -9-

             We suggest deletion or at least clarification and quantitative justification                               Chapter VI    Environmental Conseguences
             for this statement.                                                                                        General
             Page 46, paragraph 3: This paragraph acknowledges the esthetics of the coastal
             plain area but fails to recognize that the easternmost portion of the ANWR                                 We understand that the draft document is a legislative EIS largely following
             Coastal Plain is currently designated as wilderness.                                                       outline and contents mandated by NEPA. We would like to point out that many of
                                                                                                                        the environmental consequences predicted to occur for the five alternatives are
             Even with full leasing under Alternative A, these      30 miles of coastal plain                           based on "worst case" evaluations.     In May 1986 the NEPA-EIS guidelines were
             from the 1002(h) area east to the Canadian border and further into Canada will                             changed from a "worst case" assessment to one of "reasonably foreseeable." We
             remain as wilderness,      thus preserving the complete spectrum of arctic                                 feel that many of the major conclusions of significant effects carry the
             ecosystems represented in the Arctic Refuge.        Furthermore, we believe that                           earlier "worst case' assessment to an extreme, and thus ask that the authors
             leasing and development will not lead to a permanent loss of esthetics.                                    reconsider many of their conclusions in light of the "reasonably foreseeable"
                                                                                                                        assessment.
             We ask that acknowledgement   be give n in this section to the wilderness nature
             and designation of the coastal plain area from the Aichillk River east to the                              Page 98, paragraph 2:   We feel that the designation of USFWS Resource Category
             Canadian border.                                                                                           I for a portion of the calving habitat available to the Porcupine Caribou Herd
                                                                                                                        is inappropriate.    The 1002(h) report does not present adequate evidence to
                                                                                                                        support this designation.      Significant year-to-year variability in calving
                                                                                                                        distribution has been recorded for the Porcupine Herd all across the coastal
                                                                                                                        plain from well into Canada and west to the Canning River. Therefore, calving
                                                                                                                        habitat is more appropriately represented as a true continuum across the
                                                                                                                        coastal plain.    Thus, the "unique and irreplaceable" nature required for
                                                                                                                        designation as Resource Category I does not pertain.
                                                                                                                        Pne 100. Paragraph 2: We feel that the conclusions regarding relative impacts
                                                                                                                        trom potential discharges of reserve pit waters are overly severe and not
                                                                                                                        substantiated by actual field monitoring data or current practice information
                                                                                                                        from Prudhoe Bay areas.    It is not appropriate for DOI to cite unavailable and
                                                                                                                        unpublished data in support of these allegations.      To the contrary, available
                                                                                                                        data indicate that any impacts are extremely localized and limited to the
                                                                                                                        immediate vicinity surrounding the pit. No effects have been observed in fish
                                                                                                                        or wildlife species from active reserve pits and we have demonstrated that
                                                                                                                        adequate technology exists to close pits in an environmentally safe manner.

                                                                                                                        Page 100. parag aph 5:    This paragraph and the first item in the subsequent
                                                                                                                        Unavoidable Consequences discussion fail to recognize the normal industry
                                                                                                                        prattite of tlosing-out tfilling in) exploratory reserve pits upon completion
                                                                                                                        of the well. With proper planning, there would be no need to mobilize and haul
                                                                                                                        additional gravel. Even if it were, it would be unlikely that a new borrow pit
                                                                                                                        would be opened.
                                                                                                                        Page 103. paragraph 5:    Meehan (1986) is a draft report that contains a
                                                                                                                        significant number of errors including many conclusions on (1) gravel spray and
                                                                                                                        (2) dust.   We also have significant additional concerns over the methods used
                                                                                                                        and data interpretations. We request that all calculations, extrapolations and
                                                                                                                        conclusions based on Meehan (1986) be omitted.
                                                                                                                        Page 106. paragraph 2:   Data to support calving density in the pre-development
                                                                                                                        Prudhoe Bay area are very sketchy.      A general consensus exists that it never
                                                                                                                        was a major calving area and, therefore, any conclusions regarding reduced
                                                                                                                        calving density following development are unfounded.

              Comments                                _10-                                                                Comments

              We suggest this  paragraph and   Table VI-4 be amended to show this      area as an                                                  "Based upon the work of Dau and Cameron (1985), caribou
              historically low  density calving area. Regardless of the pre-development data,                             are displaced approximately 2 miles out from development ... within this 2 mile
              the fact remains that this herd has continued to proliferate during the period                              area of influence are about 357,000 acres of the total core calving grounds in
              of maximum development at Prudhoe Bay.                                                                      the 1002(h), area."
              14g III    ac r          The 242.000 acres of    calving habitat are proposed     for                       This statement is*a misrepresentation of the study conclusions.          In fact, the
              desjgnatj',
                        h ap 4ph 4:
                              Resource Category I in accordance with FWS mitigation policy.                               relationship between calves and distance from the road (Milne Pt.) is
                                                                                                                          statistically insignificant.     Dau and Cameron did find fewer maternal groups
              We feel strongly that this is an inappropriate designation and over-extension                               near the road than away from it, but the partial displacement was for 2
              of FWS mitigation policy.     We recommend that this designation be eliminated.                             kilometers, not 2 miles.
              See comment for page 98, paragraph 2, above.                                                                Additionally, their data show a high degree of year-to-year variability -- so
              Page 107, Paragraph 2:    Calculations of secondary modifications should be                                 much so that they had to resort to a mathematical transformation of their data
              changed to exclude any data extracted from Meehan (1986).                                                   in order to show stabilized variances so a test of significance could be run.
                                                                                                                          Their data also show that non-maternal caribou were not displaced by the road
              PAge 107, 108 a          These three pages of literature     citations discuss the                          corridor and that "partial displacement" was shown within a zone of 0-3 km.
              Prudhoe Bay c rihol, behavior studies in detail.         Data are reported which
              discuss disturbance and displacement of caribou movement patterns throughout                                The USFWS uses these data to imply that a complete displacement of all caribou
              the field as a,result of developmental activities.                                                          groups occurred out to 2 miles. This is a gross over-extrapolation of the data
                                                                                                                          and we ask that this section be rewritten to more properly reflect the study
              We readily agree that some degree of modified behavior and displacement has                                 results.
              occurred in response to habitat alterations in the Prudhoe field. However, as
              discussed in comments for page 28, paragraph 1, and again in the general                                    Regardless of the conclusions regarding partial displacement, a comparison of
              comments above, habitat is not limiting caribou population growth for any                                   the study data from 1978 to 1985 clearly documents an increased density of
              Alaskan herds at the present time.      Therefore, a degree of habitat loss as a                            animals through the period of maximum development in the area.          We feel this
              result of development on the coastal plain will be inconsequential to growth                                increased density clearly demonstrates that the CAN has continued to grow and
              and productivity of the herd.      Thus, we would like to again point out that                              thrive concurrently with the development of the oil field.           This conclusion
              habitat is not currently limiting the growth of the Porcupine Herd and that the                             must be noted in any discussion of the Dau and Cameron data.
              loss of habitat represented by likely development In the 1002(h) area will not
              impact growth or productivity of resident caribou.                                                          Page 108. paragraph 7: Repeat of comment for page 106, paragraph 4, above.
              Page 107, paragraph 5:    "Whitten and Cameron (1985) found consistently low                                Page 110. paragraph 3 and 4:     Available literature clearly shows that caribou
              numbers..."                                                                                                 can and do readily acclimate to aircraft overflight noise.               CAN animals
                                                                                                                          throughout the Prudhoe Bay area characteristically show little disturbance to
              Change to read "Whitten and Cameron (1985) found consistently low numbers of                                typical overflights.    Any perceived negative effects can be readily mitigated
              caribou and generally low percentages of calves In the Prudhoe Bay ollfield                                 by maintaining a 500 foot elevation.       Also, the experience with the central
              1978-82.  One of several explanations offered is possible displacement by                                   Alaskan Delta herd, where calving grounds are located next to overflight,
              oilfield activities."   Gavin (1979) also found very low percentages of calves                              bombing and strafing areas, further documents the acclimation of these animals
              and total caribou in this Prudhoe Bay oilfield area prior to and during initial                             to aircraft noise.
              oilfield development (1970-79).     White et al. (1975) suggests that the high
              percentage of wet and moist areas near Prudhoe Bay makes this area less                                     Thus, we ask that this section be rewritten to more properly reflect the
              attractive to caribou.                                                                                      acclimation of caribou to aircraft.

              Page 108. i)aragraph 3:  Although the absolute density for the PCH is almost 14                             Pagg 111, item no, 10:    Reduction of surface occupancy in the insect relief
              times greater than the  CAN and the Western Arctic almost 15 times greater than                             habitat to 3 miles from the coast.
              the CAN, none of these  herds approach the carrying capacity of their respective
              ranges (Bergerud et al. 1984).    Therefore, any arguments against extrapolation                            In the Kuparuk Oilfield, experience has shown that 3/4 mile of reduced
              of CAN data to the PCH based on relative densities on the fact that the PCH may                             occupancy from the coast is sufficient to ensure adequate insect relief
              occupy coastal plain habitat in higher densities than the CAN are not valid.                                habitat.   This distance appears sufficient since actual insect relief habitat
              (See comment to pages 107-109, above.)                                                                      is the coast line proper, shallow coastal water, offshore islands and coastal
                                                                                                                          bluffs -- a relatively narrow band.       Once this narrow band is provided, the
              We ask that the above point be clearly   made in the conclusions of environmental                           second requirement is to provide for relatively free movement along the
              impacts for Alternative A.                                                                                  coastline.   Elevated pipelines and other normal mitigation measures similar to

           Comments                                  -12-                                                                   Comments                                  -13-

           those applied in the Kuparuk oilfield have proven effective in allowing                                          activities in Greenland indicate    that muskox respond by a gradual and temporary
           passage.   Thus, this stipulation for an arbitrary three mile reduced surface                                    avoidance to seismic activities.
           occupancy zone should be changed to reflect the currently proven experience of
           3/4 mile.                                                                                                        We ask that this section of the report be rewritten to properly reflect the
                                                                                                                            adaptability of muskox to human     presence and thus reduce the severity of the
           Page 112,paragraph 2:     Neither the   CAH nor PCH are at carrying capacity for                                 Projected effects.
           their respective ranges and, therefore,          incremental habitat loss due to
           development of the coastal plain can be expected to result in only minimal                                       Page 122, paragraph 2:     Recently conducted extensive monitoring in the Lisburne
           displacement of the herd.     See comment pages 107-109, above.                                                  field provides data to reduce       concerns over geese and brant displacement.
                                                                                                                            Avian monitoring has shown that     a brant colony has successfully nested in this
           Page 112, paragraph 3:     "A major change in distribution ... could occur if the                                area since the 1970's with no decrease in productivity.         The density of geese
           1002(h) area were fully developed ... nearly 80% of coastal insect relief habitat                                and swans using this area has not changed from pre-construction (1983-84) to
           could be affected if development proves to be a barrier to caribou movements."                                   Post-construction (1985). Geese broods actually cross roads and pipelines into
                                                                                                                            the Lisburne area.     Brant continuously utilize a marsh at the mouth of the
           Although the conclusions of this paragraph are preceded with "could" and "if",                                   Putuligayuk River within 400m of one of the busiest roads on the North Slope.
           the statements are still gross over-generalizations with no basis in fact. The                                   Snow geese occasionally move into the Lisburne area to feed and rear young,
           extensive Prudhoe Bay experience has simply proven that these statements are                                     often immediately next to main roads.        Also, white-fronted geese often nest
           false.   The Kuparuk oilfield experience clearly shows that caribou can and do                                   close to roads.
           readily move across developmental structures. Proven mitigation measures such
           as elevated pipelines and crossings ensure that access to insect relief habitat                                  We ask that this section be modified to include these important new data from
           will remain and thus projections such as 80% loss of available relief habitat                                    Murphy et al. 1986.      nLisburne terrestrial monitoring program - 1985.            The
           are unfounded.                                                                                                   effects of the Lisburne development project on geese and swans."
           These gross generalizations have no basis in scientific fact and should be                                                   aragnph 1: We support the conclusion that only minor to negligible
           removed from the report.                                                                                         :;gfgec!2s';nncoastal fishery resources or fishery habitat will occur. Experience
                                                                                                                            at Prudhoe Bay                                                                        is
                                                                                                                                               as provided a significant volume of data to support h'
           Page 112. paragraph 4:     "...could result in major population decline and change                               viewpoint.   These data should be      reviewed and incorporated into the final
           in distribution of 20-40 percent... this estimate is uncertain."                                                 report.
           Although this projection is followed by the uncertainty statement, we feel                                       Page 126, column-2. Paragrauh_5:     We  also support the    conclusions of minor to
           strongly that this statement is completely unfounded and unsupportable.               No                         negligible impacts on endangered and     threatened animal species such as bowhead
           data are provided to support this estimate and we are given no basis for its                                     and grey whales and the peregrine falcon. We feel that the transient nature of
           determination. This paragraph substantially undermines the credibility of the                                    their presence on the coastal plain and the history of developmental
           assessment of caribou impacts in the 1002(h) report.               We conclude from                              interaction in the Prudhoe Bay field clearly demonstrate the lack of meaningful
           substantial scientific data that the estimate is nothing more than pure                                          impacts on these species.
           speculation and urge that the entire paragraph be deleted from the final
           report.                                                                                                          Page 131, column 2. paragraph.1-      We would like to underscore the relatively
                                                                                                                            low value of the coastal plain as recreational habitat.               History of use
           Page 114. paragraphs I and 2: We feel that the conclusions regarding potential                                   indicates that only a handful of individuals have actually utilized the coastal
           developmental effects on muskox are unnecessarily severe and unfounded.            While                         plain for recreation, either hunting, fishing or camping.             It is extremely
           it is true that very little data characterizing muskox responses to oilfield                                     expensive to reach the area; a trip from the Lower 48 costs thousands of
           development are available, it is also true that the muskox has shown ready                                       dollars and requires special custom air charter flights.         Wet and moist ground
           adaptability to human presence and has even been semi -domesticated in several                                   conditions make hiking unenjoyable during the 8-10 week "summer." Extreme cold
           areas.    This adaptability to human presence will significantly reduce the                                      and darkness during a large part of the year further reduce recreational use.
           worst-case conclusions implicated in the DEIS.
                                                                                                                            We ask that these perspectives be added to this section, of the report.
           Several experimental farming programs have been successfully initiated in                                        Page 129, column 2. paragraph 4:      Based    on  Ithe  preceding    conclusions     of
           Alaska and Canada to domestically raise muskox for their high quality qiviut,                                    negligible to minimal      effects on wildlife populations as           a result      of
           or underwool, to be used in the knitting industry.                  Obviously, their
           adaptability to constant human presence in these situations significantly                                        development,   there   remains   no reason to assume that major effects               on
           reduces concerns over occasional and distant disturbances from developmental                                     subsistence uses will occur.     Therefore, we ask that this paragraph be deleted.
           interests.    Limited   observations of muskox response to oil              exploration
                                                                                                                            Page 134, paragraphs   6 and 7: See comment above for-page 112, paragraph 4.

           Comments                                   -14-                                                                   Comments                                   -15-

           Page 143, naragraph 6:     See comment above for page 6, column 2, paragraph 5.                                         Comment:   Stipulations 8, 9, and 10 appear to prefer buried pipelines.
                                                                                                                                   Burial of pipelines is unnecessary where elevation and ramping are used to
                                                                                                                                   accommodate    movements     of    animals.      Buried    pipelines     are     not
                                                                                                                                   environmentally preferred on the North Slope due to permafrost. Moreover,
           Pages 145-147, Summary of Recommended Mitigation                                                                        burying causes more environmental impact initially and during abandonment.
                                                                                                                                   Suggest adopting the current SOA policy: To minimize impacts on caribou,
           Stipulation 2: Design all bridges and culverts to handle at least 50-year                                               pipelines must be consolidated to the extent feasible and must be
                 flood events.                                                                                                     designed,   sited and constructed to allow safe passage of caribou.
                                                                                                                                   Adequate elevation, ramping or burial of pipelines will be required In
                 Comment: Insert "permanent" before the word bridges.                                                              areas identified by (Department of Fish and Game) USFWS as important
                                                                                                                                   caribou movement zones.
           Stipulation 3: Use ice or gravel-foam-timber pads, where feasible, for                                            Stipulation 11: Separate roads and pipelines 400-800 feet, depending on
                 exploration wells.                                                                                                terrain, in areas used for caribou crossing.
                 Comment: There may be limited use for ice pads; however, the choice of
                 pad material must ensure a safe and successful completion of the                                                  Comment:    The combination of roads near pipelines is considered a
                 operations plan.                                                                                                  deterrent to caribou crossing, primarily when there is high human use
                                                                                                                                   (traffic) of the road, therefore, it is unnecessary to have all roads
           Stipulation 5: Prohibit off-road vehicle use within 5 miles of all pipelines,                                           separate from pipelines. This policy conflicts with the basic desire to
                 pads, roads, and other facilities, except by local residents engaged in                                           consolidate facilities.     A preferable wording of this stipulation may be
                 traditional uses or if otherwise specifically permitted.                                                          separate high use trunk roads and pipelines 400-800 feet, ..."
                 Comment:    Prohibiting all activities in all seasons is unnecessarily                                      Stipulation 12:    Restrict surface occupancy in the zone from the coastline
                 restrictive. This stipulation should be limited to summer season only and                                         inland 3 miles to marine facilities and infrastructure necessary                  to
                 not be applied to research, surveying, seismic work, etc. approved by                                             support activities outside the restricted zone.
                 USFWS.                                                                                                            Comment:   This restriction could preclude access to and development              of
           -Stipulation 6: Limit oil exploration, except surface geology studies, to                                               significant reserves.      Temporary exploration facilities and essential
                 November I-May I (exact dates to be determined by Refuge Manager). Cease                                          production facilities should be allowed on a site-specific basis.
                 exploration activities and remove or store equipment at an approved site
                 by May 15. Local exceptions may be made.                                                                    Stipulation 14: Close areas within 3/4 mile of high-water mark of specified
                                                                                                                                   water courses to permanent facilities and limit transportation crossings.
                 Comment:   Seasonal restriction might be appropriate for intensive human                                          Gravel removal may occur on a site-specific basis.
                 activity such as construction but this stipulation should allow activities
                 less likely to interfere with animal behavior to continue. Activities in                                          Comment:   A 3/4 mile buffer is an excessive restriction.          Maximum effort
                 this category would be those largely confined to the drill pad to include                                         to protect critical riparian habitat should be required; however,
                 drilling and testing of wells and minimum helicopter airlift support.                                             essential production facilities should be allowed on a site-specific
                 When recognizing that such prohibition cannot reason:bly be applied during                                        basis.
                 any subsequent development activities, USFWS shoul     d    low those activities
                 to be conducted as part of an approved research program to determine                                        Stipulation 21: Close area within 5 miles of development and associated
                 actual effects on wildlife and to develop better mitigation techniques If                                         infrastructure to hunting, trapping and discharge of firearms.
                 needed for development.     Restriction on drilling and testing could cause
                 expl oratory wells to take two or more years to complete, which extends                                           Comment: Subsistence trapping without firearms should be allowed.
                 environmental exposure, may compromise well safety and control, and
                 significantly increases the cost of the well.                                                               Stipulation 23: Define range of the candidate plant Thlaspi arcticum.
                                                                                                                                   Minimize surface occupancy in immediate vicinity of areas identified as
           Stipulations 8, 9 & 10:     Elevate pipelines to allow free passage of caribou in                                       supporting the.plant.      Position pads, collecting lines, and associated
                 areas without ramps or buried sections.                                                                           roads at least 1/2 mile from candidate plant locations.
                 Place ramps over pipelines at natural crossings or where development tends                                        Comment:    It appears that a feasible and prudent effort to avoid
                 to funnel animals.                                                                                                significant disturbance of the plant would be reasonable; 1/2 mile buffer
                                                                                                                                   appears excessive and unnecessary.
                 Bury pipelines where possible.

           Comments                                   -16-                                                                 Comments                                    -17-

           Stipulation 24:    Construct docks and causeways so that fish movements are not                                                         STIPULATIONS FOUND IN THE USFWS/ASRC
                 impeded and  lagoon water chemistry is basically unchanged.                                                                        AGREEMENT STIPULATIONS (APPENDIX 2)
                 Comment:    Policy needs to focus on potential impacts; suggest wording                                   Stipulation:      'Exploration activities will be tupportcd         only by Ice ro.,d-.,
                 and lagoon water chemistry not be altered to a degree which causes                                              winter trails, existing road systems-and       air service.
                 significant  adverse effects on marine populations."                                                            Comment: This stipulation' should recognize the need for barges and boats
           Stipulation 25:    Establish time and area closures or restrictions on surface                                        for marine support.
                 activity in areas of wildlife concentration during muskox calving, April
                 15-June 5;   caribou calving, May 15-June 20; caribou insect harassment,                                  Stipulation:      The operator shall not significantly alter the banks of streams,
                 June 20-August 15;      snow goose staging, August 20-September 27 and                                          rivers, or lakes while conducting exploration activities.             Crossings of
                 overwintering and spawning.                                                                                     stream, river, or lake banks shall utilize a low angle approach or, if
                                                                                                                                 appropriate,    snow bridges.      If snow bridges are utilized for bank
                 Comment:    This stipulation    should specifically exclude restrictions on                                     protection, they shall be free of dirt and debris and shall be removed
                 activities confined to an      exploration drill pad such as drilling and                                       after use or prior to breakup each year, whichever occurs first.
                 testing being conducted in conjunction with a USFWS approved research
                 program to determine effects on evaluation (key) species.                                                       Comment:    The need for the removal of ice bridges after use            or before
                                                                                                                                 breakup is not readily apparent.        If the intent is to prevent flood,',ng,
           Stipulation 26: Acquire authority to establish time and area closures           and                                   the stipulation should so state, and allow alternatives such as selective
                 minimum aircraft altitude of 2000 feet above ground level (AGL) during                                          or partial removal of ice bridges.
                 muskox and caribou calving and caribou insect harassment, April 154ugust
                 15; and snow, goose staging, August 20-September 25.         At other times the                           Stipulation:      Reserve pits shall be rendered impermeable by a design of the
                 minimum al  titude generally will be 1000 feet AGL over areas of animal                                         operator's choice, other than reliance upon permafrost.
                 concentrations.                                                                                                 Comment:    For below-grade (excavatedl desioned nits, permafrost provides
                 Comment: it is unnecessary to have time and area closures in addition to                                        an impermeable barrier.      Suggest deleting the words "other than reliance
                 minimum altitude restrictions.                                                                                  upon permafrost.* This stipulation should defer to existing reserve pit
                                                                                                                                 regulation in this matter.

                                                                                                                           Stipulation:      All hydrocarbons discharged into flare and relief pits shall be
                                                                                                                                 removed and properly disposed of as soon as practicable during the winter
                                                                                                                                 but prior to spring breakup, except that during periods of thaw, such
                                                                                                                                 removal shall occur within 72 hours of discovery.

                                                                                                                                 Comment:    This language from the COE AAP Special condition C is under
                                                                                                                                 revision by the COE to read:        "Hydrocarbons discharged into relief pits,
                                                                                                                                 flare pits, or reserve pits shall be contained and properly disposed of as
                                                                                                                                 soon as practicable.       Removal shall minimize waste generation and all
                                                                                                                                 hydrocarbons which are removed shall be disposed of in a manner consistent
                                                                                                                                 with all pertinent regulations."

                                                                                                                           stipulation:      When an exploratory well bottom hold depth will not exceed
                                                                                                                                 10,000 feet true vertical depth, the well shall be drilled from an ice pad
                                                                                                                                 with piling support for the drill rig; and
                                                                                                                                 Comment:    Stipulations should allow the use. of pad material which will
                                                                                                                                 ensure a safe and successful completion of the overall exploratory
                                                                                                                                 operations plan. Bottom hole depth may not be the most important criteria
                                                                                                                                 in determining a proper pad. This stipulation should be reworded to read:
                                                                                                                                 "When an exploratory well program       can be safely accomplisho. from an ice
                                                                                                                                 pad, it is preferred that the well be drilled from an ice pad with piling
                                                                                                                                 support for the drill rig ...

            Comments                                                                                                   Comments                                _19-

            Stipulation:    The Regional Director is authorized to designate within ASRC                                    undertaken in accordance with the provisions of the above -referenced
                 Lands special caribou calving and post-calving special areas that will be                                  Guidelines, to the extent practicable.
                 closed to all exploration activities for such periods from May I through
                 August  31 of each year as are designated by the Regional Director to                                      Comment: Suggest language consistent with 1002 Report Stipulation 7 which
                 ensure  that exploration activities do not significantly adversely affect                                  limits the application of the prohibition to major fish-bearing rivers.
                 caribou calving and post-calving activities, Including but not limited to,
                 relief  from insects.   The Regional Directory may shorten the period of
                 closure or reduce the area closed if it is determined that caribou are not
                 using the area.

                 coment, Special area stipulations should be modified to allow continued
                 exploration drilling and testing while conducting research programs to
                 determine the effects on these species (see our comments on Stipulation 06
                 of the 1002h report).
            Stipulation.    The Regional Director is authorized to designate within ASRC
                 Lands specific snow goose staging special areas that will be closed to all
                 exploration activities for such periods from August 20 through September
                 10 of each year as are designated by the Regional Director to ensure that
                 exploration activities do not significantly adversely affect snow goose
                 staging.   The Regional Directory may shorten the period of closure or
                 reduce the area closed If it is determined that snow geese are not using
                 the area.

                 Comment: Special area'stipulations should be modified to allow continued
                 exploration drilling and testing while conducting research programs to
                 determine the effects on these species (see our comments on Stipulation 06
                 of the 1002h reprrt).
            Stipulation:    The Regional Director is authorized to designate within ASK
                 Lands specific waterfowl nesting habitat special areas that will be closed
                 to all exploration activities for such periods from May 25 through August
                 I of each year as are designated by the Regional Director to ensure that
                 exploration activities do not significantly adversely affect waterfowl
                 nesting habitat, The Regional Director may shorten the period of closure
                 or reduce the area closed If It is determined that waterfowl nesting is
                 not occurring within the area.

                 Comment: Special area stipulations should be modified to allow continued
                 exploration drilling and testing while conducting research programs to
                 determine the effects on these species (see our comments on Stipulation 06
                 of the 1002h report).
            Stipulation:    Sand and gravel extraction, processing or storage sites shall
                 not be located within the active floodplains of water courses as defined
                 in the Gravel Removal Guidelines Manual for Arctic and subArctic
                 Floodplains (WSFWS 1980), unless there are no feasible and prudent,
                 alternatives.    In the event that there is no feasible and prudent
                 alternative to sand and gravel extraction, processing or storage within
                 the active floodplain of water courses, and in the event that such sand
                 and gravel extraction,    processing or storage otherwise satisfies the
                 environmental protection safeguards of these stipulations. sand and gravel
                 extraction, processing     or storage in active floodplains shall           be

                                                                                                                          My name is Don Cornett.     I am the Alaska Coordinator for Exxon Company, U.S.A.
                                                                                                                          here in Anchorage.     I am pleased to offer these comments on the draft 1002(h)
                                                                                                                          report and recommendation to Congress.       Exxon assisted in the development and
                                     COMMENTS BY EXXON COMPANY, U.S.A.                                                    endorses the detailed AOGA comments.       In addition to those comments, I would
                                                                                                                          like to offer Exxon's perspective on the report and recommendation.
                                  ARCTIC NATIONAL WILDLIFE REFUGE, ALASKA                                                 Exxon strongly supports the Department of Interior's proposal that the Congress
                                                                                                                          authorize the Secretary to lease the entire 1002(h) area for oil and gas
                                     COASTAL PLAIN RESOURCE ASSESSMENT                                                    exploration and development.      We agree with the report's overall conclusion
                                                                                                                          (page 2) that "Development can proceed on the coastal plain and generate
                                                                                                                          similar minimal effects" to those experienced at Prudhoe Bay and TAPS.

                                                                                                                          @Our endorsement of the 001 conclusions regarding negligible or minimal impacts
                                                                                                                          on the environment and resident biota is based on the following points:

                        Report and Recommendation to the Congress of the United                                           Prudhoe Say and TAPS
                          States and Legislative Environmental Impact Statement                                           The environmental experience gained from development of the coastal plain at
                                                                                                                          Prudhoe Bay demonstrates that oil field development can co-exist with wildlife
                                                                                                                          resources.    Experience with carefully applied mitigation measures as well as
                                                                                                                          innumerable lessons learned and technology developed at Prudhoe Bay and from
                                                                                                                          construction of the Trans-Alaska Pipeline         System (TAPS) have proven that
                                                                                                                          adverse effects on the environment can be minimized or eliminated.
                                              Anchorage, Alaska
                                              January 5, 1987                                                             Caribou
                                                                                                                          We agree that the Porcupine Caribou Herd is an international resource and that
                                                                                                                          proven mitigation measures should be applied to ensure minimal effects of
                                                                                                                          development on continued growth of the herd.          We would like to caution the
                                                                                                                          report's authors against unnecessarily drawing "worst case" conclusions.             Our
                                                                                                                          experience on the coastal plain at Prudhoe Bay with the Central Arctic Herd has
                                                                                                                          proven oil field development can co-exist with a healthy and rapidly expanding
                                                                                                                          herd.   Over 15 years of monitorin        data have clearly shown that even with
                                                                                                                          development of the largest oil fiM in the U.S., the Central Arctic.Herd has
                                                                                                                          continued to proliferate and that sufficient habitat for calving, summer range
                                                                                                                          and insect relief still exists. Similarly, the Porcupine Caribou Herd, as with
                                                                                                                          the majority of circum-polar caribou herds, does not now approach the carrying
                                                                                                                          capacity of its range.      Thus, we believe that ample habitat is available to
                                                                                                                          accommodate oil field development and continued growth of the Porcupine Caribou
                                                                                                                          Herd.

            1002(h) Report Exxon Comments             -2-                     January 5, 1987

            Qlher Fish and Wildlife Species
            As noted in the draft EIS report, extensive field monitoring of the other fish                                                   COMMENTS BY EXXON COMPANY, U.S.A.
            and wildlife species present on the coastal plain and immediately offshore
            provides ample data to support the conclusions of minimal to negligible effects
            on these species as a result of proposed leasing.                                                                             ARCTIC NATIONAL WILDLIFE REFUGE, ALASKA

                                                                                                                                             COASTAL PLAIN RESOURCE ASSESSMENT
            Mitigat

            We would like to caution the Department that the economic cost of developing
            any oil and gas reserves in the coastal plain will be high and the mitigating
            measures imposed can play a large role In the costs,             We believe that
            reasonable measures can and should be Implemented to protect the resources.
            some of the proposed measures. however, are unnecessary to protect fish and
            wildlife resources and could result in significantly increased costs, delays in                                      Report and Recommendation to the Congress of the United
            exploration and development, and reduced recovery of any oil and gas.
                                                                                                                                   States and Legislative Environmental Impact Statement
            We are particularly concerned with seasonal prohibitions on exploratory
            activities and with broad prohibitions of surface facilities on large areas of
            land, such as along the coast or major rivers. Over the past IS years, Exxon
            has drilled 13 exploratory wells on the coastal plain in the Point Thomson and
            Canning River areas, immediately to the west of the 1002(h) area. A lot of
            this activity was conducted during the summer and there were no significant                                                              Washington, D.C.
            adverse effects to fish and wildlife resources or their habitat.               This
            exploration experience clearly demonstrates that the technology and operating                                                            January 9, 1987
            practices exist to explore for oil and gas resources in a safe and
            environmentally sound manner in the ANWR Coastal Plain throughout the year.

            In summary, we would like to acknowledge the five years of extensive field work
            by over 50 professional scientists in the DOI who stand behind the Secretary's
            recommendation in this report. Additionally, Exxon's experience on the Arctic
            Coastal Plain in the Prudhoe Bay and Point Thomson areas confirms our
            confidence that leasing, exploration and development of the ANWR Coastal Plain
            can proceed without significant deleterious effects to the environment or
            wildlife resources.

            Thank you for the opportunity to comment.

                                                                                                                            100.2(h) Report Exxon Comments            -2-                         January 9, 1987

                                     COMMENTS BY EXXON COMPANY, U.S.A.                                                      NATIONAL NEE
                                Arctic National Wildlife Refuge, Alaska,                                                    Next I'd like to address the need for timely development of domestic energy
                                     Coastal Plain Resource Assessment                                                      reserves.  Exxon believes it is in this country's best interest to diligently
                    Report and Recommendation to the Congress of the United States                                          explore potentially significant resources.      We applaud the report drafters for
                             and Legislative Environmental Impact Statement                                                 recognizing the vital contributions that ANWR could make to the nation, namely:
                                                                                                                            reducing our increasing dependency on foreign oil; generating positive economic
                                              Washington, D. C.                                                             impacts in Alaska as well as the Lower 48 states; and improving our long term
                                               January 9, 1987                                                              balance of trade.      Of equal signiffcancei we concur with the report's
                                                                                                                            conclusion that the exploration process should start now, since even under an
                                                                                                                            accelerated schedu 1e, production of any commercial resources would not start
                                                                                                                            Until at least the.year 2000. By that time, according to the most recent NPC
                                                                                                                            forecastj the United States will almost certainly be importing well over half
            My name is Mike Johnson.     I am the Manage  .r of Exxon Company, U.S.A.'-s Offshore                           of the oil being consumed.       Also, by the year 2000, Alaska's North Slope
            and Alaska Exploration Division.      It is my pleasure to be here today to offer                               production, according to the Alaska Department of Revenue forecast, will likely
            these comments.                                                                                                 have declined from approximately 2 million BOPO to about 600,000 BOPD. As you
                                                                                                                            may be aware, the 2 million barrels now produced from the North Slope account
                                                                                                                            for nearly 20% of all U.S. production         Certainly ANWR by itself could not
            EXXON'S POSITION                                                                                                fully offset domestic production declin@,     but it could significantly mitigate
                                                                                                                            it. At the same time, it is unlikely that      the decline can be reversed by only
            Exxon strongly endorses the Department's        preferred recommendation      of full                           exploring other frontier orhigh potential     areas to the exclusion of ANWR.
            leasing pf.the.coastal-plain of the Arctic National Wildlife Refuge (ANWR).          It
            is our Judgment that this recommendation is well supported, and we very much                                    For examplet the LaIlTornia OCS appears attractive, but access is obstructed.
            oppose  the other alternatives for three very important reasons.            First, we                           The deepwater GOM holds promise, but exploration is incomplete and production
            believe there may be significant undiscovered hydrocarbon potential in the 1002                                 technology will be expensive and needs further refinement.          And much of the
            area.  Second, the national need for oil and gas is best served by timely                                       Beaufort and Chukchi Seas offshore the North Slope may not ultimately be viable
            @assessing and developing that potential.     And third, we are confident that the                              due to the harsh environmental conditions and resultant high operating costs.
            environment can be appropriately protected while industry explores and,
            hopefully, develops the area.      In my remarks today I would like to expand on
            each one of these three points.                                                                                 ENVIRONMENTAL
                                                                                                                            Finally, we recognize the significance of the existing ANWR environment.             We
            HYDROCARBON POTENTIAL                                                                                           also recognize that exploration and development of the ANWR Coastal Plain can
                                                                                                                            only proceed in a manner that ensures appropriate safeguards for the
            Turning first to that of hydrocarbon potential, we know that the ANWR Coastal                                   environment, including the fish, wildlife and their habitat.          Data collected
            Plain lies between Prudhoe Bay, the largest oil field in North America to the                                   from numerous impact studies on Prudhoe Bay facilities and the 800-mile long
            west, and the numerous Canadian oil and gas fields in the Mackenzie River Delta                                 TransAlaska Pipeline, argue, however, for a more optimistic estimate of the
            and Beaufort Sea to the east.    Our analyses suggests that the geologic                                        potential environmental impacts from ANWR development than indicated in the
            conditions found in these major oilfields also exist in 1002 area.                 This                         1002(h) report.    Independently, our experts feel that the expressed impact
            judgment, though certainly not definitive, is based on a spectrum of hard data                                  concerns regarding caribou calving, etc., represent "worst case" and thus
            and is thus more than mere speculation.       We have analyzed well control to the                              improbable scenarios, rather than the "most likely" outcomes which existing
            west and east, and, on the ANWR Coastal Plain itself, we have studied surface                                   data indicate would be-much less severe and of shorter duration.           We believe
            outcrops, oil seeps and seismic data.     We believe that the 1002 area is indeed                               that the safe history of oil and gas activities on Alaska's North Slope and in
            one of the few highly prospective untested frontiers left in the United States                                  refuges elsewhere in this country, conclusively indicates that environmental
            with the potential for substantial oil volumes that in a high side case could                                   conservation and mineral resource development are compatible.          The companies
            be on a par with Prudhoe Bay.                                                                                   associated with these operations,       including Exxon, have worked hard and
                                                                                                                            successfully to develop the expertise and technology to properly act in this
                                                                                                                            environment. Common sense directs that industry's actions would be equally
                                                                                                                            responsible in the ANWR Coastal Plain.

          1002(h) Report Exxon Lomments          -3-                      January 9, 1987

          To sum up. Exxon feels that on balance, the data and analyses argui
          conclusively for the recommended alternative of full leasing. The incentives
          high potential and national need - are there, and the downside of environmental
          impact is limited. Other alternatives only postpone an already lengthy process
          of discovery and development which the nation's interest dictates must proceed
          today rather than tomorrow.  The no-action alternative is clearly unacceptaWe
          because it is incompatible with energy needs and proven environmental
          compatibility.
          It is our hope that this matter be ultimately judged on its merits, for if it
          is, we are confident the best interests of our country, and thus those of all
          of us, its citizens, will be properly served.          I am grateful for the
          opportunity to speak.     I hope that my support will contribute to the
          implementation of the D01's recommendation of full leasing of the ANWR Coastal
          Plain.

    						COMMENTS BY EXXON COMPANY, U.S.A.

    DO YOU WANT TO MAKE PUBLIC COMMENTS?

    If you would like to speak at the hearing today, please fill in the blanks
    below and turn it in to one of the Fish and Wildlife Staff members present.
    You need not complete this sheet to sumbit written comments.  Thank you.

    Please print
    Name	Don E. Cornett
    Mailing Address	P.O. Box 6601
    			Anchorage, Alaska 99501

    Check appropriate box below:

    	I am here to offer my own views.
    			-or-
    	I am speaking for Exxon Co USA
    				(please enter name of organization you represent)

    					ARCTIC NATIONAL WILDLIFE REFUGE, ALASKA
    						COASTAL PLAIN RESOURCE ASSESSMENT

    				REPORT AND RECOMMENDATION TO THE CONGRESS OF THE UNITED
    					STATES AND LEGISLATIVE ENVIRONMENTAL IMPACT STATEMENT

    							ANCHORAGE, ALASKA
    							JANUARY 5, 1987

                       MY NAME is DON CORNETT. I AM THE ALASKA COORDINATOR FOR EXXON COMPANY,
                       U.S.A. HERE IN ANCHORAGE. I AN PLEASED TO OFFER THESE COMMENTS ON THE
                       iDRAFr 1002(H) REPORT AND RECOMMENDATION TO CONGRESS. EXXON ASSISTED IN T11E
                       DEVELOPMENT AND ENDORSES THE DETAILED AOGA COMMENTS. IN ADDITION TO THOSE
                       COMMENTS, I WOULD LIKE TO OFFER EXXON'S PERSPECTIVE ON THE REPORT AND

                       RECOMMENDATION.

                       EXXON STRONGLY SUPPORTS THE DEPARTMENT OF INTERIOR'S PROPOSAL THAT THE
                       CONGRESS AUTHORIZE THE SECRETARY TO LEASE THE EtmRE 1002(H) AREA FOR OIL
                       AND GAS EXPLORATION AND DEVELOPMENT. WE AGREE WITH THE REPORT'S OVERALL
                       CONCLUSION (PAGE 2) THAT "DEVELOPMENT CAN PROCEED ON. THE COASTAL PLAIN AND
                       GENERATE SIMILAR MINIMAL EFFECTS" TO THOSE EXPERIENCED AT PRUDHOE BAY AND
                       TAPS.

                       OUR ENDORSEMENT OF THE DOI CONCLUSIONS REGARDING NEGLIGIBLE OR MINIMAL

                       IMPACTS ON THE ENVIRONMENT AND RESIDENT BIOTA IS BASED ON THE FOLLOWING

                       POINTS:

                       PRUDHOE BAY AND TAP

                       THE ENVIRONMENTAL EXPERIENCE GAINED FROM DEVELOPMENT OF THE COASTAL PLAIN
                       AT PRUDHOE BAY DEMONSTRATES THAT OIL FIELD DEVELOPMENT CAN CO-EXIST WITH
                                                            2 -

                        WILDLIFE RESOURCES. EXPERIENCE WITH CAREFULLY APPLIED MITIGATION MEASURES
                        AS WELL AS INNUMERABLE LESSONS LEARNED AND TECHNOLOGY DEVELOPED AT PRUDHOE
                        BAY AND FRO14 CONSTRUCTION OF THE TRANs-ALAsKA PIPELINE SYSTE14 (TAPS) HAVE
                        PROVEN THAT ADVERSE EFFECTS ON THE ENVIRONMENT CAN BE MINIMIZED OR
                        ELIMINATED.

                        CARIBOU

                        WE AGREE THAT THE PORCUPINE CARIBOU HERD is AN INTERNATIONAL RESOURCE AND
                        THAT PROVEN MITIGATION MEASURES SHOULD BE APPLIED TO ENSURE MINIMAL EFFECTS
                        OF DEVELOPMENT ON CONTINUED GROWTH OF THE HERD. WE WOULD LIKE TO CAUTION
                        THE REPORT'S AUTHORS . AGAINST UNNECESSARILY DRAWING          "WORST CASE"
                        CONCLUSIONS. OUR EXPERIENCE ON THE COASTAL PLAIN AT PRUDHOE BAY WITH THE
                        CENTRAL ARCTIC HERD HAS PROVEN OIL FIELD DEVELOPMENT CAN CO-EXIST WITH A
                        HEALTHY AND RAPIDLY EXPANDING HERD. OVER 15 YEARS OF 14DNITORING DATA HAVE
                        CLEARLY SHOWN THAT EVEN WITH DEVELOPMENT` OF THE LARGEST OIL FIELD IN THE
                        U.S.# THE CENTRAL ARcTxc HERD HAS CONTINUED TO PROLIFERATE AND THAT
                        SUFFICIENT HABITAT FOR CALVING# SUMMER RANGE AND INSECT RELIEF STILL
                        EXISTS. SIMILARLY, THE PORCUPINE CARXBou HERD, As WITH THE MAJORITY OF
                        CIR-CUM-POLAR CARIBOU HERDS, DOES NOT NOW APPROACH THE CARRYING CAPACITY OF

                                                            148

                     ITS RANGE. THUS,   WE BELIEVE THAT AMPLE HABITAT IS AVAILABLE TO ACCOMMODATE
                     OIL FIELD DEVELOPMENT AND CONTINUED GROWTH OF THE PORCUPINE CARisou HERD.

                     OTHER FISH AND WILDLIFE SPECIE

                     As NOTED IN THE DRAFT EIS REPORT, EXTENSIVE FIELD MONITORING OF THE OTHER
                     FISH AND WILDLIFE SPECIES PRESENT ON THE COASTAL PLAIN AND IMMEDIATELY

                     OFFSHORE PROVIDES AMPLE DATA .. TO SUPPORT THE CONCLUSIONS OF MINIMAL TO

                     NEGLIGIBLE EFFECTS ON THESE SPECIES AS A RESULT OF PROPOSED LEASING.

                     l4xTxGATiNG MEASURES

                     WE WOULD LIKE TO CAUTION THE DEPARTMENT THAT THE ECONOMIC COST OF DEVELOP-
                     ING ANY OIL AND GAS RESERVES IN THE COASTAL PLAIN. WILL BE HIGH       AND THE
                     MITIGATING MEASURES IMPOSED-CAN PLAY A LARGE ROLE IN THE COSTS. WE      BELIEVE

                     THAT REASONABLE MEASURES CAN AND SHOULD BE IMPLEMENTED TO PROTECT THE
                     RESOURCES.   SOME OF THE PROPOSED MEASURES, HOWEVER, ARE UNNECESSARY TO
                     PROTECT FISH AND WILDLIFE RESOURCES AND COULD RESULT IN SIGNIFICANTLY
                     INCREASED COSTS, DELAYS IN ExpLoiwrxom AND DEVELOPMENT, AND REDUCED
                     RECOVERY OF ANY OIL AND GAS.

                                                            4 -

                       WE ARE PARTICULARLY CONCERNED WITH SEASONAL PROHIBITIONS ON EXPLORATORY
                       ACTIVITIES AND WITH BROAD PROHIBITIONS OF SURFACE FACILITIES ON LARGE AREAS
                       OF LAND, SUCH AS ALONG THE COAST OR MAJOR RIVERS. OVER THE PAST.15 YEARS,
                       EXXON HAS DRILLED 13 EXPLORATORY WELLS ON THE COASTAL PLAIN IN THE Pr
                       THOMSON AND CANNING RIVER AREAS, IMMEDIATELY TO THE WEST OF THE 1002(H)
                       AREA. A LOT OF THIS ACTIVITY WAS CONDUCTED DURING THE SUMMER AND THERE

                       WERE NO SIGNIFICANT ADVERSE EFFECTS TO FISH AND WILDLIFE RESOURCES OR THEIR
                       HABITAT. THIS EXPLORATION EXPERIENCE CLEARLY DEMONSTRATES THAT THE TECHHO-

                       LOGY AND OPERATING PRACTICES EXIST TO EXPLORE FOR OIL AND GAS RESOURCES IN
                       A SAFE AND ENVIRONMENTALLY SOUND MANNER IN THE AM COASTAL PLAIN THROUGH-

                       OUT THE YEAR.

                       IN SUMMARY, WE WOULD LIKE TO ACKNOWLEDGE THE 5 YEARS OF EXTENSIVE FIELD
                       WORK 13 Y OVER 50 PROFESSIONAL SCIENTISTS IN THE DOI WHO STAND BEHIND THE
                       SECRETARY'S RECOMMENDATION IN THIS REPORT. P)DITIOHALLY, EXXON'S EXPER-
                       IENCE ON THE ARCTIC COASTAL PLAIN IN THE PRUDHOE SAY AND PT. THOMSON AREAS
                       CONFIRMS OUR CONFIDENCE THAT LEASING, EXPLORATION AND DEVELOPMENT OF THE
                       AM COASTAL PLAIN CAN PROCEED WITHOUT SIGNIFICANT DELETERIOUS EFFECTS TO

                       THE ENVIRONMENT OR WILDLIFE RESOURCES.

                       THANK YOU FOR THE OPPORTUNITY TO COMMENT.
                       DEC/153
                                                           'W9

                                                                                                                         Comments                                  -2-                          January 9, 1987

                                                                                                                         conditions found in these major oilfields also exist in 1002 area.                 This

                                                                                                                         judgment, though certainly not definitive, is based on a spectrum of hard data

                                    COMMENTS BY EXXON COMPANY, U.S.A.                                                    and is thus more than mere speculation. We have analyzed well control to the

                                Arctic National Wildlife Refuge, Alaska,                                                 west and east, and, on the ANWR Coastal Plain itself, we have studied surface
                                    Coastal Plain Resource Assessment
                    Report and Recommendation to the Congress of the United States                                       outcrops, oil seeps and seismic data. We believe that the 1002 area is indeed
                             and Legislative Environmental Impact Statement
                                                                                                                         one of the few highly prospective untested frontiers left in the United States
                                             Washington, D. C.
                                               January 9, 1987                                                           with the potential for substantial oil volumes thatin a high side case could
           My name is Mike Johnson.     I am the Manager of Exxon Company, U.S.A.'s Offshore                             be on a par with Prudhoe Bay.
                                                                                                                         (PAUSE)
           and Alaska Exploration Division.      It is my pleasure to be here today to offer
                                                                                                                         NATIONAL NEED
           these comments.
                                                                                                                         Next I'd like to address the need for timely development of domestic energy
           EXXON'S POSITION
                                                                                                                         reserves.  Exxon believes it is in this country's best interest to diligently
           Exxon strongly endorses the Department's preFen 4 recommendation of full
                                                                                                                         explore potentially significant resources. We applaud the report drafters for
           leasing of the coastal plain of the Arctic National Wildlife Refuge (ANWR).          It                       recognizing the vital contributions that ANWR could make to the nation, namely:
           is our judgment that this recommendation is well supported, and we very much
                                                                                                                         reducing our increasing dependency on foreign oil; generating positive economic
           oppose the other alternatives for three very important reasons.             First, we
                                                                                                                         impacts in Alaska as well as the Lower 48 states; and improving our long term
           believe there may be significant undiscovered hydrocarbon potential in the 1002
                                                                                                                         balance of trade.      Of equal significance, we concur with the report's
           area.   Second, the national need for oil and gas Is best served by timely
                                                                                                                         conclusion that the exploration process should start now, since even under an
           assessing and developing that potential. And third, we are confident that the                                 accelerated sched ule, production of any commercial resources would not start
           environment can be appropriately protected while industry explores and,
                                                                                                                         until at least the year 2000.     By that time, according to the most recent NPC
           hopefully, develops the area.       In my remarks today I would like to expand on
                                                                                                                         forecast, the United States will almost certainly be importing well over half
           each one of these three points.
                                                                                                                         of the oil being consumed.       Also, by the year 2000,      Alaska's North Slope
           HYDROCARBON POTENTIAL
                                                                                                                         prodtiction, according to the Alaska Department of Revenue     forecast, will likely
           Turning first to that of hydrocarbon potential, we know that the ANWR Coastal
                                                                                                                         have declined from approximately 2 million BOPD to about      600,000 BOPD. As you
           Plain lies between Prudhoe Bay, the largest oil field in North America to the                                 may be aware, the 2 million barrels now produced from the North Slope account
           west, and the numerous Canadian oil and gas fields in the Mackenzie River Delta                               for nearly 20% of all U.S. production.        Certainly ANWR by itself could not
           and Beaufort Sea to the east.          Our analyses suggests that the geologic
                                                                                                                         fully offset domestic production decline, but it could significantly mitigate

            Comments                                  -3-                        January 9, 1987                       Comments                                 -4-                         January 9, 1987

            it.  At the same time, it is unlikely that the decline can be reversed by only                             environment. Common sense directs that industry's -actions would be equally
            exploring other frontier or high potential areas to the exclusion of ANWR.                                 responsible in the ANWR Coastal Plain.

                                                                                                                       SUMMARY
            For example, the California OCS appears attractive, but access is obstructed.                              To sum up,    Exxon feels that on balance,         the data and analyses argue
            The deepwater GOM holds promise, but exploration is incomplete and production                              conclusively for the recommended alternative of full leasing. The incentives -
            technology will be expensive and needs further refinement.         And much of the                         high potential and national need - are there, and the downside of environmental
            Beaufort and Chukchi Seas offshore the North Slope may not ultimately be viable                            impact is limited. Other alternatives only postpone an already lengthy process
            due to the harsh environmental conditions and resultant high operating costs.                              of discovery and development which the nation's interest dictates must proceed
            (PAUSE)                                                                                                    today rather than tomorrow. The no-action alternative is clearly unacceptable
            ENVIRONMENTAL                                                                                              because it is incompatible with energy needs and pro              .ven environmental
            Finally, we recognize the significance of the existing ANWR environment.           We
                                                                                                                       compatibility.
            also recognize that exploration and development of the ANWR C      .oastal Plain can                       (PAUSE)
        X   only proceed    in  a manner that ensures appropriate safeguards. for the                                  It is our hope that this matter be ultimately judged on its       merits, for if it
            environment, including the fish, wildlife and their habitat.         Data collected                        is, we are confident the best interests of our country, and       thus those of all
            from numerous impact studies on Prudhoe Bay facilities and the 800-mile long                               of us, its citizens, will be properly served.              I am   grateful for the
            TransAlaska Pipeline, argue, however, for a more optimistic estimate of the                                opportunity to speak.       I hope that my support will contribute to the
            potential environmental impacts from ANWR development than indicated in the                                implementation of the D01's recommendation of full leasing of the ANWR Coastal
            1002(h) report.    independently, our experts feel that the expressed impact
                                                                                                                       Plain.
            concerns regarding caribou calving, etc., represent "worst case" and thus

            improbable scenarios, rather thar the "most likely" outcomes which existing

            data indicate would be much less severe and of shorter duration.         We believe
            that the safe history  of oil and gas activities on Alaska's North Slope and in                            24.DTS(pll)
            refuges elsewhere in this country, conclusively indicates that environmental

            conservation and mineral resource development are compatible.         The companies

            associated with these operations, including Exxon, have worked hard and

            successfully to develop the expertise and technology to properly act in this

                             GEO-HYSICAL SERVICE INC.
                               -ST OFFICE BOX 2803 - HOUSTON. TEXAS 77001                                              COMILMS OF THE AMR SURVEY GROUP

                                     06 February 1987                                                      The Arctic National Wildlife Refuge Seismic survey Group
                                                                                                      ("ANWR Survey Group") appreciates,this opportunity to submit

                                                                                                      comments on tl,.e "Draft Arctic National Wildlife Refuge, Alaska
              U.S. Fish and Wildlife Service
              Department of the Interior                                                              Coastal Plain Resource Assessment" ("draft report") released in
              18th and C Streets, Northwest,   Room 2343
              Washington, D.C. 20240                                                                  November, 1986.   The ANWR Survey Group consists of the 22 energy
              Attention: Division of Refuge     Management                                            companies which funded, designed, and conducted -- through their

              Ladies and Gentlemen:                                                                   contractor, Geophysical Service Inc. (GSI) -- the 1984 and 1985

              Enclosed Please find comments offered by the GSI             ANWR                       seismic surveys of the Arctic National Wildlife Refuge ("ANWR")
              Exploration Group in response to your request for comments on
              the Draft Arctic National Wildlife Refuge, Alaska, Coastal                              study area as mandated by Congress under Section 1002 of the
              Plain Resource Assessment dated November 1986.
                                                                                                      Alaska National Interest bandsConservation Act ("ANIL.CA"), 16
              The Draft Resource Assessment allows us to make specific the
                                                                                                      U.S.C. 3142.
              concern that   we have repeatedly expressed in general terms
              about the Department's handling of proprietary geophysical
              data. We are pleased to have had this opportunity to express                                 The ANWIR Survey Group.wishes to compliment the Interagency
              our concerns, and we hope that our comments will be received
              in the spirit of cooperation with the Department        In which                        Advisory Work Group for their fine job in preparing the draft
              they are offered.      We are unanimously supportive of the
              Department's recommendation to open the entire 1002 Study                               report. Our member companies strongly support the Secretary's
              Area to oil and gas leasing. Since we believe that adequate
              Protection of proprietary data rights is critical to the                                recommendation that Congress permit leasing in the ANWR Coastal
             .health and success of the oil industry and on that success
              depends the success of any leasing program, we see our                                  Plain for oil and gas development and urge that a finalxeport be
              comments as supporting and not opposing the Department's
              goals in ANWR.                                                                          issued as expeditiously as possible.
              This submission Is made on behalf of those companies roamed on                               Nevertheless, the ANWR Survey Group is deeply concerned over
              the last page of the comments.                                                          the Interagency Advisory Work Group's de cision to release
                                           Yours truly,                                               con fidential processed geophysical data in the draft report.
                                       6G:EQ@lc          E ICE IN                                     These data pertain to areas within the ANWR as well as  .areas
                                                                                                      outside of the ANWR. The public release of processed geophysical
                                           Lonnie D Brook , Manaqer                                   data contravenes Congress' express mandate that "any processed,
                                           Western L       rket i rig
                                                                                                      analyzed and interpreted data and information-shall be held

                                                                                                      confidential by the Secretary for a period of not less than two
                                                    ,C &ERrCE
                                                              M
                                                    L        et@

                  @9160 GNEENDRIAP DRIVE STArFORD 713 494 9061 TELEX 78 2541 CAR- DUE- "OU
                                      Ti:XAS lNsrRIIMLN1S  ...... ---

               years following any lease sale including the area from which the                                               and interpreted information) obtained as a
                                                                                                                              result of carrying out the plan shall be
               information was obtained." 16 U.S.C. 3142(c).                                                                  submitted to the Secretary; and
                    Each of the companies which comprise the ANWR Survey Group                                                (C) shall make such data and information
                                                                                                                              available to the public except that any
               may submit comments on the draft report and the Secretary's                                                    processed, analyzed and interpreted data      or
                                                                                                                              information shall be held confidential by the
               recommendation under separate cover.       These comments submitted    on                                      Secretary for a period of not less than two
                                                                                                                              years following any lease sale including the
               behalf of the group as a whole focus solely on the issue of                                                    area from which the information was obtained.
               geophysical data disclosure an    d reflect the unanimous position of                             16 U.S.C.    3142(e)(2)(B),(C).
               the undersigned members of the Group that the release of                                                Congress enacted these provisions to      encourage private
               processed geophysical data in the draft report was contrary to                                    companies to finance the costly.seismic exploration of the
               law.                                                                                              ANWR.   Asa further incentive to private exploration, Congress
                    The ANWR Survey Group respectfully requests that the                                         prohibited the Secretary from approving any plan submitted by the
               Interagency.Advisory Work Group refrain from further disclosure                                   U.S. Geological Survey ("U.S.G.S.") unless private parties were
               of processed geophysical data and information whether such data                                   unwilling to explore or would not provide sufficient information
               and information pertain to the ANWR or not.        No processed,                                  to make an adequate report.       16 U.S.C. 3142(e)(2).
               analyzed or interpreted data and information pertaining to          the                                 However, Congress recognized that private entities would not
               ANWR may be released until two years after a lease       .sale including                          invest in ANWR exploration u    In.less they were permitted to protect
               the area from which the information was obtained has been held.                                   their proprietary interest in data obtained through their
               No raw, processed, analyzed or interpreted data and information                                   efforts.     The importance of Congress, promise to protect this
               pertaining to areas outside of the ANWR may be r      -eleased without                            proprietary   .interest ca .nnot be underestimated.    The only benefit
               the express written consent of the ANWR Survey Group.                                             which accrues to a company which financed ANWR data collection is
                                                                                                                 the ability to use it in lease sale decisionmaking. If ANWR data
                                              DISCUSSION                                                         were made available to all comers regardless of whether they
                  I .  SECTION 1002 OF ANILCA EXPRESSLY PROHIBITS THE                                            contributed toward its collection there would be no incentive for
                       DISCLOSURE OF ANY PROCESSED GEOPHYSICAL DATA
                       AND INFORMATION AT THIS TIME.                                                             any company  Ito contribute.
                    Section 1002(e)(2) of ANILCA requires inter alia        that the
                                                                                                                       Thus, a significant portion of the value of the data to any
               Secretary:                                                                                        given company lies primarily in its proprietary nature rather
                          (B) shall require that all data and                                                    than in its content per @_e.
                          information (including processed, analyzed

                                                  -2-                                                                                                -3-

                   This principle is simply illustrated.       Seismic. data showing                                 As can be seen, the amendment allows raw data to be made
             that an area is or is not prospective has virtually        no inherent                             available to those who desire to use it during the debate
             value. But the companies that own it know that the         area is one                             regarding the future status of ANWR but takes away from any
             on which they should or should not bid. Conversely, companies                                      recipient of the data, the right to participate in any future
             that do not own the data must either spend money to acquire it or                                  lease sale and thus any competitive advantage that recipient
             risk bidding on a non-prospective tract. if those data are made                                    might otherwise have obtained from the data.

             public, the situation is reversed. The companies that did not
                                                                                                                        A. Data Processe                   "u.t Remain Confidential
                                                                                                                             E@@@Vi        d b U.'A
             acquire the data from the permittee get it for free, giving them                                                     rtue@o Sechon 0A of ANIGCA
             a substantial competitive advantage over the companies that paid                                        AS shown above, Section 1002 requires the Secretary to keep
             for the data in the first place.                                                                        processed, analyzed and interpreted data ... confidential
                   Recognizing this to be the case, Congress amended Section                                    for.a period of.not less than two years following any lease sale
             1002(e)12) in an attempt to further protect the proprietary                                        including the area from which the information was obtained."
             interest of companies which financed ANWR data collection. The                                          The protection afforded by ANILCA Section 1002(e)(2)(C) must
             amendment   states:                                                                                be viewed not only within,the context of the other provisions of
                         ... Provided, That the Secretary    shall                                              ANILCA but also in the context of other related statutes.
                         prohibit by regulation any person who obtains
                         access to such data and information from the                                                The Trade Secrets Act (18 U.S.C. 5 1905) prohibits all
                         Secretary or from any person other than a
                         permittee from participation in any lease                                              agencies Eroff disclosing "information concernling) or relatling]
                         sale which includes the areas from which the
                         information was obtained and from any                                                  to trade secrets, processes, operations, style of work, or
                         commercial use of the information. The
                       .Secretary shall require that any permLttte                                              apparatus" unless *authorized by law". The Act has been
                         shall make available such data to any person                                           dIescribed.as "providing a s tandard by which to judge the legality
                         at fair cost.
                   The amendment is not a substitute for the Secretary's                                        of proposed agencies disclosures ... to create a federal right of
             obligation to maintain the confidentiality of any processed,                                       non-disclosure." Chevron Chemical Company v. Costle, 641 F.2d
             analyzed and interpreted data and information. It is directed at                                   104, 115 (3d Cir. 1981). See also Chrysler Corporation v. Brown,
             companies which receive raw geophysical data and information                                       441 U.S. 281, 306 (1979).
             which is the only form in which ANWR data and information may                                           ANILCA provides the   statutory authority for    certain
             presently be released.                                                                             disclosures of data and information which would otherwise
                                                                                                                undoubtedly be considered trade secrets. ANILCA Section

                                                -4-

              1002(e)(2)(B) requires that a permittee submit all data and                              to limit the protections  afforded to processed, analyzed  and
              information obtained as a result of carrying out an Exploration                          interpreted data to only  that processed, analyzed and interpreted
              Plan to the Secretary. ANILCA Section 1002(e)(2)(C) empowers the                         data submitted by the permittee to the Secretary they could
              Secretary to make such data available to the public except that                          easily have done so by merely modifying the protection to state
              any processed, analyzed or interpreted data or information must                          "any lof such data which is] processed  ... etc." or "any
              be held confidential for a period of not less than two years                             processed, analyzed or interpreted data  ... [submitted by the
              following any lease sale including the area from which the                               permittee]
              information wa3 obtained. Thus ANILCA provides plenary authority                              In the absence of these limitations, however, one is
              for disclosure of "raw data" but only limited authority to                               required to interpret the word "any'@ as including all processed,
              disclose processed, analyzed or interpreted data after a minimum                         analyzed and interpreted data in the Secretary's possession.
              period of years. Although the Secretary must, at some point make                              The legislative history of Section 1002 fully supports this
              raw data available, the statute contains no time limits,                                 conclusion. While the legislative history supporting initial

              conditions or procedures governing the Secretary's release of                            enactment of Section 1002(e)(2) does not address the scope of
              --t data. Similarly, 4-1tho-u-gh the Secretary must hold                                 confidentiality protection, Congress addressed the evil arl'u-ing
              processed, analyzed and interpreted information confidential for                         from the unauthorized release of data in the 1982 amendments,
              a minimum period, he may lengthen that term indefinitely at his                          stating:

              discretion.                                                                                        Language in the current law requires the
                                                                                                                 Secretary to make such data and information
                   The plain language of Section 1002(e)(2) prohibits                                            obtained in private exploration available to
                                                                                                                 the public. Since this allows companies that
              disclosure of "any processed, analyzed [or] interpreted  data and                                  don't directly finance the exploration to get
                                                                                                                 the information and data from the Secretary
              information ..." The term "any" is clear and unambiguous:     it                                   at little or no expense, there is no
                                                                                                                 incentive for a company to explore. In
              describes something which is "unmeasured in amount, number or                                      essence then, nonparticipating companies
                                                                                                                 could reap a windfall. Comments to the
              extent." Read in this context, it certainly describes all                                          Department of Interior on this matter from
                                                                                                                 prospective explorers suggest that private
              processed, analyzed or interpreted data which is submitted  by a                                   industry will not explore absent the change
                                                                                                                 agreed to by the managers. The Congressional
              permittee under Section 1002(e)(2)(B) or derives from data   which                                 Budget Office in 1980 reported that the cost
                                                                                                                 to the government to conduct the exploration
              was obtained as a result of carrying out an exploration plan.                                      was estimated at more than $61 million.
                                                                                                                 Because the exploration effort has been
                   This interpretation is also supported by the grammatical                                      mandated by an act of Congress, either the
                                                                                                                 government or private industry must bear the
              construction of Section 1002(e)(2)(C). Had the drafters intended                                   expense.  This amendment will thus save the
                                                                                                                 government this expense.

                                             -6-

                                                                                                      processing methods used by the permittee and other parties gives
                       The effect of the language is to put all
                       commercial interests on an equal footing by                                    him valuable commercial information regarding processing
                       denying any company that gets data and
                       information from the Secretary or any party                                    techniques and philosophies beyond that derived merely from
                       other than a permittee from participating in
                       a subsequent lease sale of land within the                                     viewing a single sample of processed data. Because of his unique
                       ANWR, unless the permittee is financially
                       compensated at fair cost for such data or                                      position, it is likely that any processing done by the Secretary
                       information.
                                                                                                      will be nothing more than a good quality compilation of the data
                       At the same time, this language preserves  the
                       right of public access to this data for the                                    already submitted and could  provide a product very similar to
                       purpose of full public discussion and debate
                       regarding whether the ANWR should be opened                                    that paid for by the permittee. Even more importantly, the
                       to lease.
                                                                                                      Secretary is uniquely positioned to interpret and analyze data
            H. Conf. Rep. 97-978, 97th Cong. 2d Bess. to accompany H.R. 7356
                                                                                                      already submitted in processed form by the permittee. Should
            at 27. The Conference version of the amendment was adopted                                that ultimate end product be released, there   Icould well be
            without debate by both houses and signed into law.                                        notIhin.g of value left to protect.  .Also,, the disclosure of any
                  Alt.hough the Secretary was already prohibited from                                 processed data would provide similar clues as to the processing
            disclosing processed, analyzed or interpreted data   and                                  preferences of the permittee or third parties.    Further, release
            information, Congress was concerned that raw data which was
                                                                                                      of data processed by the Secretary using processing methods
            relIeasable would be processed o.r otherwise used commercially by                         similar or identical to those used by the permittee would destroy
            entities which did not finance the exploration effort     It was                          any commercial value the permittee's processed data would
            feared that these "freeloaders" would create a disincentive for
                                                                                                      otherwise have gutting the protections afforded by the 1982
            other companies to finance exploration.                                                   amendment.
                 The amendment  added by the Congress in direct response to                                Thus, public release of any privately acquired data whether
            this concern was extremely broad.   It prohibits any person who
                                                                                                      federally processed or not subverts Congress' stated intention to
            has access to any data from any person other than the permittee                           protect the legitimate interests of those who took a risk in
            from 11) participating in any lease sale involving the areas from
                                                                                                      financing exploration. it renders the 1982 protection virtually
            which the data were obtained, and (2) from making any commercial
                                                                                                      unenforceable since the agency has no way of monitoring access to
            use of the data whatsoever.
                                                                                                      processed, analyzed or interpreted data once it has entered the
                 Because the Secretary holds the raw data and the data                                public domain.
            processed, analyzed and interpreted by the permittee, he is in a

            unique position, akin to a fiduciary. His knowledge of the

                                            -8-                                                                                        -9-

                    The regulations also support this conclusion. 50 C.F.R.                                Congress or the Secretary intended to create a class of private
               37.53(e) provides:                                                                          persons who are exempt from submitting their processed data to

                         Any permittee or othe
                                              0; ?e Hon submitting                                         the Secretary. Since the regulations require that all data
                         processed, anal-yi-ed    nt rpreted data or
                         information to the Regional Director shall                                        submitted be held confidential, no privately processed data would
                         clearly identify them by marking the top of
                         each page bearing the words "PROCESSED,                                           be subject to public disclosure by the Secretary... Given the
                         ANALYZED AND INTERPRETED DATA OR INFORMATION
                         ...                                                                               breadth of the protection afforded private explorers, it does not
               50 C.F.R. 37.54(a) provides in relevant part:                                               appear rational that the Secretary, acting.as fiduciary for all
                         The Department shall withhold from the public                                     privately processed data in his possession, would be able to
                         all processed, analyzed and interpreted data
                         or information obtained as a result of                                            process and release the data himself.
                         carrying out exploratory activities and
                         submitted by the permittee or a third party.                                           The only exception to these wide-ranging confidentiality
               (Emphasis added.)                                                                           provisions is created by 50 C.F.R. 37.45. This Section prohibits
                    In essence, the statutory and regulatory scheme requires                               the U.S.G.S. from asserting confidentiality over processed,
               anyone that processes information obtained from the program to                              analyzed or interpreted data but only when those data are
               submit the processed product to the Secretary, who is, in turn,                             collected.b.y the U.S.G.S. itself under a Special   Use Permit.
               required to hold it confidential. This is fully consistent with                             Such a permit can only be issued where no private   Ientity has
               the Department's prior statement that.the primary purpose of                                submitted a plan for the area involved which meets established
               Section 1002 is the collection of data to be used by the                                    guidelines and the information which would be obtained is needed
               Executive and Legislative branches in deciding what conclusions                             to make an adequate report under Section 1002(h). 50 C.F.R.
               to draw and reco mmendations to make in the report required by                              37.45 does not address the confidentiality of data collected by a
               Section 1002(h).                                                                            private permittee but processed by the U.S.G.S.
                    Obviously,,given this statutory and regulatory coverage,                                    As shown, the plain meaning of the statute, its grammatical
               there is no circumstance under which data could be processed by a                           construction, and its legislative history do not contemplate any
               third party and the processed, analyzed and interpreted product                             exception to the prohibition on releasing privately collected,
               not be required to be submitted to the Secretary. The Secretary,                            federally processed data.

               is, in turn, required even by the Secretary's unduly narrow

               interpretation of his own regulations, to hold that material

               confidential. In this context, it cannot be the case that

                                               -10-

                       B* Expe it:reC.oE Public Funds Does Not                                            analyzed and interpreted data from potential misuse, Congress
                          Vr.":I.r     .fidential indUstry Data                                           desired to stimulate privately funded exploration of the ANWR.
                          Into Public Data.
                   Section 1002(e)(2)  does not merely protect  data and                                       Although this exception is not authorized by statute, it is
              information which was submitted by a permittee   in processed,                              not inconsistent with Congress' intent. The U.S.G.S. can only
              analyzed or interpreted form. There is no evidence that Congress                            conduct exploration in the event that no private parties were
              contemplated that the confidentiality protection could apply this                           willing to do so.   Consequently, the competitive concerns
              narrowly.                                                                                   underlying ANILCA Section 1002(e)(2)(C) do not apply., However,
                   The Department has asserted that the expenditure.of public                             where private explorers mount a multi-million dollar effort to
              funds for the processing of raw data extinguishes the permittee's                           acquire data which is subsequently processed for U.S.G.S. on the
              confidentiality interest in the resultant processed data. That                              Secretary's behalf, competitive concerns resurface.     This is
              conclusion is unsupported by authority and  I, when placed against                          especially true since acquisition expenses account for 80 to 90
              the provisions of the Trade Secrets Act, 18 U.S.C. 1905, ANILCA,                            percent of the total cost of the project. Thus, release of data
              the ANILCA regulations, and general tenets of intellectual                                  which is privately acquired but processed by U.S.G.S. is no less
              property law, it is clearly erroneous.                                                      harmful to the permittee than release of privately processed
                   True enough, data which is collected and processed wholly at                           data.  In fact, the Secretary's unique ability to compile and
              the expense of the U.S.G.S. has been exempted from ANILCA's                                 evaluate data from all possible sources renders the release of
              confidentiality requirements by regulation. 50 C.F.R. 37.45.                                his interpretations the most harmful of all.
              The preamble to this regulation states:                                                          The expenditure of public,funds for the processing of data
                        GS and its contractors and subcontractors                                         which is acquired by private entities has no bearing on the
                        have been exempted from the provisions
                        dealing with processed, analyzed and                                              releasability of the resultant data. Congress has expressly
                        interpreted data or information, as data
                        acquisit!onlopraoce                A d'___                                        declined to authorize the release of any processed, analyzed and
                                                            an
                                  at n on:91  ngiG:l NA          ey or
                        int!trpre             y        a   1 Surv   I
                        on   s  behalf is financed by  public Fungs                                       interpreted data until at least two years after a lease sale has
                        and, therefore, the Department has no
                        intention of withholding such data and                                            occurred.  The Trade Secrets Act independently prohibits the
                        information from the public.                                                      agency from releasing such data and ANILCA does not authorize its
              48 Fed. Reg. 16855 (April 19, 1903) (emphasis added).                                       release until at least that point in time.
                   However, it clearly does not apply where data acquisition is

              undertaken by a private permittee. By protecting processed,

                                              -12-                                                                                        -13-

                         C. Disclosure of U.S.G               d Data Will                                                 participating in a subsequent lease sale of
                                                 ti!;,Proces:e                                                            the land to which such data and information
                            Vitiate the Protec          ough  to be
                            Proviaia 6i Me-7952 pimenament.                                                               pertain.
                     The 1982 amendment to ANIUCA barring companies which obtain                               48 Fed. Reg. 16840 (April 19, 1983).
               raw data from the Secretary from bidding at an ANWR lease sale is                                    The Department   sought to implement the 1982 amendment     by
               addressed  in regulations publishdd at 50 C.F.R. 37.54(d).                                      seeking from each party requesting data a certification of       his
                          Commercial use by any person of data or                                              awareness of the prohibitions on bidding contained in the
                          information obtained as a result of carrying
                          out exploratory activities and disclosed                                             statute.   Such a certification would provide the Department not
                          pursuant to this section is prohibited. No
                          person shall obtain,access from the                                                  only with a list of requestors. (who would.presumably be barred
                          Department ... to any data or information
                          obtained as a result of carrying out                                                 from participating   in upcoming lease sales) but also with a
                          exploratory activities aad submitted by the
                          permittee or a third party until such person                                         statement from the   requestor which would be used to demonstrate
                          provides the Department with a statement                                                                                      ntained in the 1902
                          certifying that person's awareness of the                                            that, even absent the prohibitions co
                          prohibitions contained in this paragraph and
                          the disqualification (from bidding at lease                                          amendment, the requestor had waived any right it might have had
                          sales] ...
                                                                                                               to participate in an ANWR lease sale.
                     In commenting on this regulation, members of the     ANWR Survey
               Group also sought additional controls on the release of raw                                                                    -w- my
                                                                                                               processed by U.S.G.S. gives the general public, including the
               data. The   Department responded to these concerns in     the preamble
                                                                                                               direct competitors of the survey group members, access to
               to the Final Rule but failed to make the requested changes.
                                                                                                               valuable seismic data, which, had they requested it from the
                          No changes have been made to (the definitions
                          of raw and processed data) because of the                                            Department, would have triggered the restrictions contained in
                          intervening amendment ...     The Service                                            the 1982 amendment.    Further, since the data are released by
                          considers the commepter's concerns about the
                          harm that could be done to the competitive
                          positions of permittees should their seismic                                         publication, the Department has no record of those potential
                          tapes be made available to the public and.                                           bidders that have received data nor any statement by them waiving
                          their competitors as raw data and the
                          consequent disincentive that the Service's
                          disclosure provisions provided to                                                    their right to bid. Thus, the entire objective of the 1982
                          participation in the exploration program to
                          have been mooted by the [amendment].      [The                                       amendment is vitiated by publication.
                          amendment] should restore the economic
                          incentive needed by industry to participate                                               Apparently in an attempt to reduce the potential
                          in exploration of the coastal plain.
                          According to its legislative history, the                                            commerciality of the processed data published in the draft ANWR
                          purpose of (the amendment] is to put all
                          commercial interests on an equal footing by                                          report, certain identifying data were deleted from the processed
                          denying any company that gets data and
                          information from the Department or from any                                          seismic sections contained in Plate 5.      For instance, the precise
                          party other than a permittee from

                                                 -14-

             locations of the ends of the published sections have been deleted                              Il. NO DATA.WHICH PERTAINS TO AREAS OUTSIDE OF THE
                                                                                                                 ANWR MAY BE RELEASED IRRESPECTIVE OF ITS FORM.
             along with the locations of the individual shotpoints. Despite
                                                                                                              Another data disclosure problem, potentially even    more
             this attempt, enough identifying information was included,
                                                                                                         serious than the disclosure of U.S.G.S. processed data, has also
             inadvertently or otherwise sufficient to locate the geologic
                                                                                                         arisen as a consequence of the publication of the draft report.
             features identified in those sections with sufficient precision
                                                                                                         That problem is the disclosure of data collected outside the
             to make the data very commercial.
                                                                                                         refuge boundary pursuant to State of Alaska permits but submitted
                   For example, several of the sections are published in their                           to the Department in order to a  .id its evaluation of ANWR.
             entirety and the line identification numbers are shown. The
                                                                                                              At the time that the exploration plans were submitted, the
             precise location of these lines are available to the public on
                                                                                                         applicable regulations required that the permittee submit to DOI
             maps submitted in conjunction with the exploration plans.
                                                                                                         "all data and information obtained as a result of carrying out
             Further, some of the sections are tied to exist   .ing wells outside                        exploratory activities." 50 C.F.R. 37.53(a).
             the refuge.   Since the location of these wells is precisely                                     Each  submission was required to contain:
             known, the location of structures within the refuge may be easily
                                                                                                                    1) An accurate and complete record of each
             extrapolated.                                                                                          geophysical survey conducted under the
                                                                                                                    permittee's permit, ...
                   In short, to the extent that U.S.G.S. processed   data has                                       2) All seismic .data developed under the
             been published, its confidentiality and hence its value to the                                         permit.

             survey group has been irrevocably compromised.     Since a small                            50 C.F.R.  37.53(b).

             amount of the data has actually been published,    the group's                                   The regulations define certain terms used above as follows:

             competitive position has already been severely damaged.      Further,                                  (i) "Exploratory activities" mean ... seismic
                                                                                                                    exploration ... of the coastal plain - *.. and
             disclosure of data as yet undisclosed will render the group's                                          any other type of geophysical exploration of
                                                                                                                    the coastal plain which involves or is a
             investment of over $40 million virtually worthless.     Thus, should                                   component of an exploration program for the
                                                                                                                    coastal plain involving surface use of refuge
             it become apparent that further unauthorized disclosure of                                             lands ... .

             U.S.G.S. processed data is intended, the group will be forced to                                       (p) "Raw data and information" means all
                                                                                                                    original observations and recordings in
             consider whether legal action is appropriate to enjoin it.                                             written or electronic form ... obtained
                                                                                                                    during field operations.

                                                                                                                    (w) "Special use permit" means a revocable
                                                                                                                    nonpossessory privilege.issued in writing ...
                                                                                                                    authorizing the permittee to enter and use

                                             -16-                                                                                         -17-

                         the refuge for a specified period to conduct                                              the [Government) all dat@t obtained during
                         exploratory activities ...                                                                this program which ties to adjacent areas.

              50 C.F.R. 37.2.                                                                           Special Use Permit 83-C10, Special Conditions 22.
                   Thus, the regulations require the submission of only data                                  Obviously, the Department's authority to require the
              collected as a result of "exploratory activities" and those                               collection and authorize release of geophysical data in this
              activities are limited by definition to the exploration of the                            instance is limited by the plain language of the statute and the
              coastal plain or other types of geophysical exploration of the                            rules for activities conducted within the ANWR.    Indeed, the

              coastal plain involving the surface use of refuge lands. Given                            Department cannot even authorize, let alone require, the
              this framework, it would have been impossible for a prospective                           collection of data on state lands or in state waters.
              permittee to infer from the regulations that it would be required                               Further, geophysical data is generally exempt from
              to submit (and thus possibly subject to public disclosure) data                           disclosure under the Freedom of Information Act, 5 U.S.C. 5 552

              collected outside of the coastal plain.                                                   ("FOIA"), and would undoubtedly be considered confidential "trade

                   Apparently, however, Departmental officials became aware                             secrets" pursuant to 18 U.S.C. S 1905 (the "Trade Secrets
              through informal discussions with group members that data would                           Act").  That is, seismic data is generally to be held
              be collected outside the refuge in order to provide an integrated                         confidential by government officials unless its release is
              data base to the group members.   However, no communications were                         authorized by statute as opposed to most other types of data
              made by the Department to the group that the Department expected                          collected by the government, which are subject to disclosure

              to receive any off-refuge data until the Record of Decision                               unless prohibited by statute.

              ("ROD") was issued regarding the approval of the exploration                                    In view of the general exemption of seismic data from

              plan. It stated-                                                                          disclosure (discussed more fully above) express statutory
                         (8) Copies of any well tie-in,data obtained                                    authorization is required to release seismic data in the
                         during the surveys will be provided to the
                         Government. The Government will protect the                                    government's possession.   However, ANILCA jurisdiction pertains
                         proprietary nature of these--aa-ta.
                                                                                                        only to data collected in the ANWR itself and no other statute
              ROD I Conditions of Approval, 1 C (8) at p. 7 (emphasis added).                           authorizes release of these data especially since they were
                   It did not mention the submission of other data collected
                                                                                                        obtained on state lands rW:er than federal lands. Thus, no
              outside the refuge.   The Special Use Permit itself, however,                             statute authorizes release of off-refuge data and any further
              states:
                                                                                                        release would constitute a violation of 18 U.S.C. 1905.
                         22. In addition to data obtained from the
                         coastal plain, the permittee shall submit to

                                             _18-                                                                                       _19-

                   The significance of this problem is heightened by the fact                                the group will be forced to consider the appropriateness of legal
             that much of the off-refuge datain question was collected in                                    action to enjoin any further releases of off-refuge      data in order
             State of Alaska waters offshore of the ANWR from the eastern edge                               to prevent further competitive harm.

             of Camden Bay to an area eastward of the boundary of the Coastal
                                                                                                                                           CONCLUS10H
             Plain survey area. This area is to be offered for lease in State
                                                                                                                  Congress enacted ANILCA'S prohibitions on the release of.
             of Alaska Sales 50 and 55, currently scheduled for June, 1987 and
                                                                                                             privately collected geophysical data in order that the companies
             June, 1988.   Industry interest in the sale Is high and the group                               that funded the seismic survey of the ANWR would not be     .  required
             is aware that many companies who were not members of the ANWR                                   to forfeit their. investment. Concomitantly, the passage of the
             survey group are interested in bidding. By contrast review of
                                                                                                             1982 amendment signaled Congressional concurrence in the position
             off-refuge data is not necessary to informed debate over the
                                                                                                             that carefully controlled disclosure of raw.data, but not
             conclusions drawn in the draft report.                                                          processed data, would enable those who desired it to partici      .pate
                   In spite of this, the Department published some off-refuge                                fully In the ANWR debate.
             data in the draft report.     In spite of the express.representation                                 However, the Department has released processed data by
             that  "the Government would   protect the@proprietary nature" of                                publication in direct violation of Section 1002, completely
             well  tie data contained in   the ROD, extensive well tie data are                              vitiating the 3tatutory protection.      Further, it has breached its
             published in Plate 4 of the report and are illustrated on lines
                                                                                                             promise to protect the confidentiality of well-tie data and has
             84-1, 84-5, 85-2 and 85-8, while offshore, state water data are                                 released highly proprietary data collected outside the ANWR
             apparently published on lines 85-8, 84-10 and 85-1.       In addition,                          without statutory authority and in direc    t violation of 18 U.S.C.
             Line 85-1 projects into the State of Alaska lease sale 55 area.                                 1905 -- data which is unnecessary to informed public debate but
             These disclosures are not only unauthorized but in the case of                                  which is essential to companies wishing to part     .icipate in State
             well tie data constitute a blatant breach of promise for which                                  of Alaska Sales 50 and 55.
             the Department is clearly lia   ble.                                                                 We trust that the Department will understand the seriousness
                   As in the case of U.S.G.S. processed data there is no way                                 of its past actions and take steps to ensure that they will
             that the competitive harm that disclosure has already caused can
                                                                                                             cease. The recommendations contained in the draft report and its
             be undone.   Further, as in the case of U.S.G.S. processed data,                                analysis of the   issues are generally commendable and, as

                                                                                                             demonstrated in the public hearings in Anchorage and Washington

                                                                                                             many members of the survey group have actively supported the

                                               _20-                                                                                           -21-

              Department's position. It would be a shame were that

              relationship to be marred by continued Departmental violations of

              its own guarantees of confidentiality.

                   Geophysical Service Inc. is the geophysical contractor and

              the authorized representative of the following companies of the

              GSI ANWR Exploration Group who have authorized submission of

              these comments:

                   AMERADA HESS CORPORATION       MURPHY OIL USA, INC.

                   AMOCO PRODUCTION COMPANY       PETROFINA DELAWARE, INCORPORATED

                   ARCO ALASKA, INC.              PLACID OIL COMPANY.

                   CHAMPLIN PETROLEUM CO.         SHEGG WESTERN EXPLORATION AND
                      (a subsidiary of Union         PRODUCTION INC.
                      Pacific Corporation)
                                                  STANDARD ALASKA PRODUCTION COMPANY
                   CHEVRON U.S.A. INC.
                                                  SUN EXPLORATION AND PRODUCTION
                   CONOCO INC.                       COMPANY

                   ELF AQUITAINE PETROLEUM        TENNECO OIL COMPANY

                   EXXON COMPANY, U.S.A.          TEXACO INC.
                   (a Division of Exxon Corp.)
                                                  UNOCAL
                   KERR-McGEE CORPORATION
                                                  UNION TEXAS PETROLEUM
                   MARATHON OIL COMPANY              CORPORATION

                   MOBIL OIL CORPORATION

                                            -22-

                                           LAW OFFICES
                                   COTTEN, DAY & DOYLE                                                                           /CORRECTED/
                                          TWELFTH FLOOR                                                                COMMENTS OF THE ANWR SURVEY GROUP
                                      1899 L STREE@, NORTHWEST             J.        JR.
            I GO L.
                                       WASHINGTON, 0. C. 20036               J... ... III ... I
        GAIL                                                                  01 G.-L
                                          2021 659-9505
                                      TCLCCQPIWR NO.: 1202) 775-8350
                                                                                                            The Arctic National Wildlife Refuge Seismic Survey Group

                                       February 9, 1987                                                ("ANWR Survey Group") appreciates this opportunity to submit

                                                                                                       comments on the "Draft Arctic National Wildlife Refuge, Alaska

              U.S. Fish and Wildlife Service                                                           Coastal Plain Resource Assessment- ('draft report") released in
              Department of the Interior
              18th and C Streets, Northwest,  Room 2343                                                November, 1986. The ANWR Survey Group consists of the 22 energy
              Washington, D.C. 20240                                                                   companies which funded, design.ed, and conducted -- through their
              Attention: Division of Refuge   Management
                                                                                                       contractor,,Geophysical Service Inc. (GSI) -- the 1984 and 1985
              Ladies and Gentlemens
                                                                                                       seismic surveys of the Arctic National Wildlife Refuge ("ANWR".)
                   On Friday, February 6,1987, this office transmitted the                             study area as mandated by Congress under Section 1002 of the
              comments of the Arctic National Wildlife Refuge Seismic Survey
              Group on the Draft ANWR Report and Environmental Impact Statement
              via U.S. mail.                                                                           Alaska National .interest LandL Conservation Act ("ANILCA*), 16
                   Regrettably, the comments enclosed were but a draft    and not                      U.S.C. 3142.
              the final comments. Please find enclosed the final comments. We                               The ANWR Survey Group wishes to compliment the Interagency
              would ask that these comments labelled "Corrected Comments of the
              ANWR Survey Group" be substituted for those   you will receive in                        Advisory Work Group for their fine job in preparing the draft
              the mail.
                                                                                                       report. Our member companies strongly support the Secretary's
                   We regret this error and hope that you   will not be
              inconvenienced by ourrequest.                                                            recommendation that Congress permit leasing in the ANWR Coastal
                                                  Sincerely yours,                                     Plain for oil and gas development and ur ge that a final report be

                                                                                                       issued as expeditiously as possible.
                                                           J@
                                                 Nathan S.  Bergerbest                                      Nevertheless, the ANWR Survey Group is deeply concerned over

              Enclosure                                                                                the Interagency Advisory Work Group's decision to release

                                                                                                       confidential processed geophysical data in the draft report.

                                                                                                       These data pertain to areas within the ANWR as well as areas

                                                                                                       outside of the ANWR. The public release of processed geophysical

                                                                                                       data contravenes Congress' express mandate that "any processed,

                                                                                                       analyzed and interpreted data and information shall be held

                                                                                                       confidential by the Secretary for a period of not less than two

               years following any lease sale including the area from which the                                          and interpreted information) obtained as a
                                                                                                                         result of carrying out the plan shall be
               information was obtained." 16 U.S.C. 3142(c).                                                             submitted to the Secretary; and

                    Each of the companies which comprise the ANWR Survey Group                                           (C) shall make such data and information
                                                                                                                         available to the public except that any
               may submit comments on the draft report and the Secretary's                                               processed, analyzed and interpret@d data or
                                                                                                                         information shall be held confidential by the
               recommendation under separate cover. These comments submitted on                                          Secretary for a period of not less than two
                                                                                                                         years following any lease sale including the
               behalf of the group as a whole focus solely on the Issue of                                               area from which the information was obtained.
               geophysical data disclosure and reflect the unanimous position      of                         16 U.S.C.  .3142(e)(2)18),(C).
               the undersigned members of the Group that the release of                                            Congress enacted these provisions to encourage private
               processed geophysical data in, the draft report was contrary to                                companies  to finance the costly seismic exploration of the

               law.                                                                                           ANWR. As   a further incentive to private exploration, Congress
                    The ANWR Survey Group   respectfully requests that the                                    prohibited the.Secretary from approving any plan submitted by the
               Interagency Advisory Work Group refrain from further disclosure                                U.S. Geological Survey ("U.S.G.S.") unless private parties were
               of processed geophysical data and Information whether. such data                               unwilling to explore or would not provide sufficient Information
               and information nertain to the AN  .WR or not.   No Processed,                                 to make an adequate report. 16 U.S.C. 3142(e)12).
               analyzed or Interpreted data and Information     pertaining to the                                  However, Congress recognized that privateentities would not
               ANWR may be released until two years after a     lease sale including                          invest in ANWR exploration unless they were permitted to protect
               the area, from which the information was obtained has been held.                               their proprietary interest in data obtained through their
               No raw, processed, analyzed or interpreted data and information                                efforts. The importance ofCongress' promise to protect this
               pertaining to areas outside of the ANWR way be released without                                proprietary interest cannot be underestimated. The only benefit
               the express written consent of the ANWR Su   .rvey Group.                                      which accrues to a-company which financed ANWR data collection is

                                                                                                              the ability to use it in lease sale decisionmaking. If       ANWR data
                                            DISCUSSION
                                                                                                              were made available to all comers regardless of whether      they
                  1. SECTION 1002 OF ANILCA EXPRESSLY PROHIBITS THE
                      DISCLOSURE OF ANY PROCESSED GEOPHYSICAL DATA                                            contributed toward its collection there would be no incentive for
                      AND INFORMATION AT THIS TIRE.
                                                                                                              any company to contribute.
                    Section 10021e)(2) of ANILCA requires inter alla     that the
                                                                                                                   Thus, a significant portion.of    the value of the data to any
               Secretary:                                                                                     given company lies primarily in it   .aproprietary nature rather

                         .(B) shall require that all data and                                                 than in its content per Re.
                          information (including processed, analyzed

                                                -2-                                                                                             -3-

                   This principle is simply illustrated. Seismic data showing                                   As can be seen, the amendment allows raw data    to be made

              that an area is or is not prospective has virtually no inherent                              available to those who desire to use it during the    debate
              value.   But the companies that own it know that the area is one                             regarding the future status of ANWR but takes away    from any
              on which they should or should not bid. Conversely, companies                                recipient of the data, the right to participate in    any future
              that do not own the data must either spend money to acquire it or                            lease sale and thus any competitive advantage that    recipient
              risk bidding on a non-prospective tract. It those data are made                              might otherwise have obtained from the data.

              public, the situation is reversed. The companies that did not
                                                                                                                   A. Data Processe              S- "u.t Remain Confidential
                                                                                                                       by Virtue of d by "i
              acquire the data from the permittee get it for free, giving them                                                       Section       of ANILCA
              a substantial competitive advantage over the companies that paid                                  As shown above, Section 1002 requires the Secretary to keep
              for the data in the first place.                                                                  processed, analyzed and interpreted data ... confidential
                   Recognizing this to be the case, Congress amended Section                               for a period of not less than two years following any lease sale
              1002(e)(2) in an attempt to further protect the proprietary                                  including the area from which the information was obtained."
              interest of companies which financed ANWR data collection. The                                    The protection afforded by ANILCA Section 1002(e)(2)(C       must
              amendment  states:                                                                           be viewed not only within the context of the other provisions of
                         ... Provided, That the Secretary shall                                            ANILCA but alsoin the context of other related statutes.
                         prohibit by regulation any person who obtains
                         access to such data and information from the                                           The Trade Secrets Act (18 U.S.C. 5 190S) prohibits all
                         Secretary or from any person other than a
                         permittee from participation in any lease                                         agencies from disclosing "information concern(ing] or relat(ing)
                         sale which includes the areas from which the
                         information was obtained and from any                                             to trade secrets, processes, operations, style of work, or
                         commercial use of the information. The
                         Secretary shall require that any permittee                                        apparatus" unless "authorized by law". The Act has been
                         shall make available such data to any person
                         at fair cost.                                                                     described as "providing a standard by which to judge the legality
                   The amendment is not a substitute for the Secretary's                                   of proposed agencies disclosures ... to create a federal right of
              obligation to maintain the confidentiality of any processed,                                 non-disclosure.n Chevron Chemical Company v. Costle, 641 F.2d
              analyzed and interpreted data and information.     It is directed at                         104, 115 (3d Cir. 1981). Lee also Chrysler Corporation v. Brown,
              companies which receive raw geophysical data and information                                 441 U.S. 281, 306 (1979).

              which is the only form in which ANWR data and information may                                     ANILCA provides the statutory authority for certain

              presently be released.                                                                       disclosures of data and information which would otherwise

                                                                                                           undoubtedly be considered trade secrets. ANILCA Section

                                               -4-                                                                                          -5-

               10.02(e)(2)(8) requires that a permittee submit all data and                               to limit the protections afforded to processed, analyzed and
               information obtained as a result of carrying out an Exploration                            interpreted data to only that processed, analyzed and interpreted
               Plan to the Secretary. ANILCA Section 1002(e)(2)(C) empowers the                           data submitted by the permittee to the Secretary they could
               Secretary to make such data available to the public except that                            easily have done so by merely modifying the   protection to state
               any,processed, analyzed or interpreted data or information must                            "any JoE such data which is) processed   ... etc." or "any
               be held confidential for a period of not less than two years                               processed, analyzed or interpreted data   ... (submitted by the
               following any lease sale including the area from which the                                 permitteel
               information was obtained. Thus ANILCA provides plenary authority                                In the absence of these limitations, however, one is

               for disclosure of "raw data" but only limited authority to                                 required to interpret the word "any" as including all processed,
               disclose processed, Analyzed or interpreted data after a minimum                           analyzed and interpre ted data in the Secretary's possession.
               period of years. Although the Secretary must, at some point make                                The legislative history of Section 1002 fully supports this

               raw data available, the statute contains no time limits,                                   conclusion. While the legislative history supporting initial

               conditions or procedures governing the Secretary's release of                              enactment of Section 1002(e)(2) does not address the scope of

               that data. Similarly, although the Secretary must hold                                     confidentiality protection, Congress addressed the evil arising
        14
               processed, analyzed and interpreted information confidential for                           from the unauthorized release of data in the 1982 amendments,

               a minimum period, he may lengthen that term indefinitely at his                            stating:
               discretion.                                                                                          Language in the current law requires the
                                                                                                                    Secretary to make such data and information
                   The plain language of Section 1002(e)12) prohibits                                               obtained in private exploration available to
                                                                                                                    the public. Since this allows companies that
               disclosure of "any processed, analyzed (or] interpreted data   and                                   don't directly finance the exploration to get
                                                                                                                    the information and data from the Secretary
               information ... " The term "any" is clear and unambiguous:     it                                    at little or no expense, there is no
                                                                                                                    incentive for a company to explore. In
               describes something which is "unmeasured in amount, number or                                        essence then, nonparticipating companies
                                                                                                                    could reap a windfall. Comments to the
               extent." Read in this context, it certainly describes all                                            Department of Interior on this matter from
                                                                                                                    prospective explorers suggest that private
               processed, analyzed or interpreted data which is submitted   by a                                    industry will not explore absent the change
                                                                                                                    agreed to by the managers. The Congressional
               permittee under Section 1002(e)(2)(B) or derives from data    which                                  Budget Office in 1980 reported that the cost
                                                                                                                    to the government to conduct the exploration
               was obtained as a result of carrying out an exploration plan.                                        was estimated at more than $61 million.
                                                                                                                    Because the exploration effort has been
                   This interpretation is   also supported by the grammatical                                       mandated by an act of Congress, either the
                                                                                                                    government or private industry must bear the
               construction of Section 1002(e)(2)(C). Had the drafters intended                                     expense.   This amendment will thus save the
                                                                                                                    government this expense.

                                               -6-                                                                                        -7-

                                                                                                       processing methods used by the permittee and other parties gives
                        The effect of the language isto put all
                        commercial interests on an equal footing by                                    him valuable commercial information regarding processing
                        denying any company that gets data and
                        information from the Secretary or any party                                    techniques and philosophies,beyond that derived merely from.
                        other than a permittee from participating in
                        a subsequent lease sale of land within the                                     viewing a single sample of processed data. Because of his unique
                        ANWR, unless the permittee is financially
                        compensated at fair cost for such data or                                      position, it is likely that any processing done by the Secretary
                        information.
                                                                                                       will be nothing more than a good quality compilation of the data
                        At the same time, this language preserves  the
                        right of public access to this data for the                                    already submitted and could provide a product very similar to
                        purpose of full public discussion and debate
                        regarding whether the ANWR should be opened                                    that paid for by the permittee. Even more importantly, the,
                        to lease.
                                                                                                       Secretary  is uniquely positioned to interpret and analyze data
              H. Conf. Rep. 97-978, 97th Cong. 2d Seas. to accompany H.R. 7356
                                                                                                       already submitted in  processed form by the permittee. Should
              at 27.. The Conference version of the amendment was adopted
                                                                                                       that ultimate end product be released,   there could well be
              without debate by both houses and signed into law.
                                                                                                       nothing of value left to protect. Also, the disclosure of any
                   Although the Secretary was already prohibited  from
              disclosing processed, analyze d or interpreted data and                                  processed data w Iould provide similar clues as to the processing
              information, Congress was concerned that raw data which was                              preferen ces of the permittee or third pa .rties. Further, release
                                                                                                       of data processed by the Secretary using processing methods
              releasable would be processed or otherwise used commercially.by                          similar or identical to those used by the permittee wou  IId deIstroy
              entities which did not finance the exploration effort. It was
                                                                                                       any commercial value the permittee's processed data would
              feared that these "freeloaders" would create a disincentive for
                                                                                                       otherwise have gutting the protections afforded by the 1982
              other companies to finance exploration.
                                                                                                       amendment.
                   The amendment added by the Congress In direct response to
                                                                                                            Thus, public release of any privately acquired data whether
              this concern was extremely broad. it prohibits any person who
                                                                                                       federally processed or not subverts Congress' stated intention to
              has access to any data from any person other than the permittee
                                                                                                       protect the legitimate interests of those who took a risk in
              from (1) participating in any lease sale involving the areas from
                                                                                                       financing exploration. It renders the 1982 protection virtually
              which the data were obtained, and (2) from making any commercial
                                                                                                       unenforceable since the agency has no way of monitoring access to
              use of the data whatsoever.
                                                                                                       processed,,analyzed or interpreted data once it has entered the
                   Because the Secretary holds the raw data and the data
                                                                                                       public domain.
              processed, analyzed and interpreted by the permittee, he is in a

              unique position, akin to a fiduciary. His knowledge of the,

                  The regulations alsc;support this conclusion.    50 C.F.R.                            Congress or the Secretary intended to create a class of private
             37.53(e) provides:                                                                         persons who are exempt from submitting their processed data to

                        Any permittee or oth    er
                                            e     gon submitting                                        the Secretary. Since the regulations require that all data
                        processed, analyzed o; ein  rpreted data or
                        information to the Regional Director shall                                      submitted be held confidential, no privately processed data would
                        clearly identify them by marking the top of                                                 o public disclosure by the Secretary. Given the
                        each page bearing the words "PROCESSED,                                         be subject t
                        ANALYZED AND INTERPRETED DATA OR INFOR14ATION
                                                                                                        breadth of the protection afforded private explorers, it does not
             50 C.F.R.  37.54(a) provides in relevant part:                                             appear rational that the Secretary, acting as fiduciary for all
                        The Department shall withhold from the public                                   privately processed data in his possession, would be able to
                        all processed, analyzed and interpreted data
                        or information obtained as a result of                                          process and release the data himself,
                        carrying out exploratory activities and
                        submitted by the permittee or a third party.                                         The only exception to these wide-ranging confidentiality
             (Emphasis added.)                                                                          provisions is created by 50 C.F.R. 37.45. This Section prohibits
                  In essence, the statutory and regulatory scheme requires                              the U.S.G.S. from asserting confidentiality over processed,
             anyone that processes information obtained from the program to                             analyzed or Interpreted data but only when those data are
             submit the processed product to th  e Secretary, who is, in turn,                          collected by the U.S.G.S. itself under a Special Use Permit.
             required to hold it confidential. This is fully consistent with                            Such a permit can only be issued where no private entity has
             the Department's prior statement that the primary purpose of                               submitted a plan for the area involved which meets established
             Section 1002 is the collection of data to be used by the                                   guidelines and the information which would be obtained is needed
             Executive and Legislative branches in deciding what conclusions                            to make an adequate report under Section 1002(h). 50 C.F.R.
             to draw and recommendations to make in the report required by                              37.45 does not address the confidentiality of data collected by a
             Section 10021h).                                                                           private permittee but processed by the U.S.G.S.
                  obviously, given this statutory and regulatory coverage,                                   As shown, the plain meaning of the statute, its grammatical
             there is no circumstance under which data could be processed by a                          construction, and its legislative history do not contemplate any
             third party and the processed, analyzed and interpreted product                            exception to the prohibition on releasing privately collected,
             not be required to be submitted to the Secretary. The Secretary,                           federally processed data.

             is., in turn, required even by the Secretary's unduly narrow

             interpretation of his own regulations, to hold that mate   rial

             confidential. In this context, it cannot be the case that

                      B*  Expe diture of Public Funds Does Not                                           analyzed and interpreted data from potential misuse, Congress
                          Tr.
                            ,.:for. Co. naential Industry Uata
                          Inta Public Data.                                                              desired to stimulate privately funded exploration of the ANWR.
                   Section 1002(e)(2) does not.merely protect   data and                                       Although this exception is not authorized by statute, it is
              information which was submitted by a permittee   in processed,                             not inconsistent with Congress' intent.     The U.S.G.S. can only
              analyzed or interpreted form. There is no evidence that Congress                           conduct exploration in the event that no private.parties were
              contemplated that the confidentiality protection could apply this                          willing to do so. Consequently, the competitive concerns
              narrowly.                                                                                  underlying ANILCA Section 1002(e)(2)(C) do not apply. However,
                   The Department has asserted  that the expenditure of public                           where private explorers mount a multi-million dollar effort to
              funds for the processing of raw data extinguishes the permittee's                          acquire data.which is subsequently processed for U.S.G.S. on the
              confidentiality interest in the resultant processed data. That                             Secretary's behalf, competitive concerns resurface.     This is
              conclusion is unsupported by authority and, when placed against                            especially true since acquisition expenses account for 80 to 90
              the provisions of the Trade Secrets Act, 18 U.S.C. 1905, ANUCA,                            percent of the total cost of the project. Thus, release of data
              the ANUCA regulations, and general tenets of intellectual                                  which is privately acquired but processed by U.S.G.S. is no less
              property law, it is clearly erroneous@                                                     harmful to the permittee than release of privately processed
                   True enough, data which is collected and processed wholly at                          data.   In fact, the Secretary's unique ability to compile and
              the expense of the U.S.G.S. has been exempted from ANILCA's                                evaluate data from all possible sources renders the release of
              confidentiality requirements by regulation.    50 C.F.R. 37.45.                            his interpretations the most harmful of all.
             ,The preamble to this regulation states:                                                          The expenditure of public funds for the processing of data

                         GS and its contractors and subcontractors                                       which is acquired by private entities has no bearing an the
                         have been exempted from the provisions
                         dealing with processed, analyzed and                                            releasability of the resultant data. Congress has expressly
                         interpreted data or information, as data
                         acquisittatioproce 1         1y s and                                           declined to authorize the release of any processed, analyzed      and
                                                    n!.g?la
                                      n Jogs bngiG:o       I S   e I or
                         int$rpre             y
                         on it. benalt is financed by public funds                                       interpreted data until at least two years after a lease sale      has
                         and, therefore, the Department has no
                         intention of withholding such data and                                          occurred.   The Trade Secrets Act independently prohibits the
                         information from the public.
                                                                                                         agency from releasing such data and ANILCA does not authorize its
              48 Fed. Reg. 16855 (April 19, 1983) (emphasis added).
                                                                                                         release until at least that point in time.
                   However, It clearly does not apply where data acquisition is

              undertaken by a private permittee. By protecting processed,

                                              -12-                                                                                        -13-

                     C. Disclosure of U.S.G.S. Processed Data   Will                                             participating in a subsequent lease sale of
                         Vitiate the Protections Sought to be                                                    the land to which such data and information
                          Provided by the 1982 Amendment.                                                        pertain.
                  The 1982 amendment to ANILCA barring companies which obtain                          48 Fed. Reg. 16840 (April 19, 1983).
             raw da ta from the Secretary from bidding at an ANWR lease sale is                             The Department sought to implement the 1982 amendment by
             addressed  in regulations published at 50 C.F.R. 37.54(d).                                seeking from each party requesting data a certification of his
                        Commercial use by any,person of data or                                        awareness of the prohibitions on bidding contained in the
                        information obtained as a result of carrying                                   statute.  Such a certification would provide the Department not
                        out exploratory activities and disclosed
                        pursuant to this section is prohibited. No
                        person shall obtain access from the                                            only with a list of requestors (who would presumably be barred
                        Department ... to any data or information
                        obtained as a result of carrying.out                                           from participating in upcoming lease sales) but also with a
                        exploratory activities and submitted by the
                        permittee or a third party until such person                                   statement from the requestor which would be used to demonstrate
                        provides the Department with a statement
                        certifying that person*s awareness of the                                      that, even absent the prohibitions contained in the 1982
                        prohibitions contained in this paragraph and
                        the disqualification [from bidding at lease                                    amendment, the requestor had waived any right it might have had
                        sales)
                                                                                                       to participate in an ANWR lease sale.
                  in commenting on this  regulation, members of the ANWR Survey
                                                                                                            Obviously, the general release by publication of data
             Group also sought additional controls on the release   of raw
                                                                                                       processed by U.S.G.S. gives the general public, including the
             data. The Department responded to these concerns in    the preamble
                                                                                                       direct competitors of,the survey group members, access to
             to the Final Rule but failed to make the  requested changes.
                                                                                                       valuable seismic data, which, had they requested it from the
                        No changes have been made to (the definitions
                        of raw and processed data) because.of the                                      Department, would have triggered the restrictions contained in
                        intervening amendment ...  The Service
                        considers the commenterla concerns about the                                   the 1982 amendment. Further, since the data are released by
                        harm that could be done to the competitive
                        positions of permittees should their seismic                                   publication, the Department has no record of those potential
                        tapes be made available to the public and
                        their competitors as raw data and the                                          bidders that have received data nor any statement.by them waiving
                        consequent disincentive that the Service's
                        disclosure provisions provided.to                                              their right to bid. Thus, the entire objective of the 1982
                        participation in the exploration program to
                        have been mooted by the [amendment].. [The                                     amendment is vitiated by publication.
                        amendment] should restore the economic
                        incentive needed by industry to participate                                         Apparently in an attempt to reduce the potential
                        in exploration of the coastal plain.
                        According to its legislative history, the                                      commerciality of the processed data published in the draft ANWR
                        purpose of (the amendment) is to put all
                        commercial interests on an equal footing by                                    report, certain identifying data were deleted from the processed
                        denying any company that gets data and
                        information.from the Department,or from any                                    seismic.sections contained in Plate 5.   For instance, the precise
                        party other than a permittee from

                                             -44-

             locations of the ends of the published sections have been deleted                             II. NO DATA WHICH PERTAINS TO AREAS OUTSIDE OF THE
                                                                                                                 ANWR 14AY BE RELEASED IRRESPECTIVE OF ITS FORM.
             along with the locations of the individual shotpoints. Despite
                                                                                                             Another data disclosure problem, potentially even more
             this attempt, enough identifying information was included,
                                                                                                        serious than the disclosure of U.S.G.S. processed data, has also
             inadvertently or otherwise sufficient to locate the geologic
                                                                                                        arisen as a consequence of the publication of the draft report.
             features identified in those sections with sufficient precision
                                                                                                        That problem is the disclosure of data collected outside the
             to make the data very commercial.                                                          refuge boundary pursuant to State of Alaska permits but submitted
                  For example, several of the sections are published in their                           to the D .epartment in order to aid its evaluation of ANWR.
             entirety and.the line identification numbers are shown. The                                     At the time that the exploration plans were submitted, the
             precise location of these lines are available to the public on                             applicable regulations required that the permittee submit to DOI
             maps submitted in conjunction with the exploration plans.                                  "all data and information obtained as a result of carrying out
             Further, some of the sections are tied to existing wells outside                           exploratory activities." 50 C.F.R. 37.53(a).
             the refuge. Since the location of these wells is precisely                                      Each submission was required to contain:
             known, the location of structures within the refuge may be easily
                                                                                                                  1) An accurate and complete record of each
             extrapolated.                                                                                        geophysical survey conducted under the
                                                                                                                  permittee's permit,
                  In short, to the extent that U.S.G.S. processed data has                                        2) All seismic data developed under the
             been published, its confidentiality and hence its value to the                                       permit.
             survey group has been irrevocably compromised. Since a small                               50 C.F.R. 37.53(b).
             amount of the data has actually been published, the group's                                     The regulations define certain terms used above as follows:
             competitive position has already been severely damaged. Further,                                     (i) "Exploratory activities" mean ... seismic
                                                                                                                  expl3ration ... of the coastal plain ... and
             disclosure of data as yet undisclosed will render the group's                                        any other type of geophysical exploration of
                                                                                                                  the coastal plain which involves or is a
             investment of over $40 million virtually worthless.    Thus, should                                  component of an exploration program for the
                                                                                                                  coastal plain involving surface use of refuge
             it become apparent that further unauthorized disclosure of                                           lands ... .
             U.S.G.S. processed data is intended, the group will be forced to                                     (p) "Raw data and information" means all
                                                                                                                  original observations and recordings in
             consider whether legal action is appropriate to enjoin it.                                           written or electronic form ... obtained
                                                                                                                  during field operations.

                                                                                                                  (w) "Special use permit" means a revocable
                                                                                                                  nonpossessory privilege issued in writing ...
                                                                                                                  authorizing the permittee to enter and use

                                             -16-                                                                                      -17-

                         the refuge for a specified period to conduct                                                   the [Government] all data obtained during
                         exploratory activities ...                                                                     this program which ties to adjacent areas.
              50 C.F.R.  37.2.                                                                               Special Use Permit 83-C10, Special Conditions 22.

                    Thus, the regulations require the submission of only      data                                Obviously, the Department's authority to require the
              collected as a  result of "exploratory activities" and those                                   collection and authorize release of geophysical data in this
              activities  are limited by definition to the exploration of the                                instance is limited by the plain language of the statute and the
              coastal plain or other types of geophysical exploration of the                                 rules for activities conducted within the ANWR. indeed, the

              coastal plain involving the surface use of refuge lands. Given                                 Department cannot even authorize, let alone require, the
              this framework, It would have been impossible for a prospective                                collection of data on state lands or in state waters.

              permittee to infer from the regulations that it would be required                                   Further, geophysical data is generally exempt from

              to submit (and thus possibly subject to public disclosure) data                                disclosure under the Freedom of information Act, 5 U.S.C.        S52

              collected outside of the coastal plain.                                                        ("FOIA"), and would undoubtedly be considered confidential "trade
                   Apparently, however, Departmental officials became aware                                  secrets" pursuant to IS U.S.C. S 190S (the"Trade Secrets
              through informal discussions with group members that data would                                Act"). That is, seismic data is generally to be held
              be collected outside the refuge in order to provide an integrated                              confident ial by government officials unless its    release is

              data base to the group members. However, no communications were                                authorized by statute as.opposed to most other.types of data

              made by the Department to the group that the Department expected                               collected bythe government, which are subject to disclosure
              to receive any off-refuge data until the Record of Decision                                    unless prohibited by statute.
              ('ROD"i was issued regarding the approval of the exploration                                        In view of the general exemption of seismic data from

              plan. It stated:                                                                               disclosure (discussed more fully above) express statutory
                         (8) Copies of any well tie-in data obtained                                         authorization is required to release seismic data in'the
                         during the surveys will be provided to the
                         Government- The Gov;rqe:et agit!.protect the                                        government's possession. However, ANILCA jurisdiction pertains
                         proprie ary niture o   t
                                                                                                             only to data collected in the ANWR itself    and no other.statute
              ROD I Conditions of Approval, I C (8) at p. 7 (emphasis added).
                                                                                                                                                      ially since they were
                                                                                                             authorizes release of these data espec           I
                   It did not mention the submission of other data collected
                                                                                                             obtained on state lands rather than federal lands. Thus, no
              outside the refuge. The Special Use Permit itself, however,
                                                                                                             statute authorizes release of off-refuge data and any further
              states:
                                                                                                             release would constitute a   violationof 18 U.S.C. 1905.
                         22.  In addition to data obtained from the
                         coastal plain, the permittee shall submit to

                                               _18-                                                                                           _19-

                  The significance of this problem is heightened by the fact                              the group will be forced to consider the appropriateness of legal

             that much of the off-refuge data in question was collected in                                action to enjoin any further releases of off-refuge data in order

             State of Alaska waters offshore of the ANWR from the eastern edge                            to prevent further competitive harm.

             of Camden Bay to an area eastward of the boundary of the Coastal
                                                                                                                                       CONCLUSION
             Plain survey area. This area is to be offered for lease in State
                                                                                                               Congress enacted ANILCA's prohibitions on the release of
             of Alaska Sales 50 and 55, currently scheduled for June, 1987 and
                                                                                                          privately collected geophysical data in order that the companies
             June, 1988. Industry interest in the sale is high and the group
                                                                                                          that funded the seismic survey of the ANWR would not be required
             is aware that many companies who were not members of the ANWR
                                                                                                          to forfeit their investment. Concomitantly, the passage of the
             survey group are interested in bidding. By contrast review of
                                                                                                          1982 amendment signaled Congressional concurrence in the position
             off-refuge data is not necessary to informed debate over the
                                                                                                          that carefully controlled disclosure of raw data, but not
             conclusions drawn in the draft report.
                                                                                                          processed data, would enable those who desired it to p@irticipate
                  in spite of this, the Department published some off-refuge
                                                                                                          fully In the ANUR debate.
             data. in the draft report. In spite of the express representation
                                                                                                               However, the Department has released processed data by
             that "the Government would protect the proprietary nature" of
                                                                                                          publication in direct violation of Section 1002, completely
             well tie data contained In the ROD, extensive well tie data are
                                                                                                          vitiating the statutory protection. Further. it has breached its
             published in Plate 4 of the report and are illustrated on lines
                                                                                                          promise to protect the confidentiality of well-tie data and has
             84-1, 84-5. 85-2 and 85-8, while offshore, state water data are
                                                                                                          released highly proprietary data collected outside the ANWR
             apparently published on lines 85-8, 84-10 and-85-1. in addition,
                                                                                                          without statutory authority and in direct violation of 18 U.S.C.
             Line 85-1 projects into the State of Alaska lease sale 55 area.
                                                                                                          1905 -- data which is unnecessary to informed public debate but
             These disclosures are not only unauthorized but in the case of
                                                                                                          which is essential to companies wishing to participate in State
             well tie data constitute a blatant breach of promise for which
                                                                                                          of Alaska Sales 50 and 55.
             the Department is clearly liable.
                                                                                                               We-trust that the Department will understand the seriousness
                  As in the case of U.S.G.S. processed data there is no way
                                                                                                          of its past@ awti6Aaand:. take steps to ensure that they will
             that the competitive harm  that disclosure has already caused can
                                                                                                          cease. The rec6m&en@atlnns contained in the draft report and its
             be undone. Further, as in   the case of U.S.G.S. processed data,
                                                                                                          analysis of the  issues are generally commendable and, as

                                                                                                          demonstrated in  the public hearings in Anchorage and Washington

                                                                                                          many members of  the survey group have actively supported the

                                             -20-                                                                                         -21-

             Department's position. It would be a shame were that

             relationship to be marred by continued Departmental violations of

             its own guarantees of confidentiality.

                  Geophysical Service Inc. is the geophysical contractor and

             the authorized representative of the following companies of the

             GSI ANWR Exploration Group who have authorized submission of

             these comments:

                  AMERADA HESS CORPORATION        MURPHY OIL USA, INC.

                  AMOCO PRODUCTION COMPANY        PETROFINA DELAWARE, INCORPORATED

                  ARCO ALASKA, INC.               PLACID OIL COMPANY

                  CHEVRON U.S.A. INC.             SHELL WESTERN EXPLORATION AND
                                                   PRODUCTION INC.

                  CONOCO INC.                     STANDARD ALASKA PRODUCTION COMPANY

                  ELF AOUITAINE PETROLEUM         SUN EXPLORATION AND PRODUCTION
                                                   COMPANY

                  EXXON COMPANY, U.S.A.           TENNECO OIL COMPANY
                  (a Division of Exxon Corp.)

                  KERR-McGEE CORPORATION          TEXACO INC.

                  MARATHON OIL COMPANY            UNOCAL

                  140BIL OIL CORPORATION          UNION TEXAS PETROLEUM
                                                   CORPORATION

                                            -22-

    DO YOU WANT TO MAKE PUBLIC COMMENTS?

    If you would like to speak at the hearing today, please fill in the blanks
    below and turn it in to one of the Fish and Wildlife Staff members present.
    You need not complete this sheet to submit written comments.  Thank you.

    Please print

    Name  Roger C. herrera
    Mailing Address 	P.O. Box 196612
    			Anchorage, AK 99516

    Check appropriate box below:

    	I am here to offer my own views.
    			-or-
    	I am speaking for Standard Alaska Production Co
    				(please enter name of organization your represent)

    						TESTIMONY OF

    				STANDARD ALASKA PRODUCTION COMPANY

    						ON THE

    			DRAFT LEGISLATIVE ENVIRONMENTAL IMPACK STATEMENT

    						FOR THE

    				ARCTIC NATIONAL WILDLIFE REFUGE, ALASKA

    					COASTAL PLAIN RESOURCE ASSESSMENT

    						January 5, 1987

    						PRESENTED BY:

    					ROGER C. HERRERA

    				MANAGER EXPLORATION AND LANDS

                 Mr. Chairman:                                                                             reserves and production, anu at the same time         indulge in

                                                                                                           responsible conservation if we are to preserve our life-
                 my name is Roger Herrera   and I ant rep.resenting the Standard                           style.

                 Alaska Production Company  with whom I am employed as Manager

                 of Exploration and Lands.                                                                 The Coastal Plain of ANVIR figures       prominently both as a

                                                                                                           possible source of major oil supplies and as means to
                 The 1002(h) report has two    great attributes which are not                              assuage man's yearnings for the aestheti       cs of solitude,
                 0ften seen in environmental    impact statements - it is short                            s@enery, and wildlife.

                 and readable.    The authors  are to be complimented because
                 these praiseworthy characteristics   have probably resulted    in                         Without Coastal Plain oil it is perhaps pertinent to mention
                 the report   having  been read in    its entirety by    a lar'ye                          that   the   aesthetic   experience   of   wilderness - that   is
                 number of  people.   The nature of..the decision to     be made                                   d to be the    alternate goal to development will      be
                                                                                                           perceive
                 rega.rding the C .oastal Plain. of   Arctic  National    Wildlife                         available only to an    elite few.,   It is also reasonable    to
                 Refuge obviously demands a careful   and dispassionate assess-                            mention that the tens of thousands of Americans and otner
                 mIent ofIthe knowleIdge gained from  thesix years of concen-                              visitors who have   enjoyed a -once-in-a-lifetime trip to the
                 trated study in. the area.      it is our opinion that the                                North Slope in   the past decade have done so because of tne.
                 1002(.h) report sets out that. information in  a meaningful and                           development of   Prudhoe Bay.   Prudhoe Bay has not destroyed
                 relative.ly balanced way. 'it is  an adequate  document to make                           their arctic experience, it     has made it possible, unique,
                 judgments on the'issue.                                                                   and memorab.le.  A small point, but one   worth remembering.

                 You have pre.viously heard testimony. from. the Alaska oil    and                         One aspect of the report requires comment at this Stage
                 Gas Association.    Standard Alaska Production Company        was                         namely, the bias recognizable in the chapters dealing wi       th
                 involved in the preparation of that statement      and endorses                           caribou.   This bias has lead to an emphasis on a proposed
                 it in its entirety.    We believe that the Coastal Plain, of                              mitigation measure, the utilization of the Fish and       Wildlife
                 ANWR must be opened in full to responsible leasing, explora-                              Service mitigation policy.
                 tion, development, and oil production (Alterna.tive A).      Only

                 in that way will our future state and national interests be

                 adequately considered.   We must plan to boost our domestic

                                                                                                                                           2

                in discussing the inappropriateness ot tnis policy in Alaska,                               wolf predation on the fall, winter, ano spring ranges,
                reference must be made to the recently initialed              U.S./                         augmented by human harvest.      It is therefore not logical to
                Canadian Porcupine Caribou Agreement of December 3, 1966.                                   suggest that animal species distribution or abundance would

                                                                                                            change in any biological, meaningful way as a result of the
                The Fish and wildlife service mitigation policy was delib-                                  limited, low-density oilfield construction approach used in
                erately excluded by the U.S. Government from that Agree-                                    Arctic Alaska. ' Recent bird studies (Troy et al 1986) ana
                ment.   if the use of the mitigation policy is unacceptaole                                 fish studies (Craig 1986) support this conclusion, and the
                to the Government in its efforts to achieve conservation of                                 s@eadily increasing caribou populations during the period of
                the Porcupine Caribou herd in conjunction with the Govern-                                  oilfield development also indicate that habitat is not a
                ment of Canada, what justification is     there to impose it on                             confining factor.
                industry in.order to achieve exactly tb'e'. same results on the
                Coastal Plain?                                                                              The only biologically effective approach to assessing and

                                                                                                            mitigating any effects of development on wildlife is to
                The Fish and Wildlife Service mitigation policy and some of                                 determine how industry activities will alter population-
                the biological conclusions in the      . report result from   .  an                         limiting factors for each species of concern, and then to
                assumption that fish and 'wildlife populations using the ANWR                               apply   mitigative    measures    that   avoid   those     limiting
                Coastal Plain are indiscriminately limited by habitat avail-                                factors.   That is quite different from and more practical
                ability.   There is no evidence to support this assumption                                  than the Fish and Wildlife Service policy of preserving
                and, in fact, the report does not cite or discuss any                                       'habitat value'.     .such a policy usually translates into
                evidence to justify that position.                                                          protecting land from change, or ensuring that all change is

                                                                                                            "natural".   This ignores Arctic biology and makes policy
                Nesting birds an the North Slope are in general much more                                   dominant over biology.      It imposes a particular point of
                influenced by weather than they are -by habitat, and there                                  view on the real world without determining whether the real
                are no examples of mammal population size or productivity                                   world conforms with the   imposed viewpoint.

                which has been limited by North Slope habitat availability.
                caribou abundance is believed to approximate prehistoric                                    In this case the policy is flawed and should be       'scrapped in
                levels in the North American Arctic, and it Is generally                                    Alaska.   Likewise some of the proposed mitigating measures

                accepted that caribou productivity is limited principally by                                which result from the policy are unnecessary and often

                                               3                                                                                            4

                 counter-productive.   Many of the mitigating measures that

                 have, been proposed have been  proven to be effective on tne

                 North Slope and are fully      supported by Standard Alaska

                 Production Company.    Our  aim with regard to environmental

                 protection is the same as   the Department of interior's, but

                 we feel strongly that the   end result of oil production with

                 minimum  and   acceptable   environmental    impact cannot    be
                 @chieved using the Fish    and Wildlife mitigation policy in

                 the Arctic.

                 Two other points about the caribou sections of the report:

                 First, the report would be greatly strengthened and balanced

                 if reasonable use had been made of the information and

                 analysis of the expert caribou Canadian biologists, Hergerud

                 Jakimchuk and Bamfield.   Their work has been largely ignored
                                                                   ;A
                 in the draft LEIS and the dismissal of the dissjdent views of

                 Bergerud on Page 110 as 'widely disputed' is      a distortion

                 unworthy of the authors.    Second the so-wcalled core calving

                 areas of the Porcupine herd and the *space        constraints'

                 which the caribou are supposedly subjected to at that time

                 of the year, ignore the fact that many tens of thousands and

                 in some years, hundreds of thousands of Porcupine Caribou

                 calve in Canada.  The maps in the report are misleading ano

                 less than scientific in not depicting.the full calving range.

                 It is our intention, Mr. Chairman, to comment f`n detail on

                 this and other issues in a separate written submission which

                 we hope will be carefully considered.

                                                                                                                               Mr. Chairman:

                                                 TES77MONY OF

                                        THE STANDARD OIL COMPANY                                                                     My name Is Roger Herrera and       I am Manager of Exploration and Lands for the

                                                    ON THE                                                                     Standard Alaska Production Company. Today I am presenting testimony for The Standard
                         DRAFT LEGISLATIVE ENVIRONMENTAL IMPACT STATEMENT                                                      Oil Company.

                                                    FOR THE                                                                          Standard is the largest producer of oll from the state of Alaska and has been
                               ARCTIC NATIONAL WILDLIFE REFUGE, ALASKA                                                         present as an explorer and producer In Alaska since the late 1950's. The 1002(h) report
                                   COASTAL PLAIN RESOURCE ASSESSMENT                                                           has drawn an many scientific and technological studies carried out by or for Standard Oil

                                                                                                                               as is recognized by the bibliography. Based on our long experience of operating In the

                                                                                                                               Arctic, we believe the report is thorough, balanced and fair in Its description of the

                                                                                                                               coastal plain ecosystem and assessment of scenarios of development. It needs some
                                                 January 9, 1987
                                                 Washington, D.C.                                                              modification in the caribou section to make It more realistic, and It does not justify Dome
                                                                                                                               of the proposed mitigation measures, especially the use of the Fish and Wildlife Service

                                                                                                                               mitigation policy. That policy, which concentrates on preserving habitats rather than

                                                                                                                               populations of animaL% cannot benefit wildlife In Alaska. Alaalu4 In particular the North

                                                                                                                               Slope and coastal plain, Is unique in having more habitat than animal species can ever
                                                 PRESENTED BY:                                                                 occupy. Consequently, administrative efforts to protect habitat above all does little   . or
                                               ROGER C. HERRERA                                                                nothing to benefit populations such as caribou, polar beer, musk oxen, etc. The concept
                                     MANAGER EXPLORA71ON AND LANDS                                                             and practice of mitigation Is akin to motherhood and totally accepted by my company,
                                 STANDARD ALASKA PRODUCTION COMPANY                                                            but I know from 25 years experience in the Arctic that the Fish and Wildlife Service
                                                                                                                               m I ti gation policy is a poor protective m echanism and It should be changed.

                                                                                                                                    The success of our mitigation efforts In the put is perhaps measured by the results

                                                                                                                               of a recent public opinion poll In Alaska (Dittman Nov. 1986). 06% of the respondents

                                                                                                                               thought that the oll Industry has operated in an environmentally safe manner at Prudhoe

                                                           -2-                                                                                                                    -3-

               Bay. Only 5% gave negative replies. That accolade was earned not because of                                                                                                                   ose conclusions must
                                                                                                                                     used to arrive at the conclusions on caribou concentration% etc, th
               protective envr1ronmental regulations and stipulations, although they obviously played a                              be wrong.     Caribou calving areas have been mapped annually deep Into Canadian
               Pad, but principally because the operating oil companies pursued a philosophy of care for                             territory, and not to depict the total calving area on the maps Is unscientific and aldn to
               the environment and the animals. This was done for two reasons. First and foremost,                                   Joining the net earth society. This should be rectified.
               because  Iwe are human beings too  Iand have the same appreciation of wilderness and the                                    The three mile    buffer zone precluding development factilitles at the coast to
               esthetics of scenery or sees of caribou as anyone elm.. Secondly, -there is a clear logle                             protect caribou inseet relief areas is  unnecessary. Caribou use of that zone Is sporadic
               and self-interest In not doing things wrong In the Arctic. A simple example Is an oil spill
                                                                                                                                     and ephemeral and southern areas of the coastal plain are.mueh more important to the
               on a gravel pad or the tundra. The spill Itself out the value of the oll--perhaps a few
                                                                                                                                     herd then the northern fringe.
               dollaM but the cost of clean up is usually measured In thousandis, tens of thousands, or
                                                                                                                                          standard Oil supports Alternative A. We appreciate the opportunity to testify and
               millions of dollars. The incentive not to spill oil quickly becomes very clear, as does the                           will submit detailed written comments In due course.
               Incentive to design better equipment to prevent oil opills.

                    It Is perhaps worth mentioning, In passing, that the statistics an off spills contained

               In the report are no doubt correct and represent the facts of life of working outside at 40
               or $00 F below zero in a harsh environment. What is not mentioned Is the fact that the

               vast majority of those spills occur on gravel pads or roads and that all of them are totally

               cleaned up.

                    A. recognition of this effort Is seen In the figure of 83% of Alaskan respondents
               (Nov. 186 Dittman poll) who believe that the oil Industry on operate safely in wildlife

               refuges in Aluka.

                    The success of future development on the coastal plain of ANWR will be achieved

               in two ways. one, by continuous and friendly consultation and coordination between

               Industry, native residents and refuge managers and other Fish and Wildlife Service

               personnel, and secondly, by repeating and enhancing the philosophy and practice which

               has worked so, well at Prudhoe, Kuparuk, MUne Point and Endicott. Surely those two

               requirements are not beyond our capability?

                    Before closing let me mention some aspects of the report that require attention.

               The maps depicting caribou calving areas are less then truthful      and If they have been

                                   Shell Western EV Inc.                                                                                                                                           2

            Thomas F Hart                  February 2, 1987                     PO.BoxS76                              We would like to offer an alternative price scenario which is used in a
            P-dent                                                             Houstonje,as 77001                      National Petroleum Council report on U.S. Oil and Gas Outlook, published
                                                                                                                       in October 1986, and which was suggested by.the Department of Energy to
                                                                                                                       be the basis for the outlook report. This range of "plausible prices" is
                                                                                                                       between $21 and $36 (1986S). A copy of the letter suggesting this range
                                                                                                                       is attached. We believe this price projection is more realistic than that
               Director                                                                                                currently contained in the 1002 report and we urge the Department of
               U.S. Fish and Wildlife Service                                                                          Interior to consider using it in the final report submitted to Congress.
               Division of Refuges
               United States Department of Interior                                                                    Thank you for this opportunity to comment.
               Room 2343, Main Interior Building
               18th and C Streets                                                                                                                               Sincerely,
               Washington, D.C. 20240

               Dear Sir:
               SUBJECT: ARCTIC NATIONAL WILDLIFE REFUGE - RESOURCE EST114ATE                                                                                    Thomas F. Hart
               Shell Western EAP Inc., a subsidiary of Shell Oil Company, appreciates                                  MBD:DK
               this opportunity to comment on the draft proposal for opening the
               coastal plain of the Arctic National Wildlife Refuge to oil and gas                                     Enclosure
               leasing, development and production.

               Shell Western supports the Department of the Interior's "Alternative A"
               recommendation, full leasing of the "1002" study area. We concur with
               the 001's statement that this area is an outstanding oil and gas frontier
               and could contribute significantly to our domestic energy supplies.

               In this era of rapidly 'Increasing oil imports. it is imperative that the
               United States look toward the future when the need for domestic sources
               of oil and gas may be critical, and remember what *occurred in the 1970s
               when OPEC manipulated the market to our disadvantage. Surely, the
               American people and their representatives in Congress do not wish a
               reenactment of those circumstances in the future. If we can find.
               develop and produce the potentially vast resources on the ANWR coastal
               plain, we can lessen the potential impact of an OPEC-induced energy dis-
               ruption 10 to 15 years from now. and b"ond.

               Further, Shell Western endorses the detailed comments on the assessment
               offered by the Alaska Oil and Gat Association and the American Petroleum
               Institute, of which we are a member.

               We do, however, wish to make a specific comment regarding the price prem-
               ises used in the report. On page 72, Table 111-4, entitled "Significant
               Economic Assumptions," states.that the most likely crude oil market price
               in the year 2000 (1984$) would be $33/88L, and that an optimistic price
               would be $40/88L. This range of prices, when corrected to 1980, using
               the GNP deflator, is $35 to $42.50.

               CRAO8703302.                                                                                            CRA08703302

                                        Department of Energy
                                            WashirOon. DC 20565

                                                          May 14. 1986

                      Mr. James L. Ketelsen
                      Chairman and Chief Executive Officer
                      Tenneco incorporated
                      Tenneco Building
                      Post Office Box 2511                                                                                  US. Oil &Gas Outlook
                      Houston. TX 77001
                      Dear Mr. Ketelsen:                                                                                                An Inter im Report of the
                          Immediately following the April 22, 1986, meeting of the
                      National Petroleum Council (NPC) Committee on U.S. oil and Gas
                      Outlook. the Coordinating Subcommittee met. A prime agenda item                                           National Petroleuffi                                 ounci
                      was to discuss critical path items for the  study examining the
                      primary factors affecting the Nation's future supply and demand of
                      oil and gas.
                          It was agreed that the Department of Energy woul   .d provide two                                                                        Ortober 1900.863
                      oil, price cases intended to suggest a range of Plausible prices as
                      ;
                      ssumptions for the purpose of this study. In response. we would
                      ropose the following simplified cases:
                          1.    Case A      Starting at 312 per barrel in 1986 and
                                            increasing by four  rcent, per year to
                                            about $21 per ba , -rin the year 2000.
                           2.   Case 0      Starting at $18 per barrel in 1986 and
                                            increasing by five percent per year to
                                            about $36 per barrel in the year 2000.
                      These oil prices are expressed in 19B6 dollars and should    be
                                                                   -quisition Cost.
                      interpreted as the U.S. Composite Refiner Ar
                           We appreciate the efforts of you and the other NPC members on
                      :this most important study.
                                                           Sincerely.
                                                                                                                                                                    James L. Ketelse4 Chairman
                                                                                                                                                        Cornmittm onUS. Oil &Gas Outlook

                                                           Donald L. Bauer
                                                           Acting Assistant Secretary
                                                             for Fossil Energy

                      CC:
                      Marshall Nichols                  C-2

                                         Comments of
                   THE STANDARD OIL COMPANY

                                                                                                                                    COMMENTS OF STANDARD OIL COMPANY

                                                on the                                                                                          ON THE
             Draft Legislative Environmental Impact Statement                                                               DRAFT LEGISLATIVE ERVIROMemAL IMPACT STATEMWT
                                                                                                                                                FOR THE

                                                                                                                                ARCTIC NATIONAL WILDLIFE REFUGE, ALASKA

                                                                                                                                   COASTAL PLAIN RESOURCE ASSESSmENT

                T                                                                                                                           February 6, 1987

                                                for the
                           Arctic National Wildlife Refuge, Alaska

                            Coastal Plain Resource Assessment

                                                   SUMMARY COMMENTS
                                                         OF THE
                                                  STANDARD OIL COMPANY
                                                         ON THE                                                                              The Porcupine herd calves annually in         greatly varying locations
                                  DRAFT LEGISLATIVE ENVIRONMENTAL IMPACT STATEMENT                                                           within an approximate 200-mile east-west area stretching from the
                                                        FOR THE                                                                              Canning River in Alaska to the Babbage River In the Yukon,Territory.
                                       ARCTIC NATIONAL WILDLIFE REFUGE, ALASKA
                                          COASTAL PLAIN RESOURCE ASSESSMENT                                                                  in any given year, the majority of the Porcupine herd will calve
                                                                                                                                             2utaide of the supposed "core" area.       Concentrations may not occur
                                                                                                                                             inside the "core" area at all.         In 1982 and 1986, for example,
                  The Standard Oil Company has prepared detailed analytical comments on the                                                  nearly all calving occurred in Canada.
                  draft report plus line by line suggestions, corrections and comments. These
                  comments are presented in two sections:           general comments and specific                                            The "core" area near the Jago River was defined       by FWS on the basis
                  comments, and include considerable detail on the subjects mentioned below.                                                 of freguency of overlan of mapped calving concentration areas, a"
                                                                                                                                             DA the basis of actual densities of caribou.
                  Standard Oil Company identified several major weaknesses which require
                  special attention in the final LEIS.           Nevertheless the report clearly                                        0    There is no firm basis for defining a "core" calving area; the FWS
                  supports our     recommendation to      lease    the ANKH coastal plain under                                              criterion of overlap was arbitrary:        mapped concentrations had to
                  Alternative A.                                                                                                             overlap in at least 5 of 14 years (only 36% Percent of the time).
                                                                                                                                             It is thus very inappropriate to imply that this area is "critical"
                  Our comments and observations,include:                                                                                     to the continued existence of the caribou and warrants designation
                                                                                                                                             as Resource Category 1, which would essentially preclude any oil
                  &JERNATIVE                                                                                                                 and gas development.
                       0    Alternative A       full leasing        offers the greatest       potential                                 9    The methodology and data analysis was flawed in defining the "core"
                                                                                                                                             calving area:     (1) there are no data to provide a quantitative
                            benefit of the leasing options with significantly more resource
                            potential (3.2 billion barrels versus 2.6 billion) than Alternative                                              basis for the density criteria of 50 caribou/square mile (many
                            B.                                                                                                               areas had densities of less), and (2)             the maps of calving
                                                                                                                                             concentrations used by FKS vary from the originals and appear to
                       0    Delay in leasing the so-called "core calving area" has significant                                               have been misplotted.
                             0
                                ti- I- cts! the area as depicted in the draft report covers
                              3A____                                                                                              UNR M ISTICKLLY NEGATIVE PREDICTIONS OF THE 1002 REPORT
                            three geological prospects (two of them of large size.- 30 X 7
                            miles and 21 X 4 miles), which are said to have potential for the
                            presence    of   the   prospective Sadlerochit sandstone          reservoir                                 Flawed assumptions and methodology have resulted in environmental impact
                            intervals - the principal reservoir at.Prudhoe Bay.                                                         conclusions that are consistently extreme . Problems includet
                            The U.S. domestic energy situation is even more serious then that                                           0    Application of the FWS Mitigation Policy, which assumes habitat is
                            portrayed in Chapter VII of the report and the contribution of                                                   limiting to the wildlife populations of concern in ANKH; this Is
                            ANWR's potential resourcesare greater than depicted.                                                             not supRorted by the scientific evidence;
                            Projections on the economic impact of the development of the ANWR                                           9    The habitat-based approach, stemming from that policy, has been
                            coastal plain's hydrocarbon resources may be underestimated by the                                               used to assess. impacts by simply overlaying very general "maps of
                            DOI, given major trends in the oil          industry and energy picture                                          fish and wildlife areas" with hypothetical development scenarios.
                            during the past 18 months.                                                                                       The results were used to quantify predictions of wildlife habitat
                                                                                                                                             losses, disturbances, and even mortality.             Such a methodoloqv
                                                                                                                                             applied to Prudhoe Day would predict major decreases in wildlife
                  THE CARIBOU CORE CALVING ARE                                                                                               1D01?Ul&ti0R8-  The Prudhoe Bay experience shows that this does not
                                                                                                                                             o cur.
                       0    There is no single, fixed, "Core" calvigg area uned by the
                            Porcupine caribou herd and uniquely necessary for.- Its continue                                            0    Unrealistic assumptions of concurrent development for 3 major
                            well-wbeing.                                                                                                     fields.    If three fields of different sises were discovered
                                                                                                                                             simultaneously (which is highly unlikely), the largest field would
                       0    The Porcupine herd shows no fidelity to a specific area in               the                                     inevitably be developed first.       The development of Prudhoe Bay in
                            coastal plain for calving.                                                                                       1977, Kuparuk in 1981 and Lisburne In. 1987 illustrates this.            They
                                                                                                                                             were all discovered in 1968-2959.'

                                                                                                                                                                             2

                         impact conclusions which appear to ignore existing laws and                                      THE USFWS MITIGATION POLI_CY
                         regulations that currently govern oil and gas activities.                                            0     The  FWS Mitigation Policy       forms   the   basis   for    biological
                         Use of non-primary,      out-dated,   out-of-context, or incomplete                                        assessments and proposed mitigation approaches in the draft
                         documentation upon which the report's conclusions were based.                                              report. The FWS policy assumes, as a basis for analysis, that the
                                                                                                                                    size and growth potential of wildlife populations are limited by
               "SPHERES  OF INFLUENCE"                                                                                              habitat availability. The validity of this principle in the Arctic
                                                                                                                                    is not supported by scientific evidence. Therefore, habitat-based
                         Every structure, road or facility has been assigned an arbitrar                                            conclusions and mitigation recommendations in the draft report are
                         "sphere of influence" an wildlife (e.g. caribou, muskox).         it is                                    generally unrealistic.
                         assumed that total displacement of animals occurs from these                                         0     A better approach to mitigation is to focus on population limiting
                         areas. This is not realistic                                                                               factors. Mechanisms by which the size and growth of a population
                    �    Furthermore, it is assumed that passive facilities sited within th                                         ar:, linked should be identified and then managed to achieve a
                                                                                                a                                   As red population level.
                           -called "core" calving area could cause a decline of 20-40% of
                         the PCO . There is no justification for this conclusion.                                             0     Population-limiting factors acting on arctic wildlife vary with
                    �    Experience   at  Kuparuk    shown   that calving caribou are not                                           species.   Such factors Include shortness of the summer snow-free
                         significantly displaced by facilities,       and their reproductive                                        period, predation, severe winter conditions, and characteristics of
                         success in not diminished.                                                                                 winter range used by migratory species when absent from the
                                                                                                                                    Arctic.   Availability of high value habitat -- the basis for the
               INSECT HA RAS SMENT AND USE OF THE COAST FOR ROLIE                                                                   FUS Mitigation Policy -- has not been shown to limit most arctic
                                                                                                                                    wildlife species.
                         The 1002 report emphasizes insect harassment and the importance of
                         insect-relief habitat to caribou, stating that insect harassment is                              EXISTING  REGULATORY STRUCTURE AND INDUSTRY PRACTICES
                         one of the primary driving forces in the annual caribou cycle.                                       0     The report fails to review the existing regulatory framework
                    �    The report describes the coastal strip of the 1002 area as                                                 governing   petroleum    leasing,    exploration,    development,     and
                         critically important insect relief habitat and concludes that                                              production In arctic Alaska, creating an Impression that these
                         east-west roads and pipelines will essentially block access to this                                        activities occur In a regulatory vacuum. The report also fails to
                         habitat with detrimental consequences to the caribou population.                                           document current (and evolving) industry practices that routinely
                                                                                                                                    accomplish    significant    mitigation    of    potentially      adverse
                    �    These conclusions are in error becauset                                                                    environmental effects.
                              Annual migration cycles do not correlate with                insect                         RECOMMENDATIONS OF TER STANDARD OIL C9WANY
                              conditions in many years.
                                                                                                                          The Draft ANNE Coastal Plain Resource Assessment establishes a basis for the
                              Coastal areas are generally visited for only a short period of                              production of a credible final report to Congress supporting full, leasing
                              time. Some years they are not visited at all.                                               (Alternative A) of the AM coastal plain, with the following recommended
                                                                                                                          revisionst
                              Blockage of migration is a non-issue since pipelines and roads
                              can be built to permit passage, and traffic controls can be                                     1.    Update of Chapter V11 to reflect probable effects of the 1986 price
                              implemented as necessary. (Prudhoe Say has clearly not proved                                         collapse on future U.S. energy reserves and the contribution of
                              to be an I " diment to the Central Arctic caribou hard.)                                              potential ANWR petroleum resources;
                              It In doubtful that even a major thyRothetical) loss of the                                     2.    Re-evaluation of the caribou literature and revision of analyses
                              coastal frince habitat would prove to be of significant                                               relating to the -core calving area" concept, the "sphere of
                              cons2gueAce to the Porcupine herd.                                                                    influence" hypothesis, and the importance of insect relief in
                                                                                                                                    driving the caribou annual cycle;

                                                       3                                                                                                          4

                                                                                                                                              INDEX OF COMMENTS PROVIDED BY STANDARD OIL COMPANY

                                                                                                                                               DRAFT LEGISLATIVE ENVIRONMENTAL IMPACT STATEMENT
                       3.    Modification    of     impact    assessment    methods     to     eliminate                                           ARCTIC NATIONAL WILDLIFE REFUGE, ALASKA
                             over-simplified analyses based on "reductions in habitat value";                                                          COASTAL PLAIN RESOURCE ASSESSMENT
                             examination of known population- limiting factors acting an caribou                                                                                                             PAGE
                             and other wildlife species of concern;                                                        INTRODUCTI                                                                        i
                       4.    Revision of development scenarios to reflect a sequential series of                           GENERAL   C
                             oilfield developments rather than assumed concurrent developments,                                 1.   U.S. FISH AND WILDLIFE SERVICE MITIGATION POLICY                        G-1
                             with corresponding revision of environmental            assessments     and
                             @conclusions;
                                                                                                                                2.   HABITAT-BASED ASSESSMENTS OF    BIOLOGICAL CONSEQUENCES                 G-2
                       5.    A critical review of applicability of the FWS Mitigation Policy as                                                                                                              G-9
                             applied to the North Slope of Alaska and species of concern,                                       3.   BIOLOGICAL ASSESSMENT   .PROCEDURE
                             including caribou, muskozen. polar bear, snow         .geese, and arctic.                          4.   UNREALISTICALLY Z)(TRBMR PREDICTIONS                                    G-12
                             char; and
                       6.    Review and documentation of the existing regulatory framework and                                  5.   DOCUMENTATION                                                           G-20
                             standard industry practices in arctic Alaska, and revision of
                             environmental assessments and mitigation recommendations to reflect                                6.   CARIBOU                                                                 G-23
                             these.                                                                                                  A. The Porcupine Caribou Hard Calving Grounds                           0-24
                                                                                                                                     B. Density of Caribou in Calving Concentration Areas                    G-29
                                                                                                                                     C. Sixe and Location of Calving Concentration Areas                     G-32
                                                                                                                                     D. The Question of Insect Harassment                                    G-34
                                                                                                                                     E. Importance of,the Coast an Insect     Relief Habitat                 G-37
                                                                                                                                     F. The Question of Differences Between Herds                            C-39
                                                                                                                                     G. Response of Caribou to Oilfield Development                          G-40

                                                                                                                                7a   WATER AND GRAVEL AVAILABILITY                                           0-42
          OD
           4                                                                                                                    S.   AIR AND WATER QUALITY                                                   G-44

                                                                                                                           SPECIFIC COMMENTS

                                                                                                                                CHAPTER 1.       PURPOSE AND NEED FOR THIS REPORT                            S-2

                                                                                                                                CHAPTER 11.      EXISTING ENVIRONMENT                                        S-5

                                                                                                                                CHAPTER  111.    ASSESSMENT OF OIL AND GAS POTENTIAL AND                     S-22
                                                                                                                                                 PETROLEUM GEOLOGY OF THE COASTAL PLAIN

                                                                                                                                CHAPTER  IV.'    DEVELOPMENT AND TRANSPORTATION INFRASTRUCTURE               S-22

                                                                                                                                CHAPTER  V.      ALTERNATIVES                                                S-33

                                                                                                                                CHAPTER  VI.     ENVIRONMENTAL CONSEQUENCES                                  S-35

                                                                                                                                CHAPTER  VII     OIL AND GAS -- NATIONA  L NEED FOR DOMESTIC                 S-86
                                                                                                                                                 SOURCES AND THE 1002 AREA'S POTENTIAL CONTRIBUTION

                                                                                                                                STANDARD OIL COMPANY RECOMMENDATIONS                                         S-87

                                                                                                                           LITERATURE Cl                                                                     L-1

                                                                                                                           APPENDIX              SAPC TESITHO , January 5, 1987
                                                                                                                                                 SPC TESTIMONY. January 9, 1987

                                                             5

                                                INTRODUCTI

                                                                                                                             1. U.S. FISH AND WILDLIFE SERVICE MITIGATION POLICY

          Standard Oil Company has conducted a thorough review and analysis of the Draft
          Arctic National Wildlife Refuge (ANWR) Coastal Plain Resource Assessment and                                       The draft report contains flaws in biological assessment that apparently stem
          Legislative Environmental Impact Statement (LEIS) published by the U.S. Department                                 from inappropriate application of the U.S. Fish and Wildlife Service's '(FWS)
          of the Interior in November 1986. He command the authors for producing a report                                    nationwide Mitigation Policy (FWS 1981) to the Arctic.      Biological assessments
          that is brief and readable.       Based on our long experience of operating in the                                 presented in the draft report follow a standardized habitat-based approach
          Arctic, we believe the report reasonably represents the substantial body of                                        which, as explained below, has no real basis for use in arctic environments
          baseline information which will be helpful to support. decisions regarding future                                  where habitat availability in not known or thought to limit most wildlife
          leasing on the coastal plain.                                                                                      populations (for evidence, see General Comment No. 2).         This habitat-based
                                                                                                                             approach leads to easy, unrealistically extreme predictions of reductions in
          We find that the authors need to modify caribou discussions to make assessments of                                 habitat value across large tracts of land and even of potential declines in
          environmental consequences more realistic, and that it does not justify some of the                                wildlife populations.    The draft report's almost total reliance on habitat
                                                                                                                             availability as the basis for biological assessments casts serious doubt on
          proposed mitigation measures.    we question in particular the appropriateness of the
          application of the U.S. Fis    .hand Wildlife Service (FWS) Mitigation Policy to the                               the validity of the report's conclusions and miti   .ga.tion recommendations.
       -Arctic, and the use of that policy as the basis for assessments of potential
          environmental consequences of   petroleum development on the ANWR coastal plain. We                                The draft report's use of the FWS Mitigation Policy in an arctic context leads.
          have attempted in our qener@l and specific comments to explain the biological                                      to a case of reverse logic.     It blaces g2licy first, and biology last.        The
          difficulties inherent in applying the FWS Mitigation Policy to the Arctic, and to                                  text (pp. 95-98) suggests that first, a decision was made to apply the FWS
          provide substantive information that will assist the authors with a reevaluation of                                Mitigation Policy to potential petroleum development on the ANWR coastal
          caribou Issues.                                                                                                    plain.   Second, because that policy to based on the assumption that habitat
                                                                                                                             availability limits any    wildlife species under. review, this assumption was
          We believe that the ANWR coastal plain must be opened in full to responsible                                       Implicitly adopted as     the rationale governing biological ease       ssments of
          petroleum leasing, exploration, development, and production (Alternative A), and                                   potential dove lopment-related effects on coastal plain wildlife, including the
          that Alternative A is entirely compatible with sound management and conservation of                                majority of vertebrate species which are present only during the brief arctic
          the Nation's fish and wildlife resources.         Only in this way will our future                                 summer.    Third, habitat-based mitigation goals and recommendations were
          national interest be responsibly served.                                                                           adopted.   The problem with this reasoning is that it starts with policy, not
                                                                                                                             with biology. it Imposes a particular point of view on the real world without
          Our review comments are presented in two major sections, Gene@al Comments and                                      first determining whether the real world conforms with the imposed viewpoint.
          Specific Comments.    Under General Comments, we address issues that apply to the
          entire draft report, to major sections, or to subjects that receive prominent                                      The FWS Mitigation Policy is intended for nationwide application and does not
          treatment.   Under Specific Comments, we provide a detailed review organized by                                    take geographic differences into account.         It establishes a standardized
          chapter, page, column, paragraph, and line.                                                                        approach to biological Impact assessment based on the concept that habitat

                                                                                                                                                                     G-1

                                                                                                                             numbers   from ever approaching habitat carrying          capacity.     Although a
                   availability limits (or is likely to limit under foreseeable and probable
                   circumstances) the size and biological productivity of wildlife populations in                            habitat-based approach to biological assessment is clearly applicable to
                   their "natural" state, i.e., in the absence of human influence.                 FWS                       geographic areas where habitat availability is known to limit year-round
                   biologists know that this is not always so.     It is often true in the tropics,                          resident wildlife populations (e.g., tropical and some temperate regions), the
                                                                                                                             applicability of such an approach to the Arctic Coastal Plain has yet to be
                   and sometimes true in temperate regions.    However, most evidence (see General
                   Comment  No. 2) indicates that arctic (polar/subpolar) habitat availability                               demonstrated or even convincingly suggested.        Thus a critical reading of
                   does n2t limit the size or productivity of most bird and mammal populations                               Chapter VI, Environmental Consequences, indicates that its entire biological
                   that use arctic (polar/subpolar) regions during part or all of the year.                                  basis may be erroneous, casting serious doubt on the validity of biological
                                                                                                                             conclusions and mitigation recommendations contained therein.

                   if the   FWS mitigation Policy and i&s habitat-based assessment/mitigatio
                   approach are.considered aRRlicable to the Arctic in general and the 1002 are                              Because this is such an crucial point, with important implications for how
                   in Rarticular. the report should be reyised to greglent a clear rationale and                             biological impact assessment should be conducted In the Arctic, we wish to
                   sup2orting evidence for this assertion.                                                                   discuss it at some length. There is no biological principle      . and no eve'ilable
                                                                                                                             evidence that would lead one to presuppose that habitat availability is likely
                   2  RABZTAT-BASED ASSESSMENTS OF BIOLOGICAL CONSEQUENCES                                                   to limit populations of most bird and mammal species inhabiting the ANWR
                                                                                                                             coastal plain during any part of the year. Therefore, it does not make sense
                                                                                                                             to use this assumption as justification for predicting adverse effects of
                   As noted above, biological assessments and conclusions presented in the draft                             ollfield development on wildlife populations. Yet this unexamined assumption
                   report are based, apparently for reasons of policy, on the implicit assumption
          A-                                                                                                                 serves --a the primary basis for biological assessments and predictions
         LM        that wildlife populations using the ANWR coastal plain are limited by habitat
         CD        availability.   This assumption is never stated     outright, but for the draft                           presented in the draft report. Analyses of direct and indirect reductions in
                   report's habitat-based assessment approach to make sense, the assumption must                             habitat value are used to suggest that population declines may result from
                   be there.   It is doubtful that the authors have systematically examined the                              oilfield development, when the described reductions in habitat value -- were
                   proposition,  and it seems clear        that   they   have   not   thought    about                       they actually to occur in the manner and at the magnitudes stated In the draft
                   population-limiting   factors or reviewed      available scientific literature                            report -- would most likely  . have no, detectable effect on reproductive rates,
                   elucidating such factors.     There is no A oriori reason to suppose the                                  recruitment rates, physical c     .ondition, abundance, sex/age composition, or
                   :
                    sumption to be true; yet evidence or even logic supporting its validity is                               overall distribution of wildlife populations inhabiting the 1002 area at any
                   :Lther cited nor discussed.                                                                               time of the year..

                   Obviously, sufficient h abitat (as space, food, cover, etc.) Is a precondition                            We make this assertion because in the Arctic, the availability of habitat has
                   for the existence of any   plant or animal population, but habitat availability                           not been shown or convincingly suggested to be the factor limiting most
                   does not necessarily regulate or limit population size and growth rate.          As                       wildlife populations.    Evidence (discussed below) clearly indicates that most
                   discussed in greater detail below,     animal populations may be limited by a                             animal populations in the Arctic are well below the carrying capacities of
                   great variety of other factors (e.g., snow-free season too short to allow                                 their habitats and are prevented by various limiting factors from ever
                   consistently successful reproduction from year to year, direct mortality                                  reaching those carrying capacities.     Major habitat losses on a regional scale
                                                                                                                             would be required to lower carrying capacities to the point that animal
                   through predation or from severe winter conditions) that prevent animal

                                                          G-2                                                                                                        G-3

                numbers would  be limited as a consequence. For habitat availability to become                              ever to  be approached unless predation and hunting are severely curtailed in
                a population-limiting factor in the ANKR 1002 area. major habitat losses far                                the future (see Bergerud et al. (1984)).
                beyond those predicted in the draft report would have to occur.
                                                                                                                            As a further indication that mainland caribou populations seldom, if ever,
                The following discussions briefly review evidence for population-limiting                                   reach the carrying capacities of their rangesi reindeer (the same species as
                factors acting an a few examples of wildlife species using the Alaskan Arctic                               caribou, Rangifer tarandus) introduced to islands relatively free of predation
                Coastal Plain.                                                                                              and hunting pressures have reached population levels far exceeding those of
                                                                                                                            mainland caribou in North America.      On St. Paul Island in the Bering Sea,
                A. Mammals                                                                                                  Introduced reindeer reached a density of 49 per square mile before declining
                                                                                                                            from over-grazing (Schaffer IM).          On St. Matthew Island, an entirely
                We have found no evidence that arctic populations of large mammals are limited                              different study found that introduced reindeer peaked at 47 per square mile
                by habitat availability, except in cases Involving Island introductions of                                  before declining (Klein 1968). on South Georgia Island in the South. Atlantic,
                reindeer and muskozen not subject to hunting and predation (e.g., Klein 1968,                               Introduced reindeer reached 58 per square mile before declining (calculated
                Smith 1984). Continental caribou populations are probably limited by volt and                               from Leader-Williams (1980)].     All these herds, and apparently 8130 one in
                other predation augmented by human harvest (Bergerud at al. 1984), and herds                                West Greenland where predation    and hunting were absent (Roby 1980), eventually
                calving on the Arctic Coastal Plain have steadily increased during the period                               declined because of food shortages that would not have occurred had the herds
                of oilfield development.      Mainland caribou  .herds (including the Porcupine,                            been reduced in the normal fashion by predation and hunting.
                Central Arctic, and Western Arctic) typically have less than 2 individuals per
                square mile of the area over which they range (Bergerud 1980)                                               Some biologists have suggested that caribou herd declines in North America in
                                                                                              Several
                estimates of numbers of caribou that could (theoretically) be supported on                                  the early 1900a were caused by winter forage (mainly lichen) destruction by
                various  caribou ranges are available.       Bergerud (1980) reported that the                              forest fires (Edwards 1954, Scotter     1967).  But more rigorous analyses (e.g.,
                carrying capacity of the region over which the Fortymile herd in Alaska ranges                              Klein 1967, Renshaw 1968, Miller 1971, Bergerud 1974, Kelsall and Klein 1979,
                is about 13 animals per square mile.       A simulation model for the Kaminuriak                            Roby 1980) suggest that starvation or even observable debilitation in caribou
                herd in  Canada (Walters at al. 1975) also predicted a density limitation on                                in winter Is rare except in populations Isolated from predators and prevented
                food at about 13 animals per square mile. A similar model for the Porcupine                                 from dispersing to unoccupied habitats.      In Newfoundland, where caribou access
                herd in Alaska and Canada indicated that food depletion might occur at 35                                   to forage in winter is frequently hampered by some of the most severe snow and
                caribou per square mile ("alters et al. 1978). Measurements of vascular plant                               ice conditions in North America, there has been no evidence that any
                production and caribou consumption rates in the Prudhoe Bay area indicated                                  population parameter has been influenced by winter food availability (Bergerud
                that I caribou per square mile using the range year-round would consume at                                  1971).
                most about 1.5% of the annual vascular plant production (calculated from White
                et al. 1975), a large proportion of which is high-quality caribou forage.                                   In the case of muskox populations in the High Arctic, climatic extremes are
                These estimates indicate that existing arctic ranges could support many more                                thought to result in die-offs and reproductive failures that, in the absence
                caribou than currently exist, and that range carrying capacities are unlikely                               of hunting, impose an upper limit on muskox numbers before range carrying
                                                                                                                            capacities are reached (Gunn 1984). Where a formerly steady hunting pressure
                                                                                                                            has been relieved through human resettlement, muskox populations have rapidly

                                                         G-4                                                                                                         G-5

                    :xpanded (Gunn at al. 1984). Mainland Canadian and Alaskan muskox populations                                   elsewhere.    In tundra swans,    for example, percent young-of-year measured in
                    ere sharply reduced by hunting with the introduction of firearms to the North                                   winter for swan groups breeding in northern Alaska and the Northwest
                    in the nineteenth century (Gunn 1984).          Recent Introductions to formerly                                Territories, Canada, is typically lower than for swans breeding in the
                    occupied range have, with regulated constraints on hunting pressure, resulted                                   Yukon-KuskokwLm Delta and farther south (Lensink 1973, Bellrose 1976).             Brood
                    in rapid population growth (Gunn 1984).           Thus in comparatively moderate                                sizes of Alaska North Slope swans are typically lower than those of swans
                    climatic, zones such as the 1002 area, it is conceivable that if an enforced                                    nesting in the Yukon-Kuskokwim Delta (King 1970, Wilmore 1974).

                    ban were imposed on hunting and predators were eliminated or consistently
                    reduced over the long term, descendants of introduced muskoxen might reach                                      [#91&:    RaRtors are an exception to the general principle that bird
                    range carrying capacity at some future time. However, it seems unlikely that                                    populations nesting in the Arctic are subject to dons I ty-independent limits
                    :
                     isting limiting factors would be artificially suppressed through such                                          imposed by the length of the snow-free period. . Raptors (e.g., gyrfalcon,
                    :tensive  management control   a, because there would be no useful purpose in                                   pereqrine falcon, golden eagle) tend to be limited by availability of suitable
                    raising muskox population levels to range carrying capacities.                                                  A21LJRg_JLLr&& (see review by Newton 1979).           Some cliff-nesting sites can
                                                                                                                                    shelter breeding adults and their young from snow accumulation and allow
                    B. Birds                                                                                                        successful fledging under prolonged adverse weather conditions.          Even raptors.
                                                                                                                                    however, can be subject to prevention of successful clutch production or
                    Migratory birds nesting in the 1002 area are. generally at or.near the northern                                 fledging by severe summer climatic constraints.)
                    limit of their range.     The population-limiting factor operating on most of
                    these ground-nesting species is the density-independent influence of the short                                  C. rilh
                                mr. North Slope habitat in
                    -@.c ou                                     considered  marginal tor birds because
                    the short and highly variable snow-free period          can sharply reduce nesting                              In the case of the five anadromous, fish species associated with the 1002 area
                    success, especially for waterfowl (McKnight and Hilliker 1970, King 1970).                                      (including    arctic    char,   a   1002   evaluation species),       av ailability of
                                                                                                                                    overwintering habitat (deep, unfroxen pools in river channels) -- i.e., not
                    Although food supplies are abundant in the Arctic and competition for food is                                   coastal marine habitat -- probably         limits productivity and abundance (see
                    generally low (Ogilvie 1978), late snow-malt, a late snowstorm, or an early                                     review by Craig (1987)).      As long as overwintering pools are identified and
                    first snowstorm can impair reproductive success regardless of how much habitat                                  left unchanged, free passage is maintained, and antrainment of eggs or young
                    is available or how man bi                             Thus weather exerts a large                              is avoided, no changes In fish populations are expected to result from onshore
                    dens I ty- independent Influence on reproductive success that is ameliorated in                                 petroleum development structures or activities within the 1002 area. The
                    more southerly regions where the snow-free period is consistently longer.                                       measures necessary to accomplish these objectives         are already standard civil
                    This may explain why the majority of (or perhaps all) bird species nesting on                                   engineering practice in Alaska.
                    the Arctic Coastal Plain are found to nest in greater numbers and higher
                    densities in more temperate places such as the Yukon-Kuskokwim Delta, the
                    Totlin-Yorthway area, and the Canadian prairie pothole region (King 1970,
                    Bellrose 1976, Johnson at al. 1985; see Table 1).            The marginal climatic
                    character of the Arctic Coastal Plain may also account for the typically lower
                    productivity of North Slope nesters compared to the same species nesting

                                                             0-6                                                                                                               G-7

    Table 1.	Very general estimates1 of numbers of commonly-breeding

    		waterfowl on the Arctic Coastal Plain of Alaska and elsewhere.

    		Estimates based on general information presented in Bellrose

    		(1976), King (1970), and Johnson et al. (1985).  (Note:  Most

    		geese of all species summering on the Arctic Coastal Plain are

    		non-breeders.)

    					ESTIMATED NUMBERS OF BREEDING BIRDS

    				Alaska,	Alaska,	Alaska,	North		ACP		ACP

    				Arctic	Yukon-	Entire	America	Nos.		Nos.

    				Coastal	Kuskok_.	State		(Winter	As \		As \

    				Plain		Delta				Populations)Alaska	North

    				(ACP)										America2

    Canada Goose		1,000		80,000	125,000	>2 mill.	0.8		0.05

    L. White-Fr. Goose	5,800		80,000	100,000	200,000	5.8		2.90

    Snow Goose			100-200	0		100-200	1.3 mill.	100.0		0.02

    Brant				5,000		75,000	100,000	>300,000	5.0		1.70

    Tundra Swan			1,000		40,000	--7--		90,000	2.5		1.10

    Oldsquaw			50,000-290,000		590,000	3-4 mill.	16.9		2.50

    1  These estimates are made soley for the purpose of illustrating the present

    discussion and should not be otherwise used or cited.

    2  Percertanges of estimated winter populations.

    							G-8

    3.  BIOLOGICAL ASSESSMENT PROCEDURE

    The described procedure (p. 95, col. 2, par. 3 and 4) by which environmental

    consequences were determined appears to be flawed for several reasons, as

    explained below.  If the procedures described in the draft report were not, in

    fact, those used to arrive at conclusions concerning potential biological

    consequences of petroleum exploration and development within the 1002 area,

    the text should be revised to provide clarification.

    A.  Apparent use of small-scale maps

    Wildlife use areas shown on Plates 1-3 are vague and general, and are mapped

    at an extremely small scale.  Although they may be helpful in providing the

    public with a general idea of wildlife use areas within the 1002 area, these

    maps are not appropriate to serve as the basis for a professional analysis of

    biological issues or to support professioanl review of the draft report.  If

    -- as indicated on p. 95, col. 2, par. 3 -- the maps shown in Plates 1-3 were

    indeed used to develop an assessment of potential development effects on

    wildlife, the results can have no real usefulness.  If larger-scale,

    location-specific maps were used, the text should be revised to say so.

    B.  Ina ppropriately precise was of hypothetical development scenarios

    The draft report states, "Maps of fish and wildlife use areas (pls. 1-3) were

    overlaid with full and limited development scenarios (fig. V-1).  This allowed

    measurement of direct habitat loss or alteration.  Determinations were then

    made as to the nature and magnitude of direct and indirect habitat losses,

    disturbance, mortality, and other potential effects" (p. 95, col. 2, par. 3).

    In reality, overlaying fish and wildlife use maps (even if superior to Plates

    1-3) with the full and limited development scenarios shown in Figure V-1 (p.

    90) was pointless because, as the draft repor tproperly acknowledges,

    "Alternatives A and B depict hypothetical infrastructures", and "any

    prediction as to the various stages of development at any given time on the

    1002 area would be highly speculative and perhaps misleading"  (p.95, col. 2,

    par. 4).  Yet the text states that this procedures was in fact used to measure

    						G-9

                   "direct habitat loss or alteration" and appar     ently to quantify the "magnitude                            approach is clearly inappropriate.        This Is especially true when factors
                   of direct and indirect habitat losses, disturbance. mortality, and other                                      unrelated to habitat (e.g., mortality on winter range in other geographic
                   potential effects" (p.95, col. 2, par. 3).       It is difficult to see how such                              areas). are     ignored   or    de-emphasized    as   a   result   of   applying      an
                   measurements, especially determinations 'of disturbance and mortality, could                                  across-the-board habitat-based approach as a matter of policy.
                   have been made using the described approach,              or how any substantive
                   conclusions could have been reached.       The described assessment approach can                              D. Apparent misunderstanding of gogulation-limiting factors
                   only shake the critical reader's confidence and cast doubt on all biological
                   conclusions presented In Chapter VI.                                                                          The only biologically meaningful approach to assessing and mitigating effects
                                                                                                                                 of development on wildlife Is -- first -- to determine systematically how
                   C. Indiscriminate use of habitat as the basis for biological assessments                                      project activities and structures will affect population-limiting factors for
                                                                                                                                 each species of concern, and -- second -- to apply mitigative measures that
                   Most important, the text implicitly assumes, for reasons unstated, that                                       avoid. or offset project effects on those              limiting    factors.    If     an
                                                                                                                                 automatically applied habitat-based approach happens to be effective for a
                   predicting "direct and indirect habitat losses" is a biologically appropriate
                   means of assessing probable development effects on wildlife inhabiting the                                    species; this is because one or more population- I imi ting factors happens to
                   1002 area (pp. 95-98).      This relates to the concept, discussed in General                                 involve habitat.
                   Comment 3.8,     that overlaying maps of general wildlife use areas with
                   hypothetical oilfield layout plans, and then inferring changes to habitat, is                                 It is in keeping with the national trend of FWS, codified in the FWS
                   a valid basis   for predicting a wide range of effects on wildlife. In reality,                               Mitigation Policy (FWS 1981; p. 12, col. 2. par. 2 and 3; pp. 97-98), to think
                                                                                                                                 largely In terms of preserving "habitat value" -- an approach that usually
                                   0 is onIv one of manv factors            that
                   habitat chana                                                   can affect animal
                                                                                                                                 translates into protecting land from change, or ensuring that all change is
          ca       populations.    Availability of arctic     habitat has not been shown or even
                   suggested to    limit populations of mos   t wildlife species that live in the                                "natural".    This represents, a, departure from the more conventional but
                   Arctic.during   part or all of the year [and is likely to do so primarily in the                              tried-and-true approach of managing fish and wildlife populations through
                   case of anadromous fish, raptors, and    possibly other bird species that combine                             limiting factors (which may include habitat components requiring protection).
                   (1) highly exclusive nesting territories with (2) nesting range confined
                                                                                                                                 The latter approach -- managing (or mitigating) through limiting factors -- is
                   ezclusively or predominately to the Arctic]. On the Arctic Coastal Plain of
                   Alaska, a habitat-based approach to assessing potential effects of development                                superior because it is real I ty-or iented.    One first identifies, to the extent
                      wildlife may miss the mark entirely. Where habitat availability Is likely                                  that available knowledge allows, the key factor or factors that really do
                      be a contributory factor in limiting the productivity of a species            e.g.,                        regulate -a population by limiting its productivity and growth.           Having done
                   arctic  and red-throated loons (Davis 1972, Johnson at al. 1975, Bergman and                                  so, one can then establish concrete objectives and procedures based on
                   Derksen 1977, Derksen at al. 1981) or dunlin (Holmes and Pitelka 1968, Holmes                                 managing those limiting factors to achieve or sustain the desired populatio           .n
                   1970) -- loss or alteration of habitat is one of several factors that can be                                  growth rate and size.
                   appropriate for predicting development- related effects on the species in
                   question.    However, for species where there is no evi         .dence that habitat                           in geographic regions where habitat-based mitigation or management approaches
                   availability is or is likely to be a population-limiting factor -- e.g.,                                      have been shown successfully to stabilize wildlife populations or reverse
                   caribou (Bergerud 1986, Bergerud at al. 1984)         a predominately habitat-based                           their declines, the reason has been that the availability of one or several

                                                            G-10                                                                                                          G-11

                 habitat components (food, three-dimensional space, cover,     etc.) is limiting to                          Likewise, one can take a map, draw a circle of any radius around a struc         ture
                                                                                                                             or center of human activity, and declare all land inside the circle to have
                 the species in question. This Is often true for specialized species occupying
                 a relatively narrow niche of habitat parame      ters (e.g., greater and lesser                             "reduced habitat value".      A huge land area may remain untouched, yet be
                                                                                                                             factored into an additive scheme used to formulate a mitigation requirement.
                 prairie chickens, Kirtland's warbler) and tends to be more common in the.
                 tropics (e.g., quetzals and other trogons, toucans, hornbills, etc.) than in
                                                                                                                             Through the "habitat value" concept, human activities or structures of any
                 temperate or especially polar regions, where (in the latter case) few examples
                 of wildlife (e.g., raptors, anadramous    fish) are known to be limited strictly.                           kind can be translated into a specific tract of land with exact boundaries         to
                 by habitat availability.                                                                                    be protectively regulated.       This maintains a formal, although tenuous,
                                                                                                                             consistency with the habitat-based principle of the FWS Mitigation Policy,
                 4. UNREALISTICALLY MC7REME PREDICTIONS                                                                      allowing mitigation to be defined in terms of acres or hectares of specific
                                                                                                                             land areas to be avoided by development or compensated for through agreements.
                 The draft report.presents unrealistically negative assessments of biological                                involving other, separate tracts elsewhere -- and providing legally precise
                 consequences as the nor=.      Extreme predictions result from two procedures                               boundaries and acreages for permit stipulations and record-keeping.
                 employed to develop assessments: first, the use of "indirect" reductions in
                 habitat value as the primary basis for predicting adverse biological effects                                In the draft report,   reductions in habitat value are predicted to occur in any
                                                                                                                             of three ways:    (a)  direct habitat modification; and also indirect habitat
                 of development;    and second. an assumed development scenario based on
                 concurrent construction of oilfield facilities.       Because of their important                            modification through (b) displacement of wildlife or (c) blockage of their
                 bearing on the draft report's conclusions, we have chosen to discuss these                                  access to habitat.
               .approaches at length.
                                                                                                                             Direct habitat modification:     The draft report limits predictions -of direct
                 A.                  ions in habitat value                                                                   habitat modification primarily to caribou. On. p. 106, cal.. 1, par. 5,         - the
                                                                                                                             report states that "direct modification of caribou habitat could total
                 Outright loss of habitat (e.g., by covering tundra with gravel) is cle     .arly too                        approximately 5,650 acres."     On p. 107, cal. 1, par. 2, the report further
                 narrow an approach to allow a realistic assessment of potential development                                 states that "secondary modification of habitat... could occur on approximately
                                                                                                                             7,000 acres, of which nearly 1,800 acres is In Resource Category 1....          Total
                 effects an wildlife, as many effects of development are not mediated through
                 habitat at all.    in recognition of this fact, the FWS Mitigation Policy (EVE                              modification of caribou habi   .tat attributable to direct and secondary changes
                                                                                                                             would occur an about 12,650 acres, or 0.8 percent of the 1002 area, and 1.3
                 1982) formally introduced the term "habitat value".     Inclusion of this term in
                                                                                                                             percent of the care calving area (Resource Category I habitat)."                These
                 a policy context is highly significant because the term. has no specific                                    acreage estimates impart a Eons of      precision to the report; yet there    .is no
                 definition.   It can therefore be used to embrace factors that are not really
                                                                                                                             explanation of how they were derived, no citation of another report containing
                 habitat-related   -_   for   example,   noise,   aircraft overflights,     traffic,                         the information, not even reference to another chapter of the 1002 report
                 construction activities -- in a way that appears to link them with habitat
                 through the idea of "value". This means that If a road or pipeline is to be                                 (e.g.. Chapter IV) which might be expected to provide acreages to be affected
                 built across a stretch of tundra, a vast expanse of untouched land on either                                by ollfield development. Where did these acreages come from? Do they somehow
                 side can be determined to lose "habitat value" because of the Rotential of the                              relate to the hypothetical development scenarios shown in Plates 1, 2o and 3?
                 linear structure to impede access by an unpredictable number of &niM813.                                    Using numbers in this way, without explaining or citing their origin, is

                                                         G-12                                                                                                        G-13

                  confusing and can be misleading;       The final report should be revised to                              2-mile sphere of influence on caribou was inferred does not find that calving
                  provide clarification on this point.                                                                      caribou avoided any structure or activity by a distance of 2 miles.                it
                                                                                                                            reports a vague but statistically describable trend of increasing density of
                  In any case, the estimated portion of the "core" calving area predicted to be                             cows and calves with distance from the Milne Point road.        There is no 2-mile
                                                                                                                            effect specifically mentioned in the paper or evident in the data presented,
                  modified by oilfield development -- 1.3 percent -- would be too small to
                  constitute, in itself, a threat to annual calving success. The draft report                               and no apparent justifiction for inferring a "sphere of Influence" within
                  argues that a more important adverse effect on caribou would result from                                  which habitat would receive no use, i.e., lose all value.              (See General
                  displacement of animals from or blockage of their access to calving and                                   Comment 6.G for discussion In greater detail.)        Evidence (e.g., Shank 1979,
                  insect-relief habitats purportedly required to maintain the herd, i.e.,                                   Jakimchuk 1980, Curatolo at al. 1982) shows that      the extent to which caribou
                  indirect losses of habitat value, as discussed below..                                                    avoid a road will depend more on the frequency of     traffic on that road than on
                                                                                                                            the mere presence or absence of the road itself.

                  Displacementl The draft report frequently uses this     term to infer a reduction
                  in "habitat value" for wildlife. through their          behavioral avoidance of                           The text accompanying Table VI-5 (p. 107) is misleading, in that it stretches
                  development activities.    The quantification of predicted adverse effects on                             "Area (acres) potentially influenced by development" (Table VI-5) into
                  most species (e.g.. caribou, muskoz, snow goose) is based on the idea@ that                               "complete loss of habitat values" (p. 108, col. 2, par. 5).       In applying this
                  such displacement will be absolute, and that all land involved will undergo a                             extreme approach to the 242,000-acre "core calving area" defined on p. 28,
                  complete and irretreivable loss in habitat value, i.e., will be avoided                                   col. 1, par. 3 and in Plate 2A, the authors conclude that "An approximately
                  entirely and receive no use.       In other words, the report's evaluation of                             2-mile displacement of' caribou out from petroleum facilities would include
                  environmental consequences is based an an unrealistically - extreme and                                   loss of 32 percent of the most critical PCH core calving areas (Table VI-5)"
                                                                                                                            (p. 108, col. 2, par. 5). However, the authors      fail to point out that such an
                  biologically improbable concept.      Yet this approach Is never stated as a
                  working assumption by the authors.      The reader must discover it by a close                            absolute displacement of caribou (or other wildlife) by North Slope oilfield
                  analysis of the text and tables.                                                                          development has not been documented and was not reported in the Dau and
                                                                                                                            Cameron (1985) study from which the 2-mile displacement was Inferred.            They
                  Species-by-species    discussions    in   the    draft    report   indicate    that                       are presenting an extreme and highly improbable prediction as the norm for
                  "displacement" is the primary means through which the authors predict adverse                             analysis. but do not say so.
                  effects on wildlife populations from ollfield development within the 1002
                  area. Because predicting the actual degree of such displacement (assuming it                              A similar picture is painted for muskoxen. Table VI-6, p. 113, again assumes
                  were to occur) would not be feasible, the authors use a "sphere of influence"                             (on a different basis) "a 2-mile sphere of influence", indicating that with
                  concept to develop what at first appear to be precise acres and boundaries                                full (or limited? leasing, the "Percent of Arctic Refuge range Influenced by
                  amenable to treatment under the FWS Mitigation Policy.            in the case of                          development" would be 53 (or 52) percent of the 211,000-acre range said to
                  caribou, for example, Table VI-5, p. 107. presents acres and percentages in a                             receive high use "seasonally or year-round, with calving".        As with caribou,
                  format that superficially appears to consist of "hard numbers".        In fact, as                        the authors stretch their conclusion to the limit, stating
                  stated in the table, the acreages represent areas "potentially influenced by
                  development".   The problem with this type of analysis is that it bases an                                    "Table VI-6 shows that habitat values could be lost or greatly reduced
                                                                                                                                throughout about one-third (256,000 acres) of the muskox range within the
                  absolute. black-and-white picture on very tenuous grounds. This can be highly                                 1002 area.    Habitats used for high seasonal or year-round use, including
                  misleading.   For example, the study by Van and Cameron (1985) from which the                                 calving, would be disproportionately affected; muskozen would be displaced

                                                                                                                                                                    C-15
                                                         G-14

                       from approximately 53 percent of those habitats. Habitat values could be                                    lasting effects on muskoxen from winter seismic trains,                  a conclusion
                       lost an nearly 75 percent of the high use habitats in which calving                                         reinforced by the work of McLaren and Green (1985) documenting reactions of
                       occurs. Such a high percentage of loss in valuable calving habitat could
                       have a major negative influence on herd productivity" (p. 113, cal. 2.                                      wild muskosen to snowmobile activity.          To translate local and transient
                       par. 1).                                                                                                    avoidance reactions by wildlife into a generalized loss of habitat value
                   As with caribou, there is an implicit assumption, for the purpose of the                                        "throughout   about one-third (256,000 acres) of the muskox range within the
                   analysis, that AU muskoxen would be "displaced" , i.e., lose "habitat value",                                   1002 area",   and to postulate "a major negative Influence on herd productivity"
                   from a large percentage of their range on the coastal plain. The analysis is                                    (i.e., reduct .ions in: reproductive rates or in rates of calf recruitment into
                   based entirely on acreage potentially affected, not on numbers of animals                                       the adult population) seems unwarranted and misleading.
                   potentially involved.
                                                                                                                                   Again* for snow geese, the dr    Iaft report presents a similar table of specific
                   The muskox conclusions presented in the draft report cannot be justified              an                        acreages (Table VI-7, p. 122), this time based on alternative 1.5- and 3-mile
                   the basis of the evidence cited.        The authors state,       .From the reports    of                        "spheres of influence", and states in the accompanying text: "Habitat values
                   Russell (1977) and Reynolds and LaPlant (1985), a 2-mile sphere          .of influence                          could be lost on up to     45 percent of the preferred staging area on tile 1002
                   was assumed in calculating the range which could be affected by full leasing"                                   area and 27 percent of     the total preferred staging area in the Arctic Ref        .uge
                   (p . 113, cal. 1, par. 2 through cal. 2, par. 1. line 3). Using this approach,                                  with an assumed 3-mile     displacement. A 1.5-mile displacement would result in
                   the authors indicate that habitat value could be. "lost or greatly reduced                                      lost habitat value   Ia an nearly 31 percent of the preferred staging area within
                                                                                                                                   the 1002 area and up to 18 *percent of the total preferred staging area within
                   throughout about one-third (256,000 acres) of the muskoz range within the 1002
                   area" (p. 113, cal. 2, par 1). However, the reports cited by the authors do                                     the Arctic Refuge" (p.    121, cal. 2, per. 2).
                   not support their conclusion. Those reports document observations of muskox
                   groups near winter seismic surveys.          Reynolds and LaPlant (1965) stateo                                 In all these cases, the problem is the same:           displacement within a defined
                                                                                                                                   "sphere of Influence" will not necessarily result in 011 animals avoiding the
                   "Muskoxen apparently were not displaced from areas of traditional use in
                                                                                                                                   entire area.     To base the evaluation of environmental consequences. of 1002
                   1984.   All muskozen observed were within or near use areas documented In
                   1982-1984.*'    These    authors   continue,     "Information    from    movements    of                        area petroleum development on this extreme and biologically inappropriate
                   radio-collared animals also showed that muskoxen did not move long distances                                    foundation introduces a strong bias that skews the analysis and conclusions.
                   in response to sei-smic surveys" and conclude that "Any movements caused by the
                   presence of seismic activities probably did not exceed the range of daily                                       Blocltaae of access to wildlife: PrImarily In the case of caribou, potential
                   movements which occur in undisturbed conditions."                                                               structural barriers (roads and pipelines) are presented as a mechanism by
                                                                                                                                   which habitat value will be reduced, or eliminated.           The argument is that if
                   Reynolds and LaPlant (1985),. Urquhart (1973). Beak Consultants Ltd. (1976),                                    some unpredictable number of caribou were to avoid crossing a linear corridor,
                   and Jingfors and Lassen (1984) all report that muskoxen sometimes show local,                                   the entire acreage on the other side of the corridor would be reduced in
                   transient movements away from seismic trains. As Reynolds and LaPlant (1985)                                    habitat value.       As with displacement, the reduction in habitat value is
                   conclude, "Movements away from lines were apparently of relatively short                                        calculated on the basis of the land area on the other side of the corridor,
                   duration and herd or population size did not appear to be affected." None of                                    not on documented observations of actual caribou crossing success.                   The
                   these authors reports a 2-mile "sphere of influence" from within which                                          simplistic conclusion is that some very large number of acres would be reduced
                   muskozen remove themselves.      In fact, the cited reports document an absence of                              in habitat value due to.the presence of a linear structure. The draft report

                                                             G-16                                                                                                             G-17

                  concludes:   "Eighteen percent (294,000 acres) of the 1002 area, including                                is based on a variety of information contained in Chapter IV (pp.75-87). This
                  KIC/JLSRC lands, used for insect-relief and other purposes by the PCH lie north                           chapter gives readers much information on wh    .at might be required to develop
                  of the proposed pipeline/road corridor....    If caribou refuse to cross through                          potential oil and gas fields in ANWR, but it does not address the issue of how
                  any development areas, the 294,000 acres would be unavailable as habitat.                                 activities might proceed.      In Chapter VI, the authors chose to perform
                  That area encompasses 52 percent of total insect-relief habitats. This would                              biological analyses "as if concurrent developmen@ were to take place" (p. 95,
                  mean that all coastal insect-relief habitats within the 1002 area, except for                             col. 2, par. 4 and p. 97, col.1, par.1). The authors state that this approach
                                                                                                                            was taken because "any prediction as to the various stages of development at
                  a small area In the eastern portion, would become unavailable under full
                  development" (p. 109. col. 2. par. 4).                                                                    any given time in the 1002 area would be highly speculative and perhaps
                                                                                                                            misleading" (p. 95, col. 2, par. 4, 1. 14-15).          We can hardly agree with
                  As with the case for "displacement", the blockage argument assumes that all                               this. In fact, contrary to the authors' position, we suggest that it is more
                  caribou would fail    -to cross the corridor.     All acreages and percentages                            misleading and considerably less accurate to base analyses on obviously
                  presented in the text (pp. 105-109) are based on this premise, along with all                             unrealistic "all or nothing" concepts than on informed judgments that attempt
                  conclusions concerning loss of habitat value. A biologically more ap2ropriate                             to take into account more realistic scales and sequences of events. . [Many
                  assessment Rrocedure would be to bass 2redictions on observed rates of                                    readers are almost certain to conclude that all development        stages will in
                  crossing success reRorted in the scientific literature. There is an abundance                             fact proceed concurrently.]
                  of published evidence documenting that a small proportion of caribou in a
                  group might be deterred by a pipeline or road (especially if traffic is                                   As common sense and knowledge of previous development (e.g., the Prudhoe Bay
                  present), while the remaining,       larger number of      animals would cross                            and Kuparuk ollfields) would indicate, the authors should recognize that
                  successfully (e.g., Bonfield 1954; Davis at al. 1977; Roseneau 1979; Cameron                              development in ANWR will follow a logical progression of events wherein
                  and Whitten 1980; Fancy 1982, 1983; Fancy at al. 1981; Curatolo at al. 1982;                              certain types and levels of activities will occur in certain places over
                  Robus 1983; Bergerud at al. 1984; Russell and Martell 1985).       In the case of                         varying (sometimes relatively short) time-spans.        In reality. caribou and
                  the 1002 area, where careful attention will be given to the design and                                    other wildlife will, in many cases, be encountering, these activities "one at a
                  operation of roads and pipelines to facilitate caribou crossings, the draft                               time"  (or at least not all at once).            For example, camps and other
                  report's conclusions seem particularly far-fetched.                                                       infrastructure components may be built at one location to support the first
                                                                                                                            "find", and then several years later at another distant location to support
                  B. Assumed concurrent construction of oilfiel   d facilities                                              another find (i.e., similar to Prudhoe Bay and Xuparuk).       Similarly, a system
                                                                                                                            of production roads and wells may be built in one locale, during which time
                  The development scenario presented in the draft report as the basis             for                       there will be high levels of activity, and then, after the wells are in place
                  biological assessments contains a major failingt it assumes that all aspects                              and on line, the kinds and levels of activities will change markedly (many
                  of oilfield development will proceed concurrently.      The development scenario                          fewer people, vehicles, etc.).    Caribou and other wildlife will probably have
                                                                                                                            to contend with activities at only a few locations in any one year, and the
                                                                                                                            locations will undoubtedly shift numerous times over the years.         Development
                                                                                                                            occurring sequentially along these lines is a very different matter In terms
                                                                                                                            of assessing potential effects on caribou compared to development occurring In
                                                                                                                            many areas all at once.

                                                                                                                                                                    G-19
                                                         0-18

                  Development scenarios are valuable tools for helping assess potential effects                             crossing success is ignored (e.g., Banfield 1954, Davis et al. 1977, Roseneau
                  of proposed actions, but to be useful models, they must not only incorporate                              1979, Cameron and Whitten 1980, Fancy at al. 1981, Robus 1983,     Bergerud at al.
                  the best  information available (both engineering and biological), but also                               1984, Russell and Martell 1085). Moreover, there is a failure to note that in
                  take into account how events might be expected to unfold.            Despite many                         no instance has a behavioral modification by caribou in            response to a
                  unknowns, development scenarios should still be as realistic and logical as                               structure been documented to produce any effect on herd            size. physical
                  possible     Unrealistically assuming concurrent, large-scale developments in                             condition of animals, orproductivity of a population.
                  ANWR while at the same time failing to take into account how some activities
                  might proceed, (e.g., general timing and duration of events, differences                                  He suggest that a more balanced treatment of the caribou a      ccess issue might
                  between actual construction vs. operation) seriously calls into question many                             stateg
                  of the conclusions and predictions presented in the draft report.
                                                                                                                                In studies involving the effects of the Kuparuk pipeline and associated
                                                                                                                                roads and traffic on caribou movements and behavior, Curatol         10 st al.
                  5. DOCUMENTATION                                                                                              (1982) and Robus (1983) found that caribou showed little or no rection'to
                                                                                                                                traffic-free gravel roads, crossing them consistently and frequently.
                                                                                                                                However, when traffic was present, caribou exhibited negative responses
                  Much of the documentation throughout biological sections of the draft report                                  which were in direct relation to the proximity of the vehicles (Curatolo
                  refers to non-primary references, and some references are outdated or cited                                   at al. 1982). Cameron and Whitten (1980) found that light traffic. minor
                                                                                                                                construction activities, road repairs, etc. in the Kuperuk Development
                  out of context.    In general, considering the extensive research conducted in                                Area had no detectable effect on caribou crossings of roads and use of
                  the 1002 area over the past 5-7 years, the amount of data collected, and the                                  adjacent areas.    In general, caribou cross roads and railroads freely if
                                                                                                                                traffic levels are low, but tend to avoid. transportation corridors with
                  time available for intensive review, we found biological documentation to be                                  heavy traffic (Klein 1971, Curatolo at al. 1982, Mahoney 2982, Northcott
                  poor or non-existent for many important points, and often incomplete in                                       1984). The tendency of caribou to cross a road with traffic or pass near
         00                                                                                                                     an active drilling site appears to be greatly Influenced by the relative
                  crucial ways.                                                                                                 level of Insect harassment; the greater the degree of insect harassment,
                                                                                                                                the lesser the tendency to be deterred by traffic or other human
                                                                                                                                activities (Cameron and Whitten 1980, Fancy at al. 1981, Robus 1983).
                  For example, p. 109 (col. 1, par. 3 and col. 2, par 1-3) Includes a brief
                  discussion of "the varying successes of caribou in crossing roads and                                     Similar problems involving misinterpretation of cited information are evident
                  pipelines associated with Prudhoe Bay [and other oilfield) facilities". This                              in the draft report's discussions of behavioral avoidance by caribou.            The
                  discussion generally concludes that roads and pipelines tend to deter                                     draft report statest
                  crossings by caribou, except in cases of oestri6 fly harassment not relevant
                  to the 1002 area analysis (see discussion below). Several papers are cited in                                 "Behavioral    avoidance of    development areas     displaces   caribou from
                                                                                                                                preferred habitats of traditional use....       Avoidance of oil development
                  support of this negative conclusion.        However. most of the cited papers                                 and other human activity by caribou has been reported by numerous
                  document local behavioral variations observed In caribou when moving near                                     investigators (Dan and Cameron, 1985; Cameron and others, 1979; Whitten
                                                                                                                                and Cameron, 1983; Fancy and others, 1981; Urquhart 1973; Wright and Fancy
                  structures,  and none documents a definite blockage of free passage by a road                                 1980) .... Displacement of the CAR from historic calving grounds in response
                  or pipeline  that resulted in an adverse effect on caribou.    Some of the papers                             to oil development at Prudhoe Bay has been documented (Dau and Cameron,
                                                                                                                                1985; Cameron and Whitten, 1979)" (p. 107, col. 2, par. 2).
                  cited could  be used equally to support the conclusion that roads and pipelines
                  have only a  minor influence on caribou movements (e.g., Curatolo et al. 1982;                            In  fact, none of the referenced papers presents evidence for large-scale
                  Fancy 1982,  1983), and a considerable body of work by other authors reporting                            displacement of caribou from habitat or for displacement of caribou from
                  little or no effect of roads, pipelines, or other structures an caribou                                   "historic" calving grounds.     The cited authors report localized, transient

                                                         G-20                                                                                                       G-21

                  behavioral avoidance of human activities and structures by caribou. What this                             that should help form a basis for the muskox discussion on pp. 112-113. These
                  really means is that caribou tend in some cases (e.g., parturient cows) to                                workers found that muskox responses to snowmobile harassment trials were
                  maintain a variable distance between themselves and centers of oilfield                                   complex and may have been dependent on variables such as herd size, age
                  activity (e.g., Dau and Cameron 1985), and that caribou tend to steer clear of                            structure, sex of animal, wind direction, vindspeed, and topography.          Noise
                  structures when moving through a developed area (e.g., Fancy at al. 1981).                                levels appeared to be an especially influentia     11 variable. and inconsistent
                  All such findings are expected, unsurprising, and generally accepted, and none                            degrees of habituation were observed.       In addition. this report documents
                                                                                                                            measured distances at which first reactions and closest approaches occurred.
                  suggests that large areas of habitat have been abandoned by or made
                  inaccessible to caribou as a result of oilfield development.         Moreover, we
                  have found no evidence that the Prudhoe Bay oilfield area was in the past a                               It has been noted above (General Comment 4.A) that certain papers (Dan and
                  calving concentration area for the Central Arctic caribou           herd.   It is                         Cameron 1985 for caribou, Reynolds and LaPlant 1985 and Russell 1977 for
                  therefore misleading to infer that low-density calving currently observed in                              muskoxen) are cited In the draft report as the basis for postulating "spheres
                                                                                                                            of influence" within which wildlife displacement occurs. Indeed. this concept
                  the Prudhoe Bay area represents a change from post conditions. and that the
                  change is a consequence of oilfield    ,development, especially in light of the                           in the primary assumption    on which biological assessments and quantitativ
                  fact that caribou of the Central Arctic herd presently calve in and around the                            conclusions concerning potential impacts of oilfield development on those
                  Kuparuk oilfield (Cameron and Whitten 1979, 1980; Robus 1983) without any                                 species are based. Yet none -if the cited authors presents     evidence supporting
                  detectable adverse effect on that steadily growing caribou population.                                    a specific zone of caribou or muskox avoidance that could serve as the basis
                                                                                                                            for the quantitative, all-or-nothing assessments presented in the draft report
                                                                                                                            (i.e., Table VI-5, p. 107, and Table VI-6, p. 113). The results of Dan and
                  An additional, related problem concerning biological documentation within the
                                                                                                                            Cameron (1985) are discussed in great-or dets!! in Goa  oral Comment 6.G.
                  draft report is that authors are sometimes cited out of context. For example,
                  on p.. 109, col. 1, par. 2,    the authors cite Hello and Tarvainen (1984) and
                                                                                                                            6. CARIBOU
                  Davis and Valkenburg, (1979)   out of context. This paragraph discusses insect
                  harassment and its observed   effects on caribou during the post-calving period
                  on the ANNE: coastal plain.   At that time and location, caribou are exposed to                           One. can make an assertion on the basis of intuitio          or on   the basis of
                                                                                                                            evidence. Upon reviewing the evidence of actual experience, we find that no
                  harassment by biting mosquitoes. However, the cited references and the draft
                  report-a descriptions of supposed. extreme consequences to caribou survival all                           adverts effects of Alaskan petroleum exploration or oilfield development on
                  concern infestation by oestrid flies.      Oestrid fly harassment of Porcupine                            caribou herd size or productivity have been documented.             The published
                                                                                                                            scientific literature clearly shows that during the period of oilfield
                  herd caribou tends to occur later in the season and predominately southeast of
                  the 1002 area after the majority of caribou have vacated the coastal plain.                               development  in arctic Alaska since about 1976, caribou herds in the region
                  The issue of insect harassment relative to 1002 area development should be                                have steadily increased.      None has declined.       The evidence shows that
                  kept strictly in its proper context, i.e., relief from biting mosquitoes, not                             carefully planned and managed petroleum exploration and oilfield development
                  warble flies and nose bats (oestrid flies).                                                               in the Arctic are compatible with caribou.

                  In a number of instances, relevant literature has been overlooked.               For                      We have  carefully reviewed sections of the draft report pertinent to caribou
                  example, McLaren and Green (1985) published in a major journal (Arctic) a                                 and have identified a considerable numbs      r of inappropriate assertions and
                  useful  study quantifying reactions of wild muskaxen to        snowmobile activity                        conclusions.   The following sections identify and discuss some of the more
                                                                                                                            important problems found in the draft report*3 treatment of caribou.

                                                          G-22                                                                                                      G-23

                              A. The Porcupine caribou herd calving grounds
                                                                                                                                                                                                                                                                                            0 0@_@
                                                                                                                                                                                                                                                                                            > 0
                                                                                                                                                                                                                                                                                                 Z
                                                                                                                                                                                                                                                                                            r
                              go single, fixed location Is used consistently from year to year by                                                                    the                                                                                                                    :5 0
                                                                                                                                                                                                                  M                                                                         Z M
                                                                             (PCH),         and no such location Is -unique and
                              Porcupine caribou herd
                                                                                                                                                                                                                                                                                                 Z
                              irreplaceable on a national basis or in the ecoregion" (Table VI-3, p. 98)                                                                                                    W                                                                                      I
                                                                                                                                                                                                            W     *                                                                         >
                                                                                                                                                                                                 J
                              from the standpoint of habitat value or other biological criteria.                                                           Figure 1                                                                                                                              >
                                                                                                                                                                                                 "I @i all  1                                                                               M -4
                              shows the area used in at least one year by concentrations of calving                                                        caribou,                              tZ - &     -                                                                               > M
                                                                                                                                                                                                                  0                                                                         Cn a
                                      11 as the area used by cows that were mote dispersed. These                                                          might be                              0   $t@,
                              ::rmed the "principal calving area" and the "general, calving area".                                                         Together                              I . --
                                                                                                                                                                                                 ck.
                                                                                                                                                                                                                                                                   > 0
                              they form a large continuum of calving habitat extending from approximately                                                                                                                                                          r- C                        'WIWI
                                                                                                                                                                                                                                                                   < Z
                              the Canning River In Alaska
                                                                                    nearly to the Mackenzie Delta in the Yukon                                                                                        0
                                                                                                                                                                                                 .   X
                              Territory, Canada.                                                                                                                                                 En                   Z                                                >
                                                                                                                                                                                                        =r                                                             :d
                                                                                                                                                                                                        m
                                                                                                                                                                                                                                                                   >
                                                                                                                                                                                                                      M                                                                                                                              k
                                                                                                                                                                                                                                                     G)
                              Calving females comprising a varying portion of any caribou herd do tend                                                                 to                                             Z                                                0
                                                                                                                                                                                                                      -1                             M                 -n
                              concentrate briefly in one or more areas in the spring of any given year.                                                                                                           m           A
                              Lent (1966) and Valkenburg and Davis (1986) described such areas for the
                                                                                                                                                                                                 2                          -4
                              Western Arctic herd and the Steese-Fortymile herd, respectively.                                                           "Core" or                                                2
                                                                                                                                                                                                 MR               Pe
                              concentrated" calving areas may or may not be consistent from year to year                                                                                         tj
                              (valkenburg and Davis 1986); consistency of use may, for example, depend on                                                                                        1.               s
                                                                                                                                                                                                 0, M,      al
                              ... ual snowdepth patterns (Lent 1980).                                        PCH calving concentrations vary                                                                a-
                                                                                                                                                                                                 2'< (D 0                   40
                              annually in number and location, sometimes falling within the same general                                                                                         - R X, "'
                                                                                                                                                                                                 1@-,; @ @ 2
                              area, other times varying by hundreds of miles (Roseneau at al. 1975).                                                                                             ODK C6@-
                                                                                                                                                                                                 KI  1=1* '. 0 0
                              Calving occurs primarily in the uplands along the northern sides of the                                                                                                'n = men
                                                                                                                                                                                                        0         Cr
                                                                       British, and Richardson mountains, a region extending                                                                     M      W
                              Sadlerochit, Romanzof,                                                                                                                                             CO
                              approximately from the                  western boundary of ANWR at the Canning River to the                                                                              rr
                              western Mackenzie Say,                  area in the Yukon Territory, an east-weat distance of
                              over 200 miles and an area exceeding 6,500 square miles.                                                           In 1982, for
                              example, the majority                    of the PCH calved east of the United States-Canada
                                                                                                                                                                                                     (D :3        0
                              border in the Yukon Territory, completely outside ANWR (FWS 1983), and FWS
                              investigators, citing Roseneau at al. (1975), stated "this pattern of spring                                                                                              M
                              range use has been noted several times previously" (FWS 1983).                                                      in any given                                       (D     rr
                              p                                                                                                possibly 1980s see Fig.
                                                                          (but not always,                          1973.                                                                                   a,
                                ring, there are often                                                    e.g.,
                                  one to      several areas where the densities of parturient cows are higher than
                                                                                                                                                                                                     0      M
                                                                                                                                                                                                                                                                                                           N"
                                                              PCH calving range (D. Roseneau 1986, pers. comm.).                                                 These                                      i r
                                                                                                                                                                                                     0
                              elsewhere in the                                                                                                                                                       -            -..                                                                                  I
                                                                                                                                                                                                                                                                                                                                  -4
                                                                                                                                                     some In the
                              concentrations may be several hundred miles apart, some In Alaska,
                                                                                                                                                                                                        0         CO
                                                                                                                                                                                                        rr  0
                                                                                                                                                                                                     r- M   1-h

                                                                                                                                                                                                                                                                                    4.
                                                                                                G-24

                                                                                                ARCTIC OCEAN

                                       CAMM MY

                                                                                                                       BEAUFORT SEA

                                                                                                                                        AMCKEWE
                                                                                                                                           BAY

                                                                             CONCENTRATED
                                                                             CALVING AREAS

                             ..........

                            0
                         R  0   0 0
                                         S                                                                 BOUNDARY OF
                                                      R A   N   G   E                                   CAL                 Y
                                                                                                             YING ACTIVIT

                                                                                                   ell
                                                                                1. 972
                                                       CONCENTRATED CALVING APEAS

                                Figure 2. Areas    of concentrated and general calving activity of the Porcupine Caribou Herd by year,
                               1972-1985. Solid    areas were identified as being used by 'concentrations' of calving caribou; the solid
                               line marks the boundary of calving activity. Note the large amount of annual variability in the location
                             15' of concentrations of calving caribou.    In some years (1973 and 1980) no calving concentrations were
                               observed.   [Based  on data provided by D.G. Roseneau (1972-1981) and by U.S. Fish and Wildlife Service
                               (1982-1985)].

                                                                                                   ARCTIC           OCEAN

                                          CAMM MY

                                                                                                                          BEAUFORT SEA

                                                                                                                                           MACK190M
                                                                                                                                             SAY
                                                                       BOU'NDARY OF
                                                                     CALVING ACTIVITY,
                                                              NO AREAS OF CONC ENTRATED
                                                              -,-,,CALVING ACTIVITY IN 1973

                            R               S           R  A   N G     E
                               0    0

                                                                               1973
                                        @CA

                                                      @CONCENTRATED CALVING A                               AS.

                             Figure 2 continued.

                                                               ARCTIC OCEAN

                            CANDW MY

                                                                            BEAUFORT SEA
                                                     "-T

                      CONCENTRATE                                                      MACKOWE
                      CALVING AREA
                                              BOUNDARY
                                                      OF
                                            CALVING ACTIVITY

                      0 0
                 B  R
                             S       R A N G E

                                                   1974         je
                                   @CONCENTRATED CALVING AR@AS

                    Figure 2 continued.

                                                               ARCTIC OCEAN

                             CAMM MY

                                                                             BEAUFORT SEA
                                                     I-T

                                                                                       MCKOM
                                                                                         SAY

                                             L
                                               CONCENTRATED
                                               CALVING AREAS

                                                                          BOUNDARY OF
                                                                         CALVING ACTIVIT',

                    R
                             S       R A N G  E
                      0 0
                                                                                         r

                                                   1975
                                    .CONCENTRATED CALVING AR@AS

                    Figure 2 continued.             1-102

                                                                                                   ARCTIC OCEAN

                                                                                                                         BEAUFORT SEA

                                                                              40

                                                                                                                                          MUCKEMM
                                                                                                                                             VAY

                                                                     CONCENTRA
                                                                     CALVING AR      AS.

                                                                                                              BOUNDARY OF
                                                                                                            CALVING ACTIVITY
                         13 R
                                                                   G   E

                                                                               1978.
                                                     @CONCENTRATED CALVING AREAS

                             @igufe 2 continued.

                                                                                                ARCTIC           OCEAN

                                        cmm"v

                                                                                                                      BEWFORT. SEA

                                                                                                                                       RACKMM

                                               CONCENTRATED CALVING AREAS

                        R
                            0
                            0
                                0                      A N     G  E

                                                                             1977
                                                                                                                           BOUNDARY OF
                                                      CONCENTRATED CALVING A@EAS                                        CALVING ACTIVITY

                           @iqure 2 continued.
                                                                               1-103

                                          ARCTIC OCEAN

                    c*4lxv"Y
                       7

                                                  BEAUFORT SEA

                                         77-

                                                         m4cKsvw
                                                          BAY
                               CONCENTRATED
                               CALVING AREAS       BOUNDARY OF
                                                  CALVING ACTWITY@@

              R
                    S   R AN G E
               0 0

                                           - T
                                  1978
                       @.CONCENTRATED CALVING AR@AS

              Figure 2 continued.

                                        ARCTIC OCEAN

                  CAACM aAY

                                                 BEAUFORT SEA

                                                        coraw
                                                        MY
                              CONCENTR TE
                              CALVING AS  f--
                                             @@BOUNDARY OF
                                              ALVING ACTIVITY
          8 R     s   R A NG E@
             0 0

                                 1979
                       CONCENTRATED CALVING AREAS

                       N)
             Figure 2 continued. 1-104

                                                                             ARCTIC OCEAN

                                 Cmw" mv,

                                                                                              BEAUFORT SEA

                                                                                                     /Mom"

                                                                                                           MACKEPW
                                                                                                             my

                                                BOUNDARY  OF CALVIN        ITY;
                                                                    G AC14
                                                 NO AREAS  OF CONCENTRATED
                                                  'CALVING ACTIVITY IN 1980
                   8 R   0--@
                                  S        R  A  N G   E

                                                                 1980
                                              CONCENTRATED CALVING A"EAS

                         Figure 2 continued.

                                                                               ARCTIC OCEAN'

                                   CAMDEW aA Y

                                                                                                BEAUFORT    SEA.

                                                                                                               BAY

                                                            CONCE14TRATED
                                                            CALVING ARE A

                                                                                                BOUNDARY OF
                                                                                              CALVING ACTwrry

                     B R
                           0 0      s        R A N G     E

                                   @,z
                                                                  @
                                                                   TRA  EDI
                                                                       T
                                                                  IG AREA               _Irk_

                                            kPONCENTRATED CALVING AR@AS

                        Figure 2 continued.

                                                                                ARCTIC OCEAN

                                   CAMM MY

                                                                                                 BEAUFORT SEA

                                              4r                                                                 BAY

                                                           130LINDARY F.
                                                         CALVING ACTIVITY:
                                                                                       CONCE14TRATED
                                                                                        CALVING AREA
                    B  R  O@O      s         R  A  N G   E

                                                                   1982              i
                                               CONCENTRATED CALVING AREAS

                          F'igure 2 continued.

                                                                                 ARCTIC OCEAN

                                    CAMM My

                                                                                                   BEAUFORT SEA

                                                                                                                 MCKSM

                                                          CONCENTRATED
                                                             LVING AREAS

                                                                                               UN A Y F
                                                                                           C  VIN     TI ITY

                        R            s
                                              R A N G E
                           0 0

                                                                  1983
                                                                                                                 "Y

                                                                      0

                                             @CONCENTRATED CALVI G AAEAS

                          @igure 2 continued.
                                                                    1-106

                                                                                                                  ARCTIC OCEAN

                                                CAMDEN BAY

                                                                                                                                           BEAUFORT SEA

                                                                                                                                                               MCKENZIE
                                                                                                                                                                  MAY

                                                                                                CONCEN@RATED            I
                                                                                                C ALV71 AREAS

                           8 R
                                                               R A     N G E                BOUNDARY OF
                                                                                         CALVING ACTIVITY

                                                                                        198-4
                                                            @CONCENTRATED CALVINO                                        kAS

                                 Figure 2 continued.

                                                                                                                  ARCTIC OCEAN.

                                               CANDIEN AAY

                                                                                                                                           BEAUFORT SEA

                                                                                                                                                              MCKENZIE
                                                                                                                                                                  BAY
                                                                                    CONCENTRATED
                                                                                    C
                                                                                      ALVING AREAS -

                                                                                                                                   OUNDARY OF
                                                                                                                              C     VING ACTIVITY
                          B R                                 R A N         G E
                                                                                                   AT
                                                                                                  ,RE
                                                                                                                                             Y @OF
                                                                                                                                             CTVrrY

                                                              CONCENTRATED CALVI G AAEAS

                                 Figure 2 continued.
                                                                                             I-f0'7

                 Yukon Territory, and may very greatly In location and number from One year to                                 The following discussion presents a more detailed overview of PCH calving
                 the next, while remaining inside the hard's principal calving area. The idea                                  concentrations and their variability within the 1002 area.        it was prepared by
                 of a *core" calving area consisting of a specific tract of habitat with                                       D. 0. Roseneau    in response to our request for detailed information on PCH
                 definable boundaries is unfounded.     It in reasonable, however, to delineate a                              calving distribution.    Mr. Roseneau was the principal investigator for the
                 broad area within which a high proportion of total calving consistently occurs,                               Alaskan component of the first systematic studies of the Porcupine herd and
                 every year; this area in shown in a general but accurate way in Figure I of                                   its annual cycle, distribution, and range use, conducted from 1972 through
                 the caribou section of the initial AM Baseline Report (FWS 1982). There is                                    1977.
                 no dependable means to predict the locations of high-density calving
                 concentrations based on locations from past years (D. Roseneau 1986, pers.                                         "The draft report presents information on the distribution and locations
                                                                                                                                    of Porcupine herd calving concentrations that have occurred north of the
                 comm.). and no fixed tract of "core calving habitat" that might be lost as a                                       Romanzof and Sadlerachit mountains between the Konqakut and Canning rivers
                 result of oilfield development.                                                                                    In Alaska (which is appropriate). However, no comparative data are given
                                                                                                                                    for the remainder of the large international calving grounds In Alaska
                                                                                                                                    (i.e., between the Kongakut River and the International boundary) and
                 Methods:   In attempting to map a -core" calving area, it is, not sufficient                                       Canada (i.e., north of the Old Crow Flats between the International
                                                                                                                                    boundary and the Blow River drainage).               Also,    the    considerable
                 simply to overlay general vicinities of varying concentrations of caribou cows                                     year@to-year variation that has occurred in the distribution of calving
                 and calves from different years and Interpret a place where an arbitrary                                           animals within the    large International calving grounds (i.e., during
                                                                                                                                    1972-1985; Fig. 1.    2) Is not adequately addressed.          There is strong
                 number of such areas happens to overlap as a "core" calving area.                 This                             evidence (FMS 1986)    that the herd has increased from roughly 100,000
                 approach, used to define the "core" area shown in Plate 2A and discussed on                                        animals in the early   1970a to an estimated 180,000 animals in 1986 despite
                                           the misleading impression of a consistently recurring                                    these sometimes large  annual shifts in calving distribution.       [Comments on
                                                                                                                                    annual variations in calving distribution are limited to one sentence
                 pp. 28 and 108, creates
                 calving concentration that becomes increasingly dense towards a particular                                         stating that the distribution of caribou on the calving grounds varies
                                                                                                                                    considerably from year-to-year (p. 2., col. 1, par. 3), and a brief
                 tract of land at its center,. when in fact it indicates only frequency of                                          comment that calving tends to exhibit a more northern distribution in
                 occurrence of cows and calves. in unknown and probably quite variable                                              years of early snowmelt, and a more eastern and southern distribution in
                                                                                                                                    years having late springs (p. 28, col. 2, par. 2).)              Reporting only
                 concentrations.   The superimposed shapes differ greatly from year to year;                                        locations of calving concentrations found west of the Kongakut River while
                 there Is no biological reason to suggest that a place where some of these                                          largely ignoring past annual variations in calving distribution does not
                                                                                                                                    provide a balanced perspective of the calving grounds.         it de-emphasizes
                 shapes happen to overlap is somehow special, and certainly none to justify                                         the substantial extent of calving that occurs outside the 1002 area in the
                 classifying such a location as Resource Category 1, i.e., -unique and                                              remainder of Alaska and in Canada, and fails to illustrate that the herd
                                                                                                                                    has used a broad and varied region of northeastern Alaska and the northern
                 irreplaceable on a national basis or in the ecoregion" (Table VI-3, p. 98).                                        Yukon Territory north of treeline for calving while increasing In size
                 The proposed Resource Category 1           location,   intended for an official                                    (Fig. 2).
                 designation protecting habitats that are rare or      biologically very important,                                 "[Notes   It Is generally accepted that, as caribou herds increase or
                 is defined solely by the criterion of overlap in at least 5 out of 14 years.                                       decrease in  also, they tend to expand or contract over their range.          For
                                                                                                                                    this reason, one should also expect the principal calving area of the PCH
                 or 36 percent of the years of record.            This criterion has no evident                                     to expand and contract over time.]
                 biological significance and is unexplained by the authors; in fact, it appears
                                                                                                                                    "Information is also presented implying that there is a relatively small,
                 to be arbitrary.     Had a more likely criterion been used -- for example,                                         specific, fixed 'core calving area* that is both critical to the survival
                 overlap in at least 7 of the 14 years, or 50 percent -- the "core" area would                                      of the herd and specifically sought out by large elements of the herd year
                                                                                                                                    after year (e.g., see text on p. 28, Table VI-5 on p. 107, and Plate 2A).
                 be about half the size described by the authors.           The lack of a logical                                   This concept is unfounded.      Caribou are a highly migratory, versatile
                 criterion or biologically meaningful rationale for defining the area provides                                      species capable of handling a variety of sometimes harsh, rapidly changing
                 no justification for its proposed designation is Resource Category 1.

                                                          C-25                                                                                                          G-26

                      and often widely varying conditions in their environment.           The annual                               the total cows in the herd within years, and also between years, because
                      variations that have occurred in wintering areas, migratory routes                                           the herd has been growing. The overlaid data on concentrations, without
                      (spring,  fall, post-calving,     and early winter), calving areas, and                                      density information attached, really show I requency-o f -occurrence of the
                      post-calving areas of large herds are examples of the ability of caribou                                     Rresence of these concentrations.       However, the red areas of greatest
                      to utilize successfully more than just one specific, fixed area for all of                                   overlap representing the presence of caribou in nine out 14 years are
                      these events during their life cycle.                                                                        called areas 2f greatest concentratio           (Plate 2A),     which was     not
                                                                                                                                   necessarily the case.    Similarly, the pattern of ever-darkening overlays
                      "(Notei   Papers such as Valkenburg and Davis (1985) showing annual                                          in itself tends to suggest increasing densities, not simply greater
                      variations in calving distribution in the Steese-Fortymile caribou herd,                                     frequencies of occurrence. The 1002 *core' area is equivalent to an area
                      and Davis at al - (1985) reporting rapid growth of the Delta caribou herd                                    only 19.5 miles z 19.5 miles in size.              There is no doubt (nor
                      despite habitat changes in its calving grounds, have not been cited.]                                        disagreement) that this and other portions of the upper Jago River
                                                                                                                                   drainage have been used freguentl        by concentrations or portions of
                      "Given a 15-year data set (1971-1985), it is possible to.- a) define the                                     concentrations of calving animals over the years.              (The process of
                      broad limits encompassing all calving (i.e., the general calving grounds)                                    sublimation begins reducing snow cover in the uplands along the northern
                      by overlaying the data and plotting the extreme points where calving has                                     flanks of the Romanzof and British mountains. during late winter and early
                      occurred during the years of record (Fig. 1)i b) define a somewhat smaller                                   spring.   Upland areas between the Aichilik and Hulahula rivers often
                      region encompassing the majority of calving (i.e., the primary calving                                       become relatively snow-free at about the time parturient cows begin
                      grounds) by overlaying the data and plotting the limits of the areas that..                                  reaching the area.)     However, as mentioned above, year-to-year use has
                      have contained the majority of calving over the years (Fig. 1); and C)                                       been by varying proportions of the herd's calving cows.              Using only
                      recognize   that,   over   time   and   from   year-to-year,    one   or     more                            frequency information to highlight one small, fixed area in the calving
                      concentrations of calving animals may occur anywhere within the boundaries                                   grounds, and assuming that it (along with the small remaining portion of
                      of the primary calving grounds, dependent on snow conditions (including                                      the 'core' that occurs outside the 1002 area) holds the key to increases
                      those found, along spring migration routes). weather events, proximity to                                    or decreases In a large, dynamic caribou herd that gives no indication of
                      wintering locations (which also are variable from year to year), and herd                                    being limited by habitat availability, is not a very desirable approach
                      size.   It Is also possible to go one stop farther and determine the                                         and may not be in the best Interest of the herd.          it Is quite possible
                      frequency of use of one area vs. another within the primary calving                                          that the Porcupine hard could continue to prosper without part or even all
                                                                                                                                   of this area.   In contrast, carefully preserving "habitat values" In this
                      grounds by overlaying. maps of known calving concentrations, as was done                                     area while perhaps paying less,attention to the remainder of the calving
                      fnr thA     lyffis crezented in the draft report (Plate 2A). However, the
                      fact that one area has been used more frequently than another by annually                                    grounds will hardly guarantee that the hard will maintain its size or
                      varying proportions of calving cows does not mean that there is one                                          grow. Given past variations in calving concentration areas, likely future
                      particular, small, fixed, unique 'core' area within the primary calving                                      variations in calving areas, and the fact that many cows often continue to
                      area that most of the animals seek out every year; and that in so critical                                   move westward shortly after having given birth, all of the primary calving
                      to the hard's survival that loss of any or all of it will result In a                                        grounds deserve to receive equal attention."
                      population decline (as is strongly implied in the draft report).
                                                                                                                                                                     (NOTES]
                      "The authors estimate that the large International calving grounds include
                      about 8.9 million acres (13,900 square miles, a reasonable estimate).                                        I(The 2,117,000 acre international area of concentrated calving was
                      They then identify a 2,117,000 acre (3,308 square mile) international area                                   apparently determined by:     a) plotting and overlaying all of the major
                      of 'concentrated calving'l, and a small 311,000 acre j486 square mile)                                       concentrations of calving animals found during the nine years for which
                      international "core calving area" (the equivalent of a 22 mile x 22 mile                                     data are reported; b) drawing now boundaries encompassing any resulting
                      square area)2.    About 242.000 acres '(378 square miles) (78%) of the                                       overlapping concentrationsi and c) measuring and summing these new areas,
                      311,000 acre core area -are reported being in the 1002 area, and the                                         and combining them with measurements and sums of any remaining area.)
                      remainder (69,000 acres, or 108 square miles) .(22%) are apparently located                                  2[The 311,000 acre international care calving area was                 apparently
                      east of the 1002 area in Alaska and in northwestern Canada.         The portion
                      of the 'core' area occurring within the 1002 area Is illustrated by Plate                                    determined byi 1) stating that a core calving area is              a location to
                      2A.                                                                                                          which pregnant cows have shown at strong fidelity as traditionally favored
                                                                                                                                   calving habitat"; and 2) measuring and summing all areas within the 2.1
                      "Plate  2A tends to be misleading.       The plotted concentrations were of                                  million acre International area In which concentrated calving occurred In
                      varying densities (sometimes greater than 50 cows [sic) /square mile,                                        at least five of the nine data years.)
                      sometimes less), but they were clearly discernable as concentrations in
                      contrast to the more scattered distribution of animals in surrounding
                      areas. The mapped concentrations also represent differing proportions of

                                                          G-27                                                                                                          G-28

                 B. Density of caribou In calvina concentration areas                                                         For 1982, however, it Is possible to make a rough calculation of the density
                                                                                                                              of caribou in the concentrated calving area South of Herschel Island, Yukon
                 The draft report states (p. 28, col. 1,     par. 3) that "areas where caribou were                           Territory. Whitten and Cameron (1983),       on the basis of 5,900 cows that were
                 present during calving at a density of at least 50 caribou/square mile (during                               actually counted, estimated that 23,400 cows may actually have calved within
                 1972-85] were identified as concentrated calving areas" (presumably referring                                the high density area. Measuring on the inside of the thick crayon line that
                 to mainly calving cows plus a few yearlings, and not including neonates). On                                 marks the boundary of the high density       calving area on the authors' original
                 p. 106, co2- 1, par. 4, the report further states that the 242,000-acre "core"                               map, one can calculate an area of about 1,000 square miles, for a density of
                 calving area proposed as Resource Category I was defined specifically on the                                 calving cows of 23.4/square mile, not        50/square mile.    Thus it is only by
                 basis that "More than 50 caribou/ sq mile have been present during calving in                                measuring on a small-scale map and back-calculating that it is feasible to
                 at least 5 of 14 years (1972-85) for which detailed data exist (pl. 2A)". In                                 estimate the density of cows that probably occurred in the area of
                 reality. no known "detailed data" on calving densities from 1972 through 1977                                concentrated calving in, 1982. Data are not made available in the ANKR Update
                 were ever collected or have ever existed (D. Roseneau 1987. pers. comm.).                                    Reports to allow such calculations for 1983, 1984, and 1985.
                 Indeed. no known                     ta of any kind on calving densities were
                 collected during those yAara. Furthermore. we have been unable to confirm the                                In 1983, PCH calving distribution was studied by Whitten at al. (1984). Among
                 existence of any guantitative data on PCH calving densities collected from                                   their objectives was the measurement of variations in calf mortality and in
                 1978 through 1985.     If there are cuantitative data 9mg2orting the density                                 calf mortality factors between core and peripheral areas. Whitten at al. make
                 claims. they should be made available for review,                                                            no mention of their criterion for distinguishing a "core" calving area from
                                                                                                                              other calving areas. Calving caribou were located by tracking radio-collared
       _L        The principal investigator who conducted the research from 1972-1977 estimated                               animals, but no density data were reported.
                 and mapped the approximate "boundaries" of PCH calving concentration areas
                 while observing them from an aircraft; his determinations were subjective and                                For the 1984 calving season, Whitten et al. (1985) again conducted research on
                 involved no quantitative criterion or actual counts (D. Roseneau 1987, pers.                                 the PCH calving grounds.      These workers report number of caribou seen and
                 comm. ) . Roseneau believes that some areas that he identified as concentrated                               percent calves, but do not provide Information about densities of caribou in
                 calving areas contained densities much lower than 50 cows/square mile, while                                 areas of concentrated calving or elsewhere.
                 others consisted of much higher densities.       Apparently the first mention of
                 the density criterion of 50 caribou/square mile was made In the final report                                 Nowhere in the ARWR Update Reports is there documentation of research
                 of the Caribou Impact Analysis Workshop held in November 1985 (Elison at al.                                 conducted that would have permitted a density of calving caribou to have been
                 1986).    That   report    indicated,   without    documentation,    that   the    50                        calculated (e.g., systematic surveys, vertical aerial photographs).         The term
                 caribou/square mile criterion had been applied since 1981 (not 1972).                                        "concentrated calving area" appears to have always been subjective, never
                 However@ there is no direct information on density of caribou on the calving                                 quantitative and objective.
                 grounds in.any of the FWS ANWR Update Reports (FWS 1983, 1984, 1985, 1986).
                 Therefore, we are unable to confirm that the criterion of 50 caribou/square                                  We at first assumed, given the draft report's lack of specific information on
                 mile was in fact used for objective identification and mapping of calving                                    this point, that the stated density criterion of 50 caribou/square mile (p.
                 concentration areas in any year.                                                                             28) was applied in usual fashion to parturient cows or cow-calf groups. Upon
                                                                                                                              inquiry, howe .ver, we were informed that the criterion of 50 caribou/square

                                                         G-29                                                                                                           G-30

                 mile included both cows ao calves (A. Rappaport 1987, pers. comm.).        I f the                      vroposed for Resource Category 1 designation. The reality is that PCH calving.
                 density criterion includes calves, the criterion is misleading and introduces                           can and does take place throughout,the ANWR coastal plain from approximately
                 uncertainty in comparing mapped calving concentrations shown for different                              the Canning River to the Babbage River. Although parts of the 1002 area are
                 years or by different workers.     The inclusion of calves within the density                           used regularly by calving caribou, there appear to be no data that meet the
                 figure surprised several biologists.    [Ton of twelve biologists polled assumed                        criteria stated in the draft report to define a "core" calving area Ji.e.,
                                                                                                                         "More than 50 caribou/sq mi", "present during calving in at least 5 of 14
                 that the density criterion referred only to cows.)        Because of the high,
                 variable mortality rates suffered by calves, it is usual practice to omit them                          years (1972-85) for which detailed data exist"]. Therefore, no "core" calving
                 from counts (e.g., counts made during photo-censuses), except where they are                            area can be delineated without altering the criteria.
                 of particular interest (e.g., calves per 100 cows).        Other workers (e.g.,
                 Parker 19172) have reported densities on calving grounds in terms of cows only.                         C. Size and location of calving concentration areas

                 If calves are included in counts, the actual percentage of the total that they                          There are serious limitations in the data that were available to plot the
                 comprise will vary depending on pregnancy rates, percent parturient cows,                               location and areal extent of concentrated calving areas, particularly for
                 neonatal mortality rates, and pe Ircent calves missed during surveys (which will                        1972-1981 (Plate 2A). Maps of calving concentrations observed in those years
                 be greater than the percent of adults that are missed). Thus, the proportion                            (fig. 3) were prepared by D. G. Roseneau (1987, pers. comm.) to show
                 of cows In the counts will vary considerably  from year to year. The Inclusion                          variability in calving area locations and were never intended to be used for
                 of calves in density figures also makes it    impossible to compare results from                        precise mapping of calving concentrations. The original map scale (1 inch.
                                                                                                                         50 miles) is far too small to have permitted the data to be replotted
                 studies using cows only.   if one were Interested In density of caribou on the
                                                                                                                         accurately to a larger scale map.    (Unfiirtunately, much of the original data
                 calving grounds in the context of range stocking density, the numbers would be
                 useless because calves do not graze on vegetation.        Or if one wished to                           was lost in an office fire, and thus more detailed information about the
                 compute the minimum number of cows in areas of concentrated calving, the                                location of the calving concentration areas is not available.]
                 Inclusion of calves would make the figure meaningless. Also, if one wished to
                 make an inference about the number of caribou selecting a particular portion                            Several problems have been identified with the maps of PCH calving
                 of range, the inclusion of calves in the density figure would be misleading                             concentration areas shown in Plate 2A.        In addition to relatively small
                 because calves obviously do not select range areas. There are valid reasons                             plotting errors that can be expected, there are substantial errors that have
                 to base index counts solely on cows. Thus. if calves and cows were included                             caused mapped calving areas to become larger in size, to change shape, and to
                 in the density figures, the results should be revised to reflect cows only.                             "migrate" (about 16 miles in one case for 2977) J  .Fig. 3).

                 In summer ,    the draft report clearly states that the density of 50                                   He believe that the. following sequence of events probably describes what
                 caribou/square mile has been used as the criterion defining a core calving                              happened during the plotting of the data.          First, the original calving
                 area. This implies that there is a clear, objective, quantitative difference                            concentration maps for 1972-1981 received by F   WS from Roseneau (Fig. 3) were
                 separating concentrated calving areas from general calving areas.             with                      enlarged slightly and a base map was drawn, only slightly different from the
                 critical examination, however, this distinction blurs. There d    .o not appear to                      originals provided.    [Note the general similarity in style of the maps.       The
                 be any objective, quantitative data that were used to determine the boundaries                          error of showing the Babbage River flowing directly into Mackenzie Bay rather
                 of areas of concentrated calving, including the composite 242,000-acre tra t                            than into Phillips Bay, the simile  rity of the representations of the Canning

                                                        G-31                                                                                                    G-32

                           CAMUE14           I r Islonid      ROSENEAU INITIAL                                                                                             CAMDEN                 Island
                      It      DAY                                                                                                                                             nAv                              ROSENEAU INITIAL                         1973

                                                                                 14, sc"                                                                                                                                          lf@schl
                                                                              C>   lsin.d              Miles 25       0       25                                    1                                               Komnkuk         IsInnd             Miles 25       0      25
                                                                                           King Pl.   MACKENZIE                                                                                                                           King Pl.   MACKENZIE
                                                                                                                                                                                                                                                          BAY
                                                                                                          BAY
                                                                                                n9II, Pf                                                                                                                                     Sbingle Pl.

                                                                                                                                                                                                                 J*
                                          1'R'Y ANE                                                                                                                       0 0               R
                        900@A                                                                                                                                                      S              N E                                                         AklaAk     A
                                                                                                                                                                               r
                                                LEGEND                                                                                                                                            LEGEND
                                                 Boundary    enclosing major calving activity.                                                                                             -Boundary enclosing major calving activity.
                                           ---Boundary       enclosing light scattered calving.                                                                                            ---Boundary enclosing light scattered calving.
                                         0 Area of major concentration of calving activity.                                                                                               0       Area of major concentration of calving activity.
                            USFWS INITIAL                                 C
                                C                                                                                  1972                                               USFWS INITIAL                              4                                              1973
                                                                                                                                                                                                  Boller 1.
                                                                                                 0 C e 4 V                                                                                      0
                                                                                                                                                                                 offy      -                                                     0 C,         4,
         21
         _16                                                                              He,,ch.1 1.                                                                                           !v
                                                                                                                                                                                                                                         HeILE1161 1.

                                                                                                      MACKENZIC          8Ar
                                                                                                                                                                                                                                                  MA CAEA(ZIE          &A Y

                                                                                                                                                                      R
                                     r

                                                      G E
                              't,. S                                                                                                                                                              A
                          00        1k,                                                                                                                                    0 K S
                         ft                                                 Z
                                                                          =i

                                                                          LEGEND                                                                                                                                           LEGEND

                                                           ANVIR STUDY AREA
                                                           BOUNDARY ENCLOSING LIGHT                                                                                                                        ANWR STUDY AREA
                                                           SCATTERED      CALVING                                                                                                                          BOUNDARY       ENCLOSING      LIGHT
                                                           MAJOR    CALVING ACTIVITY                                                                                                                       SCATTERED       CALVING
                                                                                                                                                                                                           MAJOR     CALVING ACTIVITY
                                                           AREA OF MAJOR CONCENTRATION
                                             F7.  2 3      OF CALVING ACTIVITY                                                                                                                             AREA Or MAJOR CONCENTRATION
                    Figure 3.      Maps of distribution of calving caribou prepared by B.G. Roseneau                                                                                                       OF CALVING ACTIVITY
                    (A) and by U.S. Fish and Wildlife Service (B) for 1972-1981.                                   Data from
                    1972-1977 were collected by D.G. Roseneau, who also assembled the.data for
                    1978-1981 from other sources.               because the original field data were lost in
                    an office fire, the maps shown in panel A for each year are the only source
                    of i  nformation on the location             of calving caribou for 1972-1981.                 The USFWS,
                    apparently based maps in panel B on the originals in panel A by redrafting'
                    the map base and hand transferring the data; note that there are changes in
                    shape and size of the areas shown in panel A compared with the original in'                                                                Figure 3 continued.
                    panel A.       Maps in panel B were apparently enlarged and entered into the
                    USFWS computer data files, which in turn were the basis of the concentrated
                    calvino areas shown in Plate ?A nf thp draft ronnrt

                                                          Island                                                                                                                                CAMDEN                     Island        ROSENEAU              INITIAL
                               CAMDEN
                                   DAY                                    ROSENEAU INITI               AL           19T4                                                                           DAY                                                                                 19TS

                                                                                            H@scw
                                                                              Va"Itult        Island                Miles 25         0       25                                                                                               "ak.k            Wand                  Miles 25          0      25
                                                                                                                                                                                                                                                                                    MACKENZIE
                                                                                                                   MACKENZIE                                                                                                                                            Xing Pl.         BAY
                                                                                                      King Pt          BAY.                                                                                                                                                S!,ingfe Pt,
                                                                                                          Sivingle Pl.

                                                                          lo

                                                                          to
                                                                          31
                               00                  R      N        E                                                        .Ak                                                                    0
                    L                @s         /         , .      .      ..
                                                       LEGEND                                                                                                                                                         LEGEND
                                                       Boundary           enclosing major calving activity.                                                                                                      -Boundary            enclosing major        calving activity.
                                                 ---Boundary              enclosing light scattered calving.                                                                                                             Boundary      enclosing light       scattered calving.
                                               0       Area of major concentration of calving activity.                                                                                                                  Area of      major co    .ncentroflon of calving activity.
                          U  8FWS INITIAL                                  4                 C                                   1974                                                     USFWS INITIAL                                    4       C                                            1975
                                                          Bo,lef 1.                                                                                                                               Ca.deft             a
                                                                                                              0          4 V                                                                                                                                                  0    r
                                                                                                                                                                                                                                                                                             4,
                                                                                                                                                                                                                                                                     Hericnel    1.
                                                                                                     Hefschel 1.                                                                                      r
           _16
                                                                                                                                                                                                                                                                                                        HAr
           co                                                                                                     MACKENZIE             SAI,                                                                                                                                    MACKENZIE

                                                                          %
                                                                   Kan 0  Is                                                                                                                                     N
                                                                                                                                             10                                                              60 66                                                  06bild
                                                               r                                                                                                                                                          A   IN     E
                                                     it            E                                                                                                                                Y, S
                                                                                                                                                                                          it 0 0

                                                                                                                                                                                                                                                 LEGEND
                                                                                  LEGEND
                                                                                                                                                                                                                                ANWR        STUDY AREA
                                                                   ANWR       STUDY       AREA
                                                                   BOUNDARY ENCLOSING LIGHT                                                                                                                                     BOUNDARY ENCLOSING               LIGHT
                                                                                                                                                                                                                                SCATTERED CALVING
                                                                   SCATTERED       CALVING                                                                                                                                      MAJOR      CALVING ACTIVITY
                                                                   MAJOR     CALVING ACTIVITY
                                                                                                                                                                                                                                AREA OF MAJOR CONCENTRATION
                                                                   AREA OF MAJOR          CONCENTRATION                                                                                                                         or CALVING ACTIVITY
                                                   177 ",          OF CALVING ACTIVITY
                                                                                                                  MACKEN

                                                                                                     _J It

                    Figure 3 continued.                                                                                                                                             Figure 3 continued.

                      AMDEN        11-41, Island                                                                                      CAMDEN         1,% Island   ROSENEAU INITIAL                 1977
                       13AY                     ROSENEAU INITIAL                 1976                                                   BAY
                                                                                                                                                                       K-qkuk    Hesclel
                                                     Ka'"'"k C:> 410.d          Miles 25    0     25                                                                               Island         Miles 25    0     25
                                                                                                                                      IS,                                                         MACKENZIE
                                                                               MACKEN                                                                                                   King Ill.   BAY
                                                                       King Pl.   BAY                                                                                                            Pt
                                                                         Shi.gle Pt

                                                          V
                                                                                                                                                                   IT"
                                                                                                                                                                               Bat

                                                                                      Akia@ik
                laIR00 S            R@A                                                                                              00
                                                                                                                                   Fil.             R N      E
                                   LEGEND                                                                                                             LEGEND
                                -Boundary     enclosing major calving activity.                                                                   -Boundary enclosing major calving activity.
                                -Boundary     enclosing light scattered calving,                                                                  -Boundary enclosing light scattered calving.
                                0 At   ea of major concentration of calving activity.                                                              0 Area of major concentration of calving activity.
                  USFWS INITIAL                                  C                       1976                                       USFWS INITIAL                                                          1977
                        Camde.       '0                                     0 C e 4                                                      COM0111
                                                                                                                                            Bey                                               0 C,    4  41
                                                                      Herschol 1.                                                                                                       He'schel 1.
                                                                               MACKENZIE      BAY                                                                                                MACICENZIE     BAY

                                                                                                                                                                                            W
                                                                                        J*

                                            E                                                                                                             A N
                      OY.S           it.                                                                                                0   S
                                                                                                                                 a Vt                                     =i14
                  ft                                                                           B                                                                            P
                                                                                                                                                                            LEGEND
                                                         LEGEND
                                                                                                                                                                AIRW R  STUDY   AREA
                                            AWW R   STUDY     AREA                                                                                              BOUNDARY ENCLOSING LIGHT
                                            BOUNDARY ENCLOSING LIGHT                                                                                            SCATTERED CALVING
                                            SCATTERED    CALVING                                                                                                MAJOR   CALVING ACTIVITY
                                            MAJOR   CALVING ACTIVITY                                                                                            AREA OF MAJOR CONCENTRATION
                                            AREA OF MAJOR CONCENTRATION                                                                                         OF CALVING ACIIVITY
                                  F7422-3   OF CALVING ACTIVITY
                                                                                                                                                                                                         7ZIE

              Figure 3-continued.                                                                                              Figure 3 continued.

                                     A0,1kr Word                                                                                                   CAMDEN                           ROSENEAU INITIAL
                        CAMDEN                           ROSENEAU INITIAL.                                                                            BAY
                           SAY                                         Herschel           1978                                                                               C.            Qkuk    Herschel            191`9
                                                                Wit      IsInnd                                                                                                                      IsInnd           Miles 25     0     25
                                                                                                       0     25
                                                                                          Miles 25
                                                                                                                                                                                                                     MACKENZIE
                                                                                         MACKENZIE                                                                                                         King PC      SAY
                                                                               king PI      SAY                                                                                                               Shingle Pf.
                                                                                  Shingle PI

                                                                                                                                                                                    r
                                                                                                             X
                                                                                                                                                                @R      N    E                                              Aklwik
                        00                A,N     E                                             Allovil,   A,                                    goo       S                                                                           A
                             @s      /                                                                          I                          L                                                                                               i
                                                          LEGEND                                                                                                                      LEGEND
                                          Boundary enclosing major calving activity.                                                                            -Boundary enclosing major Calving activity.
                                                                                                                                                                --- Boundary enclosing light      seat tered calving.
                                    ---   Boundary enclosing light    scattered Calving.
                                          Area of major concentration of calving activity                                                                       (Q Area of major concentration of calving activity
                      USFWS INITIAL                       4 A?          C                           1978                                        USFWS INITIAL           sorter 1,    4               C,                       1979
                            coinde.                                                  OC                                                               cofildo;
                                &or                                                           4 4@                                                                                                               0

                                                                               Herschel 1.                                                                                                               Herschel 1.
                                                                                         MACKENZIC        SAY                                                                                                       'A CKENZIE       CIA Y

                                                  900190                                                                                                           t         mangos,)I
                                                                              OOD0044                                                                                          6 E
                            VI.S                                                                                                                     0    S

                                                                                                                                                                                          LEGEND
                                                               LEGEND
                                                                                                                                                                             ANWR      STUDY    AREA
                                                  ANWR      STUDY     AREA                                                                                                   BOUNDARY    ENCLOSING    LIGHT
                                                  BOUNDARY    ENCLOSING     LIGHT                                                                                            SCATTERED    CALVING
                                                  SCATTERED     CALVING
                                                  MAJOR    CALVING ACTIVITY                                                                                                  MAJOR    CALVING ACTIVITY
                                                                                                                                                                             AREA Of MAJOR CONCENTRATION
                                                  AREA OF MAJOR CONCENTRATION                                                                                                OF CAI VING ACTIVITY
                                                  OF C LYING ACTIVITY
                                       E               A

                 figure 3 continued.                                                                                                        Figure 3 continued.

                                   krW Island                                                                                               CAMDEN       k,k"   Island                     INTIAL
                      CAMDEN-                       ROSENEAU INITIAL                                                                   Q.      BAY                       ROSENEAU
                         GAY                                                                                                                                                                                19
                                                                                     1980                                                                           yc@                                       81
                                                                  Ifierschel                     I                                                                                       11"SChel
                                                                    IsInad          Miles 25     0    25                                                                                   island          Miles 25     0    2
                                                                                   MACKENZIE                                                                                                     King pl. MACKENZIE
                                                                          King PI,     SAY                                                                                                                   SAY
                                                                             IN-9fe Pt                                                                                                             shingle PI
                                                                  10,
                                                                                                                                                                            iep 4L
                                                                  at,                                                                                                                                                        ;a
                                                                  at,
                          @S      /R     N    E                                           A
                      00                                                                            A                                      0 0

                                                       LEGEND                                                                                                                LEGEND
                                  -Boundary enclosing major calving activity.                                                                            -Boundary enclosing major calving activity.
                                  X_k Area of major Concentration of cotving activity.                                                                   ZIA Area of major concentrallon of calving activity,
                                  V                                                                                                                      V
                    USFWS INITIAL                     4     C       C                         1980                                      USF*S INITIAL                       4
                                         Barter 1.                                                                                                             Barter 1.                                           1981
                         Camden        0
                             flay                                                       4 4,                                                  Comdo:
                                                                                                                                                 Be                                                   0

                                                                         Herschel  1.

                                                                                   MACKENZIE       sAr
       _16                                                                                                                                                                                             MACKENZIE         SAr

                                                   IL0                          fL
                                              x0a 0

                                                                                                                                                                                                 b
                                                                                                                                                                                               0ob
                                            G E                                                                                                                      C! 1E      J
                                                                                                                                                                        E
                       0 V@s                                                                                                              0 0 K S
                                                              z                                                                                                                                                          B

                                                            LEGEND
                                                                                                                                                                                LEGEND

                                              A"WR      STUDY AREA                                                                                                  ANWR      STUDY AREA
                                              8OUNDARY ENCLOSING LIGHT                                                                                              aOUNDARY ENCLOSING LIGHT
                                              SCATTERED     CALVING                                                                                                 SCATTERED    CALVING
                                              MAJOR CALVING ACTIVITY                                                                                                MAJOR CALVING ACTIVITY
                                              AREA OF MAJOR CONCENTRATION                                                                                           AREA OF MAJOR CONCENTRATION
                                              OF CALVING ACTIVITY                                                                                                   OF CALVING ACTIVITY

              Figure 3 continued.                                                                                                  Figure 3 continued.

                           River delta, and other features suggest a common origin of these maps.)
                                                                                                                                                                                                                                                      0
                           Second, the original data from the Roseneau maps were copied by hand onto the                                                                                       0 C'R
                           new bases (Pig. 3).                    A comparison of the two sets of maps will reveal several                                                                         , 0@;,
                                                                                                                                                                                               I @. @Q'- -@ ,
                           changes In depicted calving concentration areas, some of the changes large,                                                                                                    (D
                                                                                                                                                                                                   C6 (D
                           others small, in all years. Some of the larger changes apparently occurred in
                           the 1977 data.                  Third, the replotted data were apparently transferred to                                                                            rt  @h
                                                                                                                                                                                               ::r W.
                           11250,000-scale maps, digitized, and entered into the FWS computer file.
                           Finally, the information was replotted by computer to indicate the degree of                                                                                                                                                                                                         -ft.
                                                                                                                                                                                                          0
                                                                                                                                                                                                          :3
                           overlap and to define the "core calving area" shown in Plate 2A. of the draft                                                                                               w  rp
                                                                                                                                                                                                       (D
                                                                                                                                                                                                       :3 0
                           report.                                                                                                                                                                     M ,
                                                                                                                                                                                                   rr
                           With the assistance of D. 0. Roseneau, Standard replotted the locations of                                                                                                                          Z
                                                                                                                                                                                                                               0
                                                                                                                                                                                                   rJJ
                           calving concentration areas using Roseneauls original small-scale maps (Fig.                                                                                                   0
                                                                                                                                                                                                                               M
                                                                                                                                                                                               ID = R
                           2). Mr. Roseneau made additional adjustments to make the representations more                                                                                               CT 0                    Z
                           accurate. We believe that these maps are the most accurate representation of
                                                                                                                                                                                               M   C6
                           the calving concentrations for 1972-1981.                                       The revised maps have been made
                           available to FWS at a scale of lt25O,OOO.                                                                                                                           M

                           The years 19?5, 1976, and 1977 will                                  serve to Indicate the magnitude of the                                                                                                  -4
                                                                                                                                                                                                                                        U,
                           alterations that have crept into the                                draft report's analysis of locations of                                                                    :3*
                                                                                                                                                                                               in
                           PCH       calving           concentration                areas.           Figure         4      shows         three          different
                                                                                                                                                                                               En
                           representations of the same information: 1) an accurate transfer of date from                                                                                                  W
                                                                                                                                                                                                       -4
                           the original maps (Pig. 3); 2) the version presented in the AM Initial
                           Baseline Report (FWS 1982) (Fig. 3); and 3) the
                                                                                                                       version from FWS computer                                                          -4
                           files which formed the basis of Plate 2A in the                                             draft report. It is clear                                                                                                                                 - -- - - - - -- - --
                                                                                                                                                                                               CL      ZJ U.
                           that there are substantial differences between these three versions, and that
                                                                                                                                                                                                   1 0
                           there are significant problems associated with transferring data from very                                                                                                  rr
                                                                                                                                                                                                       rr 0
                           :mall-scale maps to larger-scale maps.                                       The larger-scale maps (Plate 2A)
                             annot responsibly be used for any purpose other than to provide a general
                                                                                                                                                                                               Cal
                                                                                                                                                                                               W
                           indication of areas that have received higher than average use by calving                                                                                                      M
                                                                                                                                                                                                       <                                                                                                                        to
                           caribou in some years.                            it is inappropriate to state that these areas                                                                             M                                                     rn
                                                                                                                                                                                                                                                 (a    ca    Z
                           accurately represent locations where caribou were present in densities equal                                                                                            D, :r                                                     M
                                                                                                                                                                                                                                                       q
                           to or greater than 50 animals/square mile. or to designate a specific tract                                                                                             0                                             >
                                                                                                                                                                                                       ca In                                     r-    3.
                                                                                                                                                                                                       rt 0                                            r-
                           formed by composites of such areas as a special resource category with assumed                                                                                          1@. 0, :)
                           site characteristics that are "Unique and irreplaceable on a national basis".
                                                                                                                                                                                                          0

                                                                                                                                                                                                          r
                                                                                                                                                                                                          A.

                                                                                              G-33                                                                                                                                                                                     N

                                                                                                                   ARCTIC OCEAN

                                                   CAMDEN DAY

                                                                                                                                            BEAUFORT SEA

                                                                                                                                                                MACKENZIE
                                                                                                                                                                   "Y

                                                                                                                                                  ROSENEAU INITIAL
                                                                                                                                             e>   USFWS INITIAL
                                   R  01 er S                     R A N        G   E
                                                                                                                                             0    USFWS FINAL

                                                                                               1976                       1"
                                                                     CONCENTRATED CALVING AAEAS

                                     Vig
                                        ure  4 continued.

                                                                                                                   ARCTIC OCEAN

                                                  CAMVM "Y

                                                                                                                                            BEAUFORT SEA

                                                                                                                                                                MACKENZIE
                                                                                                                                                                   aAv

                                                                                                                                           ROSENEAU INITIAL
                                      0
                                      0 0
                                                                                                                                           USFW8 INITIAL
                                                                         N    G   E                                                         USFW8 FINAL

                                                                                              1977
                                                                                                                        A
                                                                   CONCENTRATED CALVING A, EAS
                                                                                                                                                                NAC:@

                                    Figure  4 continued.

                  D. The question of insect harassment                                                                           post-calving caribou and migrations, occur regardless of the presence of
                                                                                                                                 insects and are therefore more likely associated with the gregariousness
                                                                                                                                 and social behavior of caribou than with short-term modifiers such as
                  The draft report emphasizes insect harassment           and   the   importance of                              insects).
                  insect-relief habitat to caribou.     The authors state that "The insect season                                "in 1972, mosquitoes became very abundant on the Alaskan summer range of
                                                                                                                                 the PCH as far north as the Beaufort Sea coast as early as about 10 June
                  is a period of extreme natural harassment and one of the primary driving                                       (Roseneau at &1. 1974).    [1972 was the year 'of greatest insect abundance
                  forces in the annual caribou cycle" (p. 109, col. 1, par. 2).                                                  during the period from 1972 through 1977.1 Despite an early emergence of
                                                                                                                                 insects (primarily mosquitoes) inland and numerous warm, sunny days, the
                                                                                                                                 h
                                                                                                                                 ,:rd made no concerted effort to vacate the foothill zone (contrary to
                  We do not accept the latter assertion.            Indeed, we    believe that the                                sumptions that have been made    suggesting that insects regularly 'drive'
                                                                                                                                 caribou out of Inland zones).       Instead, most animals stayed inland for
                  preponderance of available evidence, while not conclusive, clearly indicates                                   about three weeks after insect emergence and two weeks after calving,
                  that insect harassment and the use of insect relief habitat are pgt primary                                    slowly coalescing In larger and     larger groups.   By about 20 June larger
                  driving forces In the     annual cycle of caribou and do mt exert a major                                      aggregations were beginning to      form, but these growing concentrations
                                                                                                                                 stayed inland until 30 June (Roseneau and Stern 1974). Then, within the
                  influence on caribou      aggregatory behavior or migratory movements.          The                            next two days (i.e., by the evening of 2 July, well after. Insect
                                                                                                                                 harassment began inland) most groups moved rapidly to the coast near
                  following discussion of   these points has been provided by D. 0. Roseneau In                                  Camden Day where they joined, forming one massive, classic post-calving
                  response to our reguest   for detailed information.                                                            aggregation.   Nithin 24 hours (i.e., an 3 July), the post-calving
                                                                                                                                 migration was well underway. The animals moved rapidly eastward a few
                                                                                                                                 miles south of the coast (where insects were numerous) to an far east as
                      "Certainly harassment by Insects, Including mosquitoes, oestrid flies and,                                 Barter Island,  and then turned southeastward (i.e., inland) toward the
                      in some areas,      blackflies,   has  an effect on       caribou.     However,                            Aichilik River  foothills, where not only mosquitoes, but also oestrids,
                      environmental factors. including insect harassment, are thought to be most                                 tended to be even more abundant.       Dver 40,000 animals continued esat
                      important.over the long term as evolutionary selective forces and over the                                 through the foothills of the lower Rongakut and Clarence river drainages
                      short term as modifiers of daily behavior patterns, activitieso and                                        and entered Canada in about seven days (i.e., by the evening of 10 July).
                      movements (e.g., Curatolo 2975)1. Insect harassment clearly does modify                                    About 30,000 other animals left the foothills, entered the coastal
                      the day-to-day activity . patterns, behavior, and movements of caribou, but                                lowlands east of the Kongakut River, reversed direction, and returned to
                      it does not in itself serve as a 2rimar driving force in the annual life                                   the lower Jago River floodplain by the evening of 10 July. The animals
                      cycle (i.e., Insect harassment tends to operate on an Intermittent,                                        that entered Canada traveled steadily through the British Mountains at
                      short-term, local level -- not at a higher level on the longer-term,                                       about 10 miles per day, usually traveling at night, and during the day
                      larger-scale events making up the annual life cycle).           Evidence that                              were intensely harassed by Insects (both mosquitoes and oestrids). During
                      insects (especially mosquitoes) are the primary cause of post-calving                                      the day, the migrating animals usually paused, hIll-topping and obviously
                      caribou coming together in large aggregations just before beginning their                                  making use of locally available insect-relief habitat during mid-day
                      post-calving migrations In weak.        Similarly,   evidence   that    Insects                            (McCourt at al. 2974).    Regardless of periods of on-going harassment by
                      (especially mosquitoes) actually cause migrations in weak.           There is                              Insects, these animals soon (on 21 July) crossed the headwaters of the
                      evidence that Insects may aid in forming and maintaining aggregations, and                                 Blow River, arriving in the upper Driftwood drainage (where insects,
                      also evidence that some insects (especially oestrid flies) play a role,                                    including oestrids, tend to be abundant) by the last few days of the month.
                      possibly an important role, In encouraging caribou to disperse over. their
                      late summer ranges.                                                                                        "The animals that returned to the Jago River were also harassed Intensely
                                                                                                                                 by Insects.  Even so, as they turned back near Demarcation Day, they did
                      "Large herds tend to be in near-constant motion and the annual cycle is                                    not move the short distance to the coastline where they could have
                      characterized by periods of strong, forceful movements - (e.g., spring,                                    actually found relief from Insects al*j2g.the beaches of the bay. As they
                      post-calving, fall, and early winter migrations) interspersed with periods                                 traveled westward near the coast between the Turner and Jago. rivers, they
                      of weaker, less directed movements (essentially pauses that Include times                                  were attacked steadily by swarms of mosquitoes and nose bats, and most
                      of calving, formation of post-calving aggregations. August dispersal, and                                  responded in classic fashion -- e.g., shaking heads, thrusting muzzles
                      wintering).  These annual movements are thought to be largely traditional                                  Into water or mud, occasionally jumping. They did gain some relief from
                      in nature and largely functions of the species' gregarious habits and                                      harassment by trotting steadily Into a westerly breess, However, as they
                      social behavior (e.g.. Lent 1966, Curatolo 1975).     Indeed, observation of                               continued moving, they did not shift their travel corridor to the actual
                      the Porcupine caribou hard (PCH) suggests that this is likely (i.e., that                                  coastline (often only 0.5-1.0 mile away) and thus bypassed many areas
                      major events, such as the actual coming together of large numbers of

                                                        G-34                                                                                                       G-35

                    (e.g.. beach-bluffs, beaches and gravel spits, shore-fast ice) clearly                                           River, pausing in valleys of the Clarence drainage during the evening of 8
                    affording better relief.         [At one point,       it can be added,          the                              July, and crossing into Canada on 9 July. These animals continued moving
                    investigators gave up and walked about 0.5 mile to the coast to enjoy                                            rapidly southeastward, away from the relatively insect-free coastal plain
                    brief insect relief for themselves before attempting to rejoin the caribou                                       near the international boundary and Into the warmer British Mountains,
                    farther inland.]                                                                                                 where insect concentrations were considerably greater.            These caribou
                                                                                                                                     entered the relatively warm upper Driftwood drainage by 23 July and were
                    "The 'Jago group' remained in Alaska for about one month. Within a few                                           exposed to substantial concentrations of insects (see Doll at al. 1974).
                    days after reaching the river, the conceniration broke into smaller groups
                    of   several hundred to several thousand individuals,              and gradually                                 "Thus in both 1972 and 1973, regardless of notable differences in insect
                    dispersed along the coast between Camden and Demarcation bays. During the                                        emergence dates and in Insect abundance between the two suffaers, the
                    first two weeks while these groups paused near the coast, they often made                                        Porcupine   herd    followed   the   same   basic,    traditional    pattern    of
                    use of the local shoreline in classic fashion for insect relief.               Then                              post-calving aggregation and migration.      In 1972, the worse insect year,
                    some animals began drifting back into Canada both coastally and inland,                                          most post-calving caribou stayed inland, coalescing into increasingly
                    while many others moved inland -- through areas still                    containing                              large groups in the presence of large numbers of insects, then moved
                    relatively large concentrations of insects -- to the uplands near Peter                                          rapidly to the coast well after insects had emerged at the coast,
                    and Schroder lakes, where they made use of local hilltops for Insect                                             aggregated briefly coastally, and then turned inland, traveling for many
                    relief before also drifting eastward into Canada,                                                                days through heavily insect-infested regions of Alaska and Canada, and
                                                                                                                                     making use of local insect-relief areas while continuing to migrate
                    "In contrast to 1972, conditions In 1973 were considerably cooler on the                                         farther southeastward In Canada. . (Animals that turned back west into
                    PCH's summer range in Alaska (Roseneau st al. 1974). and insects were                                            Alaska and paused near the coast also made use of locally available
                    lower in abundance that summer than in most years during 1972-1977. The                                          insect-relief habitat before moving back eastward into Canada.)                  In
                    differences between 1972 and 1973 help provide insight into the question                                         contrast, in 2973 -- a relatively insect-free year -- large numbers of
                    of insects driving major events in the caribou annual cycle such as                                              caribou began coalescing inland despite an absence of Insects, moved
                    post-calving aggregations and migrations.           Mosquitoes began emerging                                    rapidly to the coast well before insects had emerged at the coast, briefly
                    inland during late June, and finally became noticeable on the coastal                                            formed large coastal aggregations as insects were just beginning to
                    plain during the first few days of July (initial numbers were very low).                                         emerge. and migrated eumass inland into Canada, abandoning a broad,
                    Mosquito numbers remained relatively low both inland and near the coast as                                       essentially Insect-free zone in Alaska in exchange for a substantially
                    late.as 8 July, and did not reach concentrations resembling those seen the                                       insect-infested region of Canada."
                    previous year until about mid-July, after post-calving Porcupine caribou
                    had left Alaska.      Despite the general absence of insects both in the                                                                             (NOTE)
                    inland foothills and on the coastal plain, post-calving movements of
                    caribou were nearly identical to the post-calving movements seen the                                             I(Curatolo (19715) stated that caribou appear to have a relatively high
                    previous year.                                                                                                   tolerance to mosquitoes and that mosquito harassment acts as a modifier of
                                                                                                                                     ongoing caribou activity.      He also believed that mosquitoes have very
                    "Post-calving aggregations began coalescing in the          southern lowlands by                                 little  effect an initiating        (i.e.,    actually causing)      post-calving
                    about 20 June.       (Caribou were distributed broadly and were already                                          migrations.   However, he believed that oestrids do have a role in
                    utilizing lowland areas, and had been for some time, because snowcover had                                       dispersing caribou during the August (late summer) dispersal.)
                    been light and, despite cooler conditions, had begun to disappear much
                    earlier than during the previous year.) By I July, post-calving animals                                    R.    ImR2rtance of the coast as insect-relief habitat
                    were moving rapidly north to the coast between Camden Bay and Barter
                    Island, and most of them formed a massive, classic aggregation spreading
                    several miles Inland by the early morning of 3 July (Roseneau at al.                                       The   following discussion was prepared by D. G. Roseneau in response to our
                    1974).   A steady, forceful, eastward migration began almost immediately:                                   request for detailed information.
                    it 'was underway by the late morning of 3 July. The animals paralleled the
                    coast, staying within a narrow corridor about two miles inland, and
                    vanguard elements arrived just south of Beaufort Lagoon by early morning                                         "The authors of the draft   .report emphasize the importance of the coastal
                    on 4 July.     By the next day at Beaufort Lagoon, the migrating animals                                         fringe as insect-relief habitat (e.g, see Plate 2A). and state:
                    began moving inland away from the insect-free zone toward the foothills of
                    the Aichilik and Kougakut drainages,            where mosquitoes were still                                           'A greater concern, relative to the location of potential barriers
                    relatively scarce on hilltops, but more abundant in the valley bottoms                                                under the full leasing scenario, would be inhibiting movements for
                    where    oestrids    were   also    present.    A    massive   concentration     of                                   the large post-calving aggregations which annually occur on the 1002
                    72,000-87,000 animals moved through the lower valley of the Kongakut                                                  area as they move between          inland   feeding    areas    and coastal
                                                                                                                                          Insect-relief habitats' (p. 109, col. 1, par. 2).

                                                          G-36                                                                                                           G-37

                       "The importance of the coastal fringe as important insect-relief habitat,                                         "It should be noted that the depiction of insect-relief habitat In Plate
                       including implications that large numbers of post-calving caribou go to                                           2A is very general. Also, areas of insect-relief habitat include many of
                       the coast regularly for the purpose of using it for relief from insects.                                          the river corridors between the Brooks Range and the Beaufort Seat thes
                       as well as concerns that the Porcupine herd might somehow be placed in                                            are not shown.    Not all areas that are perceived by humans to be potential
                       jeopardy if large aggregations were prevented from reaching insect-relief                                         insect-relief habitat are used by caribou to any great extent, and not all
                       habitats, are over-emphasized and are not necessarily consistent with most                                        areas shown in the major insect-relief zone' of Plate 2.A are actually
                       data (see preceding discussion).      PCH caribou typically make use of a wide                                    used by caribou."
                       variety of local habitat types for insect relief, including hilltops,
                       river bars, river banks, and floodplains, in addition to the kinds of                                        F.   The guestion of differences between herds
                       habitat afforded by the coastal fringe (e.g., coastal bluffs, beaches,
                       barrier islands, shore-fast ice) as conditions warrant on summer range.
                       In most years, large post-calving aggregations have spent very little time                                   The following discussion was prepared by        -D. G.   Roseneau in response to our
                       actually at the coast.      Usually, large numbers of animals gather inland,                                 request for detailed information.
                       move rapidly to the coast in a few days, and then, after briefly 'stacking
                       up' at the coast, migrate rapidly away from it after only a few more
                       days.   (This was true even in 1972, one of the worst insect years on                                             "The authors indicate     that caution must be used when drawing analogies
                       record.)    Moreover,    In years when post-calving migrations generally                                          between the Central Arctic herd (CAN) and the Porcupine caribou herd
                       followed the coast, most of the animals remained one or two miles inland,                                         (PCH).   We agree completely.        However. the most relevant differences
                       generally ignoring the nearby beach-bluffs, beaches, spite, and remnant                                           between the two herds involve relative herd sizes and contrasts In range
                       shore-fast areas affording better relief from insects (although some                                              geography.   Other perceived differences (e.g., abilities to habituate) are
                       migrating animals have used these areas during short pauses                 in the                                likely to be of less importance.       Both herd size and range geography are
                       eastward movement).      [Examples of years when migrating caribou stayed                                         important considerations because they may have considerable bearing on how
                       inland   from coastal insect-relief areas include 1972               (for    initial                              caribou respond to development on their ranges. As indicated in the draft
                       movements onlyi see exception below), 1973, 1974, 1975, and 1979.)            In at                               report, the CAN is a relatively small herd ranging in summer north of the
                       least two years, post-calving aggregations did not visit the coast at all                                         Brooks Range across a very broad coastal lowland and upland area extending
                       (in 1976,   when many smaller aggregations formed and stayed well inland                                          many miles east and west.         In contrast, the PCH is a very large herd
                       along over 100 miles of the front of the Brooks Rang       e and northern British                                 ranging in summer across a much narrower coastal lowland and' upland area
                       Mountains,  where insects were generally more numerous than in the coastal                                        between the Brooks Range and the Beaufort Sea.               Large herds tend to
                       zone; and   in 1981, when many smaller aggregations formed and stayed inland                                      undertake longer. more direct, and more forceful movements then those of
          L            along the Sadlerochit and Romansof mountains).                                                                    small herds, and the generally widespread, weaker, and less forceful
                                                                                                                                         movements of the CAN must be taken into account when attempting to
                       "jAn exception to the above pattern occurred In 1972, when a large element                                        interpret responses to oil development, including reactions to physical
                       of the cow-calf segment turned back near the international boundary after                                         structures and human activities.        The much larger size of post-calving
                       being joined by many newly arriving bulls (one possible reason for the                                            aggregations    and the greater momentum and inertia of                 post-calving
                       turn-around). These animals, totalling about 30,000 Individuals, returned                                         migrations of PCH animals may result in different levels of response to
                       to the Jago River, and then dispersed between Camden and Demarcation                                              similar activities.      These differences may not necessarily         be adverse.
                       bars.   While pausing near the coast for about two weeks, many of these                                           For example, large migrating aggregations of PCH animals might be less
                       animals did indeed seek relief from insects in coastal habitats.)                                                 hesitant when approaching structures, and might cross roads. and pipelines
                                                                                                                                         more readily than has been seen near Prudhoe Bay (where information on
                       "In some recent years, large numbers of post-calving caribou have remained                                        interactions between the pipeline corridor and 'large' groups is still
                       in Alaska somewhat longer and later than during previous years.                 [The                              limited to observations of groups consisting of less than 1,000 animals;
                       first Instance occurred In 1977 when post-calving animals remained between                                        see Smith and Cameron 1985).         Also, after lead animals in large groups
                       the Hulahula and Atchilik rivers until about late July.) However, even in                                         cross   potential barriers,       remaining    animals,    including caribou        In
                       several of these years, most animals visited the coast only for relatively                                        following groups, might tend to pay less attention to the perceived
                       short times.     (The few ezceptions have been years when elements of the                                         obstacles and continue moving along the established route with less
                       herd have turned back west as in 1972. Examples include 1977 and 1983 (a                                          hesitation.    On the other hand, if the lead animals in large, forcefully
                       year having some similarity to 1972).)          In general, based on available                                    migrating groups are deflected, it is possible that the groups might
                       information, It is doubtful that even relatively maigx (hypothetical)                                             travel farther than would smaller groups of similarly deflected caribou.
                       losses of coastal fringe habitats would Prove to be of more than minor                                            However, it should be understood that even very large deflections would
                       conseguence to the Poreugine her                                                                                  not necessarily produce adverse effects on the,caribou population."

                                                             G-38                                                                                                              G-39

                G. Response of caribou to oilfield development

                The draft report's analysis of potential effects of development on calving
                caribou are based primarily on conclusions attributed to a study comparing

                                                                                                                                                                          A
                densities of caribou cows and calves before and after construction of an                                                3.0-                              yi-0.32xi-0.50
                oilfield road on the Arctic Coastal Plain: "Dan and Cameron (1985), in what                                                                                rgO.65
                may be the most systematic study of caribou displacement by oil development,                                       ft   2.57                              P<0001
                                                                                                                                   .W
                reported that maternal groups showed measurable declines In habitat use within                                          2.0-
                approximately 2 miles on either side of the Milne Point road in the central
                                                                                                                                                                0     0
                Alaskan arctic" (p. 107, col. 2, par. 2).     However, examination of the cited                                         1.5 - - - - - - -0-
                                                                                                                                   13                                          0
                paper shows that Dau and Cameron (1985) did   AQt refer to decreased habitat use                                         -                           A
                                                                                                                                   'S   1-0     0      0             Yo-O.O1Xi+1.33 0
                within 2 miles of the Milne Point road, and    that their study is so confounded                                   d    0       0                        r--0.04
                by uncontrolled variables that it is quite     impossible to make any conclusive                                        5                                P>0.50
                interpretation of their results.                                                                                        0.0   -H 071978-811 1          1   -   1
                                                                                                                                                  10 1982-85
                Figure 5 presents graphs from the Dan and Cameron paper showing the
                                                                                                                                                                     A
                relationship between the square toot of the density of all caribou and also of                                                                       Yi-O.Mi+0.12
                calves only, and distance from the road. The data points shown are the means                                            2.0                               r-0.68
                                                                                                                                                                          P<0.001
                of four years; no information about year-to-year variability In given.          The                                     1.5
                data were collected by helicopter surveys conducted during the four years
                prior to road construction (1978-1981) and the four years following road                                                1.0
                                                                                                                                                       0-
                                                                                                                                               0          ". @OO
                construction (19 .82-1995).  The Intent, of course, was that the first four                                             0.5-                    aoi-, ,51
                years' data would serve as a control against which to compare caribou                                              0                          r--0.07
                                                                                                                                   d    0       OL           P>10.59 I         I      I
                distribution after the road was in place and development had begun.                                                z    0.0     1               3     4        5     6
                                                                                                                                                   Distance  from kood    (km),
                Use of the square root tranaformation and of calculated regression     lines (Fig.
                5) gives the impression that caribou density was evenly distributed within 6
                km of the alignment prior to construction of the road, but afterwards was low
                near the road and high away from it.     If we take the graphs in Fig. 5 at face                           Figure S.    r5raphs from Dau and Cameron (1985) showing relationship between
                value, an effect relating to the presence of the road appears to continue out                              the square root of the density of caribou to distance from the road leading
                to at least 6 km.      However, removing the square root transformation gives                              to the Nilne Point oilfield.     Data from 1918-1981 were collected prior to
                                                                                                                           construction of the road; data from 1982-198S were collected after the road
                quite a different picture (Fig. 6).     Examination of the non-transformed data                            had been built.    Note that the data points shown are square roots of the
                leads to four observationst                                                                                four-year means.   Values for individual years have not been made available
                                                                                                                           by the authors and consequently, the annual variability is unknown.
                                                                                                                                                                0
                                                                                                                                                                0     0
                                                                                                                                              @0_                     i: __0

                                                        G-40

    		ALL CARIBOU

    Figure 6.  A replotting of the data in Figure 5 to show approximate actual
    values.  Because the authors have not made the orginial data available,
    values were obtained by reading the square roots in Figure 5 and squaring
    them.  Shown are the four-year means; variances are not known.  [Note added
    in proof: R. Cameron, Alaska Department of Fish and Game, has provided the
    actual four-year means.  They are not significantly different from those
    shown in Figure 6.]

    1. 	In both four-year periods, the data from 1-3 km show the same trend,

    	i.e. increasing density away from the road alignment.  The fact that

    	this trend existed both before and after the road was constructed

    	suggests that some other factor (e.g., topography) may have

    	influenced the distribution of caribou.

    2.	The densities shown for the 1-3 km interval are the four-year means;

    	no information on year-to-year variability is given.  Assuming that

    	there was a normal amount of variability, it is almost certain that

    	the data from both four-year periods overlap and are not

    	statistically different.

    3.	The real differences in the data sets appear to be in the 4-6 km

    	interval.

    4.  	From inspection of the curves, it is apparent that there were roughly

    	twice as many caribou in the study area (i.e., the 1-6 km zone)

    	following road construction than before.

    Finally there are two other factors that confound interpretation of the Dau

    and Cameron (1985) data.  The authors apparently assumed that the density of

    calving caribou would be the same in both four-year periods.  This implies an

    assumption on theri part that 1) the population was constant in size, 2) that

    the distribution was essentially the same, and 3) that snowmelt and weather

    conditions were practically identical.  In fact, the Central Arctic herd

    roughly trebled (i.e., from 5,000 to 15,000) in size during the period over

    which the study took place, and snowmelt and weather conditions differed

    betwwen years, as did the distribution of calving caribou.

    What explains the pattern seen in Figure 67.  It is impossible to know.  Dau

    and Cameron's (1985) study is too unclear to permit a conclusion to be drawn,

    and there is no scientific basis to conclude from their study that any

    displacement of caribou resulted from the road and associated activity.  If

    the numbers out to 6 km are compared, it is clear that there were about twice

    as many caribou in the area after the road was constructed than there were

    							G-41

    before.  Clearly, it is inappropriate for the draft report to base predictions

    of potential caribou displacement form the "core calving area" on the Dau and

    Cameron study.

    During the period 1981-1986 surveys of the calving distribution of the Central

    Arctic Herd have been conducted (RRCS, 1985; R.M. Jakimchuk 1986, pers.

    comm.).  Figure 7 shows areas of major usuage by calving caribou.  It is clear

    that although calving densities may be lower immediately adjacent to areas of

    active oilfield operations, caribou continue to calve in the region where they

    have traditionally done so.

    The most important point is that whatever the exact response of the Central

    Arctic Herd to oilfield activities, the herd has grown rapidly.  Clearly, and

    contrary to may earlier predictions, whatever the effect of oilfield

    activiites on individual caribou, there have been no detectable

    population-level effects.  The herd has more than quadrupled in size since

    development begain in the early 1970s.  Nor is this situation unique:  several

    (Bergerud et al. 1984).  The only effect of human activity that has clearly

    been capable of seriously lowering caribou numbers is direct mortality from

    excessive hunting.

    (It should be reconginzed that traffic in the 1002 area will be appropriately

    controlled during periods when calving animals are present near oilfield

    developments, and that construction will be timed to avoid periods when

    calving and post-calving caribou are present.)

    7.  WATER AND GRVEL AVAILABILITY

    Throughout the 1002 draft Report there are numerous references to gravel and

    water shortages with the implication that there are no know means by which

    these resources can be obtaine din quantities sufficient to support

    exploration and development operations.  The Report overstates potential

    problems in both cases.

    							G-42

                  A. Hate Ir                                                                                                  Sea and the shorter steeper gradient streams and rivers carry a significant
                                                                                                                              load of gravel throughout their length.         No river such as the Colville
                  Lack of readily available water resources is acknowledged, however its                                      intercepts the north-trending drainage to deprive the coastal streams of
                  significance is repeatedly overemphasized. The availability of fresh water Is                               discharge and gravel load.     At Prudhoe Bay, further west, gravel resources
                  not a problem unique to the 1002 area. Over 250 exploration wells have been                                 have been more than adequate to sustain both onshore and nearshore petroleum
                  drilled in the North Slope arctic desert. Methods      Ideveloped to satisfy water                          development. The basic geomorphological setting; and recent geotechnical data
                  requirements elsewhere in the arctic will be applicable to activities In                                    from the Coastal Plain, clearly lead to the conclusion that there are
                                                                                                                              available gravel resources.      Gravel can be utilized without significant
                  ANWR. Just as water availability varies by location, solutions to providing
                  water will have to be considered on a site by site basis. Examples of methods                               adverse environmental Impacts and is more than adequate to support major
                  that will be contemplated include creating deep pools in river/stream beds.                                 petroleum development.
                  creating deep pools. In lakes, desalination of sea water, erecting snow fences
                  to trap snow which could be used with snow melters, insulating lakes to keep                                8. AIR AND WATER  QUALITY
                  them from freezing to bottom, and the conversion of gravel extraction pits to                               Existing oil and   gas development at Prudhoe B  .ay and Kuparuk has not resulted
                  reservoirs. Water availability will not limit industry's ability to operate
                  in the region.                                                                                              in any significant impacts to air and/or water quality.               The existing
                                                                                                                              regulatory structure affords numerous opportunities for state and federal
                  B. Gravel                                                                                                   resource agencies, in addition to the issuing agency,     .to review projects and
                                                                                                                              make   recommendations    for   modifications   and/or    permit   conditions    and
                  With respect to the availability of gravel, the Information in the document is                              stipulations which minimize the potential for air and water quality Impacts.
                  actually contradictory. On,:ppp 20 the report acknowledges that "valleys of                                 The existing regulatory structure is sufficient to ensure similar protection
                                                                                                                              for the environmental resources in AM. Prior to recommending any additional
                  larger streams are underlain      by the large quantities of coarse sand, and                               regulatory authorities, a careful review of the      .existing requirements should
                  gravel." The Executive Summary    (page 6) states however that gravel is in very
                  limited supply.    Again on page 75, it is reported that specific sources of                                be conducted to identify potential gaps, if any, in coverage of environmental
                                                                                                                              concerns. Any recommendation for now authorities should be specific to these
                  gravel have not been identified.         On page 84, the Report reads: "The
                  availability of adequate gravel supplies on the 1002 area is uncertain." Not                                identified gaps in coverage and not duplicate existing programs, since the
                  only do these inconsistencies require correction,           but also information                            existing regulatory framework already is duplicative and cumbersome.            This
                  gathered during past geophysical surveys needs to be evaluated and reported.                                perspective is supported In the following discussion.
                  Geophysical operators conducting the surveys were painfully aware during their
                  two seasons of  .drilling all over the 1002 area that virtually the entire                                  A.  Air gualit
                  region is underlain in the very near surface (75' holes) with gravel.          Drill
                  logs containing this information were available to the government as were                                       The discussion of air   quality in the 1002 Report is brief and generally
                  samples from all the holes.                                                                                     correct however a thorough analyses of the multitude of air quality data
                                                                                                                                  available from North Slope operations is not given.       Air quality data on
                  It is logical that this area of the North Slope        harbors significant gravel                               the Arctic Coastal Plain has been consistently good. always better than
                  resources.   The Brooks Range mountains are at their closest to the Beaufort                                    national standards even downwind of oil and gas development.            Emission

                                                          G-43                                                                                                        G-44

                     sources can cause a localized increase    In the ambient air quality above                               in operation.   The results of this study are summarized in the Table 3.
                     background levels at Prudhoe Bay and Kuparuk, however federal PSD review                                 All measured ambient air quality levels were well below the applicable
                     in conjunction with atmospheric dispersion modeling studies and aerometric                               National Ambient Air Quality Sta Indards (HAAQS).
                     monitoring programs indicate compliance.     The diminimus impact of the
                     relatively large development is below the regulated emission       limits of                             Due to PSD - permitted increases in heater and turbine capacity, two
                     the U.S. Environmental Protection Agency (EPA) and the Alaska Department                                 one-year ambient air quality monitoring programs, developed In cooperation
                     of Environmental Conservation (KDEC).    Regional air quality has not been                               with the EPA Region X and the Alaska Department of Environmental
                     degraded by the existing oil and gas development.                                                        Conservation (ADEC), were begun on the North Slope during 1986 to assess
                                                                                                                              post construction ambient air impacts due to oil and gas production
                                                                                                                              facilities.  Both the Kuparuk River Unit (KRU) and the Prudhoe Bay Unit
                     The primary source of air emissions from North Slope oil and gas
                                                                                                                              (PBU) instituted air monitoring programs to assess the air quality at each
                     production facilities results from the operation of natural gas-fired
                     turbines and beaters.   Since the fuel used by all permanent facilities is                               respective unit's maximum air quality impact location as well as a
                     low sulfur natural gas, the emissions of sulfur dioxides are minor. The                                  location representative of background air quality levels.
                     H2S content of fuel gas as measured over the past 8 to 10 years has
                     varied from 10 to 15 ppm resulting in extremely low SO     2  emissions.which                            In the PBU the station placed at the maximum ground level impact receptor
                     are well within the National Ambient Air Quality Standards (NAAQS) 83 well                               to directly downwind from a facility that operates thirteen 3.5 MHP
                     as the PSD Increments. Likewise, the emissions of TSP,     .CO and HC are also                           gas-fired turbines, the largest single concentration of emission sources
                     extremely low and well within NAAQS. The only criteria pollutants emitted                                on the North Slope. Data acquired to date from this monitoring effort has
       21            in significant quantities from North Slope facilities are oxides of                                      not identified air emission levels even approaching NAAQS.            Table A
                     nitrogen.                                                                                                summarizes the preliminary data from the two ongoing monitoring programs.

                     The gas-fired turbines, most of which are in the 30 to 35 MHP range,                                     In summary, there is sufficient air quality data demonstrating that oil
                     produce the majority of the 60, emissions.          Beat Available Control                               and gas production activity on the north slope does not detrimentally
                     Technology (BACT) limits were established at the New Source Performance                                  affect arctic air quality and that north slope facilities are well within
                     Standard (NSPS) limit of 150 ppm NO    2 for gas-fired turbines during PSD                               the NAAQS.
                     permitting in the early 1900's. A variety of types of turbines operating
                     on the North Slope have been compliance tested. These turbines have met
                     permit limits and generally produce emissions well below the required
                     limits (See Table 2).

                     Ambient air monitoring was conducted on the North Slope by the Prudhoe Bay
                     Unit from April 1979 through March 1980 to determine the ambient air
                     quality on the North Slope of Alaska when there was approximately 600 MHP
                     of gas fired turbine capacity and 770 MMBTU/hour of gas fired heater duty

                                                         G-45                                                                                                    G-46

                                                        TABLE 2                                                                                                        Table 3
                                            Measured Turbine Emission Levels                                                                             Measured Pollutant Levels (ug/m    3
                                                 At Prudhoe Bay, Alaska                                                                                        At Prudhoe Bay, Alaska
                                                                                                                                                         from April 1979 through March 1980

                                                                                                                                                                                     National Ambient Air

                                                                                                                                                               Monitor Location         QMalitv Standards

                                                                                                                                                                 Drill      Well
                                                                 Allowable             Actual                                   Pollutant                        Site 9     Pad A    Primary        Secondary
                         Turbines               Ca2acit          NO, Rate              NO. Rate
                                                               RM      lb/MMBtu             lb/MMBt                             Nitrogen Dioxide
                                                             (015%02)             (@15% 02                                      1 Hour Maximum                    84.0      125.0           ---            ---
                                                                                                                                Annual Arith. Mean                  3.5        4.0          100            100

                                                                                                                                Ozone,
                 Ruston-RD 2500                  2.5  MHP      150       0.56         73       0.27
                                                                                                                                1 Hour Maximum                   113.0      113.0           23S            235
                 Ruston-RB 5000                  4.9  MRP      153       0.57         83       0.31                             Annual Arith. Mean                51.0        47.5          ---            ---
          A
                 GE-MS 5001                     25.0  MRP      150       0.56         66       0.25                             Carbon Monoxide
         -4      GE-MS 5001P                    34.0  MHP      167       0.62        102       0.38
                 GE-MS 5002R                    33.5  MRP      208       0.77        181       0.67                             1 Hour Maximum +                3430.0     3120.0       40,000           40,000
                                                                                                                                8 Hour Maximum *                 946.0      856.0       10,000           10,000
                 GE-M 5352                      35.0  MHP      173       0.64        100       0.37                             Annual Arith. Mean               133.0      171.0           ---            ---
                 GE-M 3142(J)                   14.6  MHP      162       0.60        121       0.45                             Sulfur-Dioxide
                 Cooper Rolls     RB 211-24     29.1  MHP      205       0.76        146       0.54
                 Solar Mare                     23.0  MBP      293       0.74        135       0.50                             3 Hour Maximum                    13.0        25.3          ---           1,300
                                                                                                                                24 Hour Maximum +                   9.5        9.3          365            ---
                 Solar Centaur                   3.95 MRP      164       0.61         98       0.36                             Annual Arith. Mean                .0.4         0.5          80             ---
                 Sulzer                          7.7  MHP      ISO       0.56        143       0.53

                                                                                                                                24 Hour Maximum                  112.0      294.0           260            150
                                                                                                                                Annual Gen. Mean                    6.7       11.4          75               60

                                                                                                                                Sources Radian Corporation, 1981.

                                                                                                                                      Not to be exceeded more than one per year.

                                                                                                                                      Ozone standard is attained if the expected number of days per calendar
                                                                                                                                      year with maximum hourly average concentrations above 0.12 ppm is equal
                                                                                                                                      to or less than one.

                                                            G-47                                                                                                         G-48

    							Table 4
    						Ambient Air Monitoring Results
    							North Slope Alaska
    								1986

    				Prudhoe Bay Unite Ambient Air Monitoring Results

    					October	November	December	Quarter
    Maximum Impact Site
    Central Compression Plant
    	03 (ug/m3)			49		54.9		51		51
    	NO2 (ug/m3)			15		13.2		15		15
    	SO2 (ug/m3)			7.9		7.9		7.9		7.9

    Background Site
    Well Pad A
    	03 (ug/m3)			52.9		56.8		56.9		54.2
    	NO2 (ug/m3)			7.5		7.5		7.5		7.5

    			Kuparuk River Unit Ambient Air Monitoring Results

    											First
    					July		August	September	Quarter
    Maximum Impact Site
    Kuparuk River Unit CPF-1
    	03 (ug/m3)			37		37		39		35
    	NO2 (ug/m3)			17		15		9		11
    	SO2 (ug/m3)			2.6		2.6		2.6		3

    Background Site
    Kuparuk River Unit DS1-F
    	03 (ug/m3)			39		35		49		37
    	NO2 (ug/m3)			6		9		2		4

    						G-49

    B.	Water quality

    	The existing regulatory framework applicable to exploration and

    	development activities provides for a comprehensive review of

    	essentially all phases of every project and ensures adequate

    	consideration of environmental concerns, especially those related to

    	protection of water quality.  For example, if one wanted to construct a

    	gravel pad and reserve pit in a wet tundra area and drill a well on that

    	pad, the following permits, authorizations, plans and approvals would be

    	required before the construction could proceed (Note that this is not an

    	exhaustive list of the potential requirements, but a sample of the types

    	of permitting procedures typically required):

    	1.)  	Federal (U.S. Army Corps of Engineers)

    		Section 404 Discharge of Dredge of Fill to Waters of the U.S.

    		The Corps has asserted Section 404 jurisdiction over wet tundra (as

    		"Waters of the U.S.") since 1979.  This section of the Clean Water

    		Act requires that a Public Interest review be conducted including

    		an evaluation of the project against the 404 (b) (1) guidelines

    		promulgated by the EPA.  These guidelines contain specific

    		consideration of water quality concerns.

    		The Fish and Wildlife Coordination Act provides for the formal

    		involvement of applicable federal resource agencies in reviewing

    		and providing comment on federal actions such as the Corps' 404

    		permit.  Therefore, at a minimum, the Fish and Wildlife Service,

    		EPA and National Marine Fisheries Service are give the opportunity

    		to provide comments and recommendations regarding this permit.  In

    		addition, the EPA has ultimate veto authority over Corps 404

    		actions.

    		If the project being permitted is determined to be "major", the

    		National Environmental Policy Act (NEPA) may require the

    							G-50

                            preparation of an gnvironmental ImRact Statement (EIS), such as was                                            The ACMP contains specific policies and procedures          regarding the
                            the case with the Endicott Development, Project.       (An oil field 20                                        evaluation of the environmental effects of a given Rroject. Alaska
                            miles northeast of Prudhoe Bay.)                                                                               uses the mechanism of conditional consistency concurrences--&
                                                                                                                                           project may be deemed consistent if certain stipulations are
                      2.)   State (Alaska Department of Environmental Conservation)                                                        incorporated. This provides an addition      .al regulatory mechanism for
                            Sectign 401 Water Quality Certification for the Section      404 Permit.                                       the State to respond to environmental concerns regarding potential
                                                                                                                                           surface water impacts.

                            The State has formal review and approval authority for actions such
                            as the Corps' 404 Permit described above. One mechanism is through                                        All  of the above permits,         reviews    and mechanisms     for    affixing
                            the 401 Water Quality Certification process.           The Corps' must                                    stipulations   for a given proj      act result basically from the one
                            receive 401 certification before th      .a 404 permit can be issued.                                     requirement for a 404 permit. This one regulatory requirement triggers,
                            This process provides for consideration of      the project in terms of                                   two federal and two State review mechanisms and affords a comprehensive
                            its effect on State Water Quality Standards and contains a                                                review of any potential surface water problems from the proposed
                            mechanism for issuing a conditional certification.         That is, the                                   project.   In addition to tAis suite of' requirements, the following are
                            State can affix stipulations regarding reserve pit construction and                                       additional regulatory requirements for the same given project (Again,
                            operation to the 401 certification to provide for protection of                                           this is not an exhaustive list of the potential requirements):
                            surface water quality.
                                                                                                                                      4.)  Federal (Bureau of Land Management (BLMI)
                                                                                                                                           Exploratory Drilling and/or Development Plan Approval
                      3.)   State (Division of Governments! Coordination EDGCD
                                            Manogement                  Consistency Determinatio                                           Permit to Drill. DeeRRn or Plug Back

                            The State recently developed new permitting procedures which                                                   The application requirements for these permits and plan approvals
                            provide for a comprehensive State review of projects involving a                                               include the preparation of numerous plans describing how the
                            Federal and a State permit, or two or more State permits.             These                                    construction of facilities will proceed, how various waste streams
                            procedures provide formal involvement of the Departments of NatuK&J                                            will be handled, how the site will be rehabilitated. Additionally.
                            Resources    (DNR).   Fish   and   Game    (ADFG).    and    Environmental                                     an oil Spill Prevention, Co    Intaimsent and Countermeasure (SPCC) Plan
                            Conservation OXEC).       The Division of Governmental Coordinatio                                             Js prepared and submitted with the application.            The SPCC plan
                            (DGC1 within the Office of Management and Budget (OMB) acts as the                                             addresses the environmental setting of the facility, potential
                            coordinator for the State review process.         Additionally. the new                                        sources of oil/hydrocarbon discharges, location and description of
                            program regulations provide for formal involvement of the effects                                              response equipment, preliminary restoration plans, handling of
                                                                                                                                           spill cleanup materials.
                            Coastal Management District, in this case the North Slope Borough

                                                                                                                                      5.)  State (DGC).
                                                                                                                                           ACHP Consistency Determination

                                                           G-51                                                                                                            0-52

                           The  BtJ4   permits/approvals    described    above   require    an ACMP                                        0    Description    of   the   proposed    development    and     operating
                           Consistency Determination.      This program and its implementation                                                  procedures and ways that water pollution wi     .11 be controlled,
                           were discussed previously.
                                                                                                                                           0    Evaluation of      the   site's leachate generation and water
                     6.)   Federal (BLM)                                                                                                        pollution potential based on waste quantity and type, site
                           Authorization for DisRasal of Produced Water                                                                         geology, hydrol  ogy, and other physical cc  nditions

                           Water produced from oil and gas wells must be disposed of In                                                    0    Discretionary requirement for the determination of surface
                           accordance with approved authorization from the BIX.                                                                 water quality nearthe proposed site.

                     7.)   State (DGC)                                                                                                     Thus, reserve pits have been regulated in the past and are becoming
                           ACMP Consistency Determinatio                                                                                   subject to move specific requirements that are tailored to the
                                                                                                                                           special conditions required for reserve pits in permafrost areas.

                           The DE14 authorisation described above requires an ACHP Consistency
                           Determination.    This program and its implementation were discussed                                      9.)   state (DGC)
                           previously.                                                                                                     ACMP Consistency Determination

                     8.)   State (ADSO                                                                                                     The Solid Waste Disposal Permit, like the            other State permits
                           Solid Waste DLM20801 Permit                                                                                     mentioned    previously,     would    require    an    ACMP     Consistency
                                                                                                                                           Determinatio    that provides a mechanism for affixing additional
                           The State has produced new regulations tailored         more specifically                                       stipulations and requirements on the construction and operation of
                           to the drilling fluids disposal Issues than in the past. These new                                              the reserve pit. This determination would involve the Departments
                           regulations are nearing promulgation and include consideration of                                               of Environmental Conservation. Natural Resources. and Fish and
                           the differences created by the presence of permafrost.          The focus                                       Game, the Division of Governmental Coordination and the North Slope
                           of the new regulations will be on efficient fluid management                                                    Boro
                           practices to reduce the volumes of water in the reserve pit.               A
                           more specific monitoring program will be required for the detection                                       10.)  Federal (EPA)
                           of potential seepage problems.                                                                                  NPDRS Permit f                  ischarge to Surface Waters

                           It must be recognized, however, that there are existing regulations                                             The National Pollutant Discharge Elimination System is a permitting
                           requiring a Solid Waste Disposal Permit for a disposal site such as                                             system for point source discharges of wastewater to surface waters
                           reserve pits.     Although the now regulations are more specific                                                of the U.S. This program is administered by the EPA.
                           regarding information requests pertinent to reserve pits, the
                           existing regulations require substantial information submittals
                           including, but not limited to, the following:

                                                           G-53                                                                                                            G-54

                      11.) State (ADEC)                                                                                               The  simplified example of a single gravel drilling pad also does not
                           401 Water Quality Certification for the NPDES Permit                                                       include considerations for what          it would     take   for   permits     and
                                                                                                                                      authorizations for the necessary gravel and water sources, and access to
                           The State must issue a certification that the Federal permit would                                         the pad. A thoughtful and careful analysis of the existing regulatory
                           not violate the State Water Quality Standards.                                                             framework for oil and gas exploration and dqvelopment activities should
                                                                                                                                      be undertaken prior to formulating any recommendations on additional
                      12.) State (DGC)                                                                                                regulatory authorities.
                           ACMP Consistencl Determinatia

                           The NPDZ8   Permit and the State 401 Water Quality Certification
                           mentioned    above   are   both    subject to the KCMP Consistency
                           Determination requirements discussed previously.

                      23.) North Slope Borough (RED)
                           Development Permit

                           The North Slope Borough's Land Kanagement. Regulations require a
                           development permit for oil and gas activities.

         CA)
                      In addition to the   above listing of requisite permits and.author       Izations
                      for the relatively simple example of a single drill pad, there are
                      numerous programs, processes, methods and procedures that regulate other
                      aspects of the construction/production of this facility. There will be
                      the listing of environmental protection requirements that will be
                      imposed as conditions for allowing the ANNE to be leased. Also, there
                      will I be the listing of environmental protection requirements that will
                      be imposed an conditions of the lease male ("Notice to Lessees"). Not
                      mentioned specifically above are the state and federal environmental
                      protection. programs covering oil spills and hazardous substances control
                      (Toxic Substances Control Act          [TSCA],   Comprehensive Environmental
                      Response, Compensation. and Liability Act (CERCLAI, Hazardous Substances
                      Control Act), the Migratory bird Treaty Act, the Endangered Species Act.
                      the Resource Conservation and Recovery Act (RCRA).

                                                           G-65                                                                                                             G-56

    						SPECIFIC COMMENTS

    				CHAPTER 1 - PURPOSE AND NEED FOR THIS REPORT

    p.  c. _.  1.*

    INTRODUCTION

    9 2 3		This paragraph discusses the recreational and aesthetic values

    		of the Coastal Plain and implies that it is more "unique" than

    		any other coastal area of the Arctic.  The Coastal Plain does

    		provide varied wildlife viewing scientific and recreational

    		opportunities; but so do many other arctic areas.  Care should

    		be taken not to be so subjective as to classify the aesthetic

    		value of this area "unique" without qualifying that every

    		region along the coast is "unique" in its own right.  The

    		Coastal Plain figures prominently both as a possible source of

    		major oil and gas supplies and as a means to assuage man's

    		yearnings for the aesthetics of solitude, scenery and

    		wildlife.  (See comments on p. 45, c. 2,  _ 5-6.)

    		This name paragraph mistakenly implies that the 1002 area is

    		valued for it's threatened arctic peregrine falcon habitat.  In

    		fact it provides only minimal, and very poor habitat for the

    		peregrine falcon.

    10 1 1 2-3	The information available on both the resouces potential of the

    		region and the wildlife resources is entensive.  The nature of

    		the decision to be made obviously demand s careful and

    *NOTE:  Comments are listed by page, column, paragraph, and line.

    							S-1

    p.  c. _.  1.

    		dispassionate assessment of the knowledge gained from six years

    		of concentrated study.  It is our opinion that even though the

    		caribou sections need reworking (see our general comments) this

    		is a n adequate document on which to judge the issue of leasing.

    BASELINE STUDY OF FISH AND WILDLIFE RESOURCES

    11 1  3	It would be more accurate to describe the baseline work

    		performed by the Fish and Wildlife Service (FWS) as inventories

    		rather than studies.  These inventories provided an extensive

    		basis for what we believe to be a thorough, and for the most

    		part, a reasonable description of the coastal plain ecosystem

    		and assessment of scenarios of development.  To do the impact

    		analyses, FWS has necessarily drawn from many scientific and

    		technological studies carried out elsewhere in the arctic, as

    		recongnized by the bibliography.  In a few areas, however,

    		conclusions are based on one or two studies that have not been

    		critically reviewed when other studies, some peer-reviewed and

    		published, were available.  This is of particular concern with

    		respect to the caribou impact analysis.  Very significant

    		decisions regarding the leasing of ANWr will be based on this

    		report.  It is imperative that FWS critically examine all the

    		relevant information on which their impact analyses are based,

    		and where appropriate, modify their predictions of

    		environmental consequences.

    		See both our general and specific comments on caribou.  We

    		strongly believe that there is sufficient justification, based

    		on the less-than-scientific nature of some assumptions and the

    		less than critical examination of some of the research cited,

    		for FWS to rewrite the sections dealing with caribou.

    STANDARD FOR ENVIRONMENTAL PROTECTION

    12  2		We fully  support the concepts of avoiding and minimizing

    		environmental impacts to the greates extent possible which are

    							S-2

              C. 1.                                                                                                      C.

                              embodied by the FWS Mitigation Policy.      The Mitigation Policy                                          of comprehensive regulatory programs governing oil and gas
                              as a whole, however,       is not an effective. standard         for                                       operations,

                              protection of wildlife in the arctic.       The foundation of the
                              FWS Mitigation Policy is the management of habitat 83 a means                                              To assess adequately the potential: environmental effects of
                              of protecting and managing the productivity          of fish and                                           leasing in the 1002 area (and necessary mitigation measures),
                              wildlife   populations.     it   is   inappropria  te to    use    a                                       it is essential that the report review,            in detail,     the
                              habitat-based system to manage a population          when habitat                                          regulatory framework and related permitting programs that
                              availability has not been shown to be a mechanism    by which that                                         regulate oil and gas activities. A legal analysis should be
                              population    in   regulated.    The    policy    is    particularly                                       completed to determine which, if any, environmental concerns
                              inappropriate in the arctic where habitat has not    been shown to                                         are not addressed by existing laws and regulations.              This
                              be a limiting factor for most species, and this is particularly                                            analysis    should    be  incorporated    in   the   evaluation    of
                              true with respect to caribou.                                                                              environmental consequences. At a minimum, such a review should
                                                                                                                                         includes

                              The only biologically effective approach to assessing and
                              mitigating effects of development on wildlife is, first, to                                                1.    major permitting programs for each stage of petroleum
                              determine systematically how project activities and structures                                             development;
                              will alter popullation-limitinq factors for each species of
                              concern, and second, to apply mitigative measures that avoid or                                            2.    environmental protection measures built into those programs;
                              offset project effectli,,qu. those limiting factors.         If an
                              automatically applied habLtat-based approach happen to be                                                  3.    the authority of regulatory agencies to regulate oil and
                              effective   for a species,      this   is because one or more                                              gas   development to ensure environmental protectiont and
                              population-limiting factors happens to involve habitat, not
                              because there is anything uniquely important about the quantity                                            4.    the regulatory management schemes and experience of oil and
                              of real estate available, qu At.       (see our general comments                                           gas   activities in other wildlife refuges (e.g. Kenai National
                              for a more complete discussion.)                                                                           "Ildlife Refuge).

         12   2   1-          In addition to identifying the FNS Mitigation Policy as the                                                Although the     report states that the existing regulatory
         13   1   2           standard for impact analyses and mitigation recommendations,                                               mechanisms are incorporated In the evaluation of potential
                              thiIa section simply lis ts some of the major State and Federal                                            environmental consequences, the worst-case predictions imply
                              regulations that would apply to exploration, development and                                               the contrary, i.e.    a regulatory vacuum.     it is  essential for
                              production. The list should be much more extensive so that the                                             the reader and for the writers of the draft LEIS to appreciate
                              reader has a clear understanding of the degree to which                                                    how the regulatory framework works, especially        on the North
                              environmental protection is already guaranteed.        Our general                                         Slope of Alaska,      in order to understand the        environmental
                              comments on water quality discuss some of the incredible number                                            safeguards already    provided.   This would also. eliminate the
                                                                                                                                         need for many of the proposed mitigation recommendations that

                                                   S-3                                                                                                         S-4

                c.                                                                                                D.     C.

                              duplicate either standard engineering practice or that are                          N-kT-ER RESOURCES
                              included   an   standard  permit stipulations     under existing
                              regulatory programs.                                                                21     1  3   1      Since this draf   It report makes an issue of       limited water
                                                                                                                                       resources    a map indicating the location of, major water
                              [It Is worth noting that OCS Lease Sale Environmental Impact                                             sources, ;ncluding any depth or flow information should be made
                              Statements explicitly assume the safeguards of the existing                                              available and included in this section or an appendix.
                              regulatory framework in Impact projections. Thus the need for
                              any additional stipulations are more easily assessed and                            22     1  2   2      The word "must" should be changed to "may" as there are several
                              justified.)                                                                                              different methods which can be used to obtain water in ANWR
                                                                                                                                       without having to rely solely on marine waters.       The sentence
         ADDS                                                                                                                          should readt " ... the adjacent marine waters may be viewed as a
                                                                                                                                       water source."

         23@    bottom        It will be important in the Final LEIS to address the
                              conveyance of approximately 20,000 acres        to the Kaktovik                     22     1  3-4        Following is a now paragraph we suggest adding to the end of
                              Inupiat Corporation (RIC).     Subsequent ANNE   boundary changes                                        the section on Water Resources and before "Erosion and Mass
                              will have to be reflected on reference maps.    The importance of                                        Movement"I
                              the exchange to the RIC shareholders   and area residents should
                              also be addressed.                                                                                       Although naturally occurring sources of fresh water for
                                                                                                                                       exploration and developmental use are scarce in the 1002 area,
                                                                                                                                       this Is true throughout the North Slope.         Methods by which
                                   CRKPIM 11 - MISTING ENVI                                                                            water has been successfully extracted include:

         PHYSICAL GEOGRAPHY AND PROCESSES                                                                                              (1) Excavating deep pools in river and stream beds;
                                                                                                                                       (2) Excavating deep pools in lakes;
         15     2  3   1      An oil seep has also been identified at Brownlow Point.                                                  (3) Insulation of ponds to prevent freezing;
                                                                                                                                       (4) Deselination of sea water;
         17     1  1   6      Are there not data available from Deadhorse?                                                             (5) Erecting snow fences to trap snow which could be used with
                                                                                                                                           snow melters;
         19     1  2   4      typo: unusually                                                                                          (6) Converting gravel extraction pits to reservoirs.

         20     2  4          He concur that there are numerous sources of gravel in large                        23     1  3-6        This section on air quality is well written.          It would be
                              quantities.   The extensive gravel finds discovered during the                                           beneficial, however to clarify that all emission sources on the
                              two winters of geophysical exploration should also be discussed.                                         North Slope hold valid air permits from State and Federal
                                                                                                                                       agencies and are complying with emission limitations and
                                                                                                                                       ambient air quality standards.     In fact, emissions fall well

                                                   S-5                                                                                                      S-6

         2.    c. 1.                                                                                                          V,     c, 11,

                                below the I    imits set by EPA and ADEC.          Air quality on the                                                identical to unvegetated islands with respect to substrate
                                Arctic Coastal Plain in consistently good.                                                                           composition.

         BIOLOGICAL ENVIRONMENT                                                                                               25     2   2   21-22   As an extension of the previous comment we suggest changing the
                                                                                                                                                     begints,ing of the sentence tot        "Sails, when present. consist
         VEGETATION                                                                                                                                  of......

         23   .2    4   1-8                       g (arctic pennycress)     has been under review for                         26     1   6   5       Remove final      from "soils".
                                official designation as a threatened or endangered plant
                                species since Murray (1980) first listed it. As a consequence,                                26     2   4   21      Should "macro-invertebrates" be "micro-invertebrates"?
                                virtually every North Slope EIS produced since that time has
                                conscientiously accorded It a token paragraph, although the                                   27     1   1   5-7     The boundaries of the Sadlerochit Spring Special Area shown in
                                species has never been legally protected. There has been no                                                          Plate IA do not conform with the text description and appear to
                                ca a that we are aware of in which arctic pennycress has been                                                        exaggerate the size of the Special Area.            Because exploration
                                suggested to be threatened by development. Having reviewed the                                                       activities are prohibited on a site-specific basis, the site
                                status of this. species for the past six years, FWS should be in                                                     boundaries should be clearly . portrayed for the reader.                  A
                                a position    to III make A decision an to whether the species                                                       detailed and accurate map of the Sadlerochit Spring Special
                                will or will not be legally protected by official designation                                                        Area, either USGS topographic or photo-based,                 should be
                                as    threatened     or    endangered,      along    with     appropriate                                            provided at ls63,360 or other appropriate scale.
                                Justification; and (2) provide a map showing its distribution
                                at proper scale and in sufficient detail to assist decisions                                  27     2   2           The list of International Treaties should be amended to include
                                regarding potential development.            What are the         "Thl  asgi                                          the recently initialed "Agreement Between the Government of
                                arctic      -stations" shown in Plate 1AT          Do these represent                                                Canada and the Government of the United States of America on
                                specific areas where the species in known to occur? What legal                                                       the Conservation of the Porcupine Caribou Herd".
                                statup Is proposed for these "stations"? Will development be
                                prevented there even if the species in question Is not legally                                CARIB
                                protected? Please arovide clear and mWlIcIt wMIanations on
                                these statters.                                                                               27     2   5           The information on herd size needs to be put in               perspective.
                                                                                                                                                     we suggest including the following: The          Porcupine   Caribou Herd
         25    2    2   14-18   this sentence is misleading. The way in which the sentence in                                                        (PCH) is currentlythe sixth largest herd          In North  America.     It
                                constructed, implies that unvegetated floodplain islands differ                                                      is surpassed in sixe by five other               herds which are also
                                from vegetated islands in that the latter have developed                                                             increasing in sizes       The Weatern Arctic Herd (Alaska               now
                                soils.    This is sometimes true,     but vegetated Islands in early                                                 about 220,000-240,000), the George River Herd (Canada                 about
                                successional stages often have no developed soils and are                                                            600,000 in 1984). the Kaminuriak Herd (Canada            about 320,000),
                                                                                                                                                     the Beverly     Herd   (Canada      about 285,000         1984) and the

                                                       8-7                                                                                                                  S-8

              C.                                                                                                     D.     C.

                              Bathurst Herd (Canada     about 385,000 in 1984).     (See Williams                    28     2  1   2-3     "Most caribou migrate to reach the calving grounds of the 1002
                              and Heard 1986, Heard and Calef 1986]                                                                        area from Canada... 11 misleadingly implies that the majority of
                                                                                                                                           the Porcupine herd migrates to the 1002 area expressly to reach
         28   1   1   1-4     There will always be some degree of uncertainty in estimating                                                calving grounds located there. The statement should be revised
                              the size of any population of wild animals.         Sufficient data                                          to read: "Most caribou calving within the 1002 area migrate
                              are available, however, to show that the difference between the                                              there from Canada ......

                              population estimate from the early 19709 (approx. 100,000) and
                              the current estimate (180,000) reflects population growth and                          28     2  2           Snow ablation is the key term here, and should not be confused
                              not simply improved (or different) estimation techniques.                                                    with "early" and "late" springs (which imply warmer and colder
                                                                                                                                           temperatures than average).     For ezample, during the winter of
         28   1   3           The Porcupine herd calves in many locations which vary from                                                  1971-1972   snowfall was heavy and in the spring of 1972 PCH
                              year to year within its International calving grounds. Areas                                                 calving took place inland in the foothill zone in spite of a
                              in the general vicinity of the Jago River are Indeed used for                                                very warm, early spring. The deep snow cover found across the
                              calving by a       Porcupine caribou in most     years, along wi                                             lowlands initially restricted the caribou to inland areas.
                              ImM other areas Inside and outside the 1002 pro& boundaries.        ,                                        Even after the snow disappeared, the caribou remained inland
                              However, no comparative Information is given for other calving                                               and did not move to the Coastal Plain to calve.         In contrast,
                                                                                                                                           snowfall was quite light during the winter of 1972-1973, and in
                              areas throughout the remainder of the large international
                              calving range.     Reporting only calving concentrations within                                              the spring of 1973 calving was widely dispersed throughout both
                              the 1002 boundaries while not showing the other areas used for                                               the inland uplands and northern coastal lowlands in      .spite of a
                              calving In Alaska and Canada, and calling it "the core calving                                               much cooler, later spring. The shallow snowcover found in the
                              area", creates a false Impression that this particular location                                              lowlands did not initially restrict the caribou, and was soon
                              is consistently used by the vast majority of parturient cows In                                              gone in spite of the much cooler weather.
                              the herd and is somehow much more important than other calving
                              areas.   The term "core calving araa!' should not be used to                           28     2  3           It is significant that the estimates of cows calving in various
                              describe what is simply one     of many annually varying calving                                             areas are extrapolations from       .relocation of radio-collared
                              concentration areas.      The discussion should be revised                                                   cows.   Given the findings of Cameron at &1. (1985) that at
                              e"anided to provide a more accurate verspecti .          [See "core                                          least 30%, and preferably 50%, coverage is needed during
                              calving area" discussion in General Comments.]                                                               line-transect counts of animals to reduce sampling errors to
                                                                                                                                           reasonable levels, extrapolations based on only a few dozen
                              It Is not apparent that concentrated calving areas were in fact                                              radio-tagged cows may be highly inaccurate.       It is an untested
                              defined objectively as having a minimum of 50 caribou/sq. mi.                                                assumption    that   the    radio-collared    animals   are    evenly
                              Actual supporting data must. be made available if the stated                                                 distributed throughout the PCH each year, they were not evenly
                              definition (50 caribou/sq. mi. in 5 or more of 14 years) Is to                                               distributed at the time of the original tagging.                These
                              be applied.                                                                                                  extrapolations should be supported by other survey data, or

                                                   S-9                                                                                                          S-10

              C. 1.                                                                                                R.    c. 1.

                              more information on ranges and variances should be provided.                                               after only one or two days.      They then migrate inland to an
                              The use at such gross extrapolations is potentially misleading.                                            area, which is often considerably more insect-infested.           if
                                                                                                                                         remnant groups are left, or migrating elements of the herd
         Z8   2   4           The comment about disturbance of      cow-calf pairs within the                                            reverse direction for some reason, these groups then often do
                              first 24 hours of the calves' lives is more appropriate     Ito theI                                       use coastal insect-relief habitat. (D.G. Roseneav, 1987, pers.
                              Environmental Consequences section.                                                                        cosm.

         29   1   1-2         These two paragraphs are somewhat contradictory           in that                    29    1   4           It in very unlikely that access to insect-relief areas is.
                              paragraph   I    states   that   "post-calving . movements      show                                       "critical" to productivity. If it were, one questions whether
                              considerable annual variation", while paragraph 2 states that                                              many caribou would be present today.       it Is true that in most
                              "The calving/post-calving area Is an important identifiable                                                years the post-calving caribou leave       Section 1002 lands and,
                              habitat that has been used repeatedly...".                                                                 AM by mid-Ju2y. This migration has         occurred in -years when
                                                                                                                                         insects have been very abundant and in     years when insects have
         29   1   2           The calvLaglpost-calving area is important, and In relatively                                              been nearly absent.    in several years,   (e.g. 1972, 1973, 1974,
                              small compared to the hard's range, but it also includes more                                              1975 and 1979) the caribou have left relatively insect-free,
        -                     th- just the 1002 area and use within it has varied                                                        coastal areas for more heavily insect-infested zones in the
                              considerably over the years.         it should -he .-tstad that                                            British Mountains and northeastern Old Crow Flats. In at least
                              approximately 1/3 of the calving/post-calving area falls within                                            2 years (1976, 1982), post-calving aggregations -did not visit
                              the 1002 boundaries.     Without this clarification, the draft                                             the coast at all. but remained well inland.

                              report infers that the 1002 area alone is the "important,
                              identifiable habitat" referred to here.                                              29    1   5           The Gover   ate of Canada and the United States have recently
                                                                                                                                         initialed a joint agreement on the conservation of the PCH,
         29   .1  3           The importance of InSect-relief habitat is overemphasized.                                                 that will have direct implications on activities in ANWR. As a
                              Post-calving PCH animals have         formed  dense    aggregations                                        practical matter, this agreement will carry great political
                              regardless of the presence of Insects.   . It In true that caribou                                         weight On PCH Issues.    It is Important that the Department of
                              respond to insects and seek relief from insects (and'get it In                                             the   Interior   fully , evaluate   the    legal  obligations    and
                              a variety of habitat types), but data on movements of                                                      authorities established by this Agreement in the Final LEIS.
                              post-calving caribou to and from the coast do        I  not always                                         The implementation of the conservation section of the Agreement
                              correlate with the presence of insects.          it is true that                                           should be fully explained in light of both current U.S. laws
                              movement to the coast Is often rapid.       If caribou are forced                                          and   regulations    protecting    the   species,    and    specific
                              there by insects, however, and the purpose of their going Is                                               stipulations proposed in the draft LEIS for the      1002 area.    In
                              solely to seek relief from harassment by insects,               they                                       particular the authority and function of the newly created
                              apparently have an ability to store up enough "relief" within                                              advisory board needs to be described in detail.        Additionally,
                              just a few days to last them for several weeks.         They often                                         Chapter VI, Environmental Consequences, should be revised to
                              leave potential insect-relief areas along the coastal plain                                                reflect the protection afforded the caribou by the Agreement.

                                                   S-11                                                                                                       S-12

    29   1  6	This paragraph presents conflicting harvest statistics without

    		explanation, it is suggested that the total annual harvest is

    		200-1000 at Arctic village, 25-75 at Kaktovik, plus an average

    		of 1700 from Canada.  Taking the larger figures, one obtains a

    		total of 2775.  However, LeBlond (1978) is cited as estimating

    		an annual harvest of 3,000-5,000.  These figures should be

    		reconciled.  It should also be noted that Kaktovik residents

    		believe harvest and herd size will not be affected by leaisng

    		or its associated exploration and prodcution, provided existing

    		environmental regulations and practices remain in effect.

    29 2 1 1-2	More recent estimates put the Central Arctic Herd (CAH) at

    		approximately 17,000 in 1985 (Carruthers and jakimchuk 1968).

    2_ 2 1 3-7	The range of the _ _ _ has included areas south of the

    		continental divide in the past (e.g., elements of this herd

    		wintered south of the divide in winters 1971-1972 and

    		1972-1973).  During the winter of 1973-1974, these animals

    		began wintering north of the divide (some records suggest they

    		have done this in the past).  [See Child 1973, Roseneau and

    		Stern 1974, Roseneau et al. 1974.]

    29 2 3 3-4	Very few CAH animals were seen calving in the 1002 area during

    		the early and mid-1970s (often none).  This appears to be a

    		relatively recent event and is probably associated with

    		increasing herd size.  (See Roseneau and Stern 1974, Roseneau

    		et al. 1974, Roseneau et al. 1975, Roseneau and Curatolo 1976)

    29 2 3 6-9	At the oil industry/government caribou seminar held in

    		Girdwood, Alaska, in October 1986, it was concluded that there

    		was no evidence that calving had ever been a common occurrence

    		in the Prudhoe Bay region, even prior to oil field

    		development.  In fact, some CAH caribou calve in the

    		Kuparuk/Milne Point areas where oil fields have been

    						S-13

    p. c. _. 1.

    		developed.  The inference that caribou cannot calve near

    		petroleum development should be removed.

    29 2 4	Summering by CAH animals east of the Canning River also appears

    		to be on the increase.  Post-calving CAH animals made

    		incursions into portions of this area in the early and

    		mid-1970s, but their stay was relatively brief.  Wintering by

    		CAH animals also began increasing east of the Canning River

    		after the mid-1970s.

    29 2 5 1-3	This sentence repeats information given on p. 29, col. 1, par.

    		6, lines 3-6.  Consolidate.

    29 2 5 3-6	The text should note that the majority of PCH caribou taken for

    		subsistence by Kaktovik residents are obtained inland from the

    		coastal plain in the spring, and not within the 1002 area.

    		Summer harvest along the coast is very minor.

    MOOSE

    30  2  3	It is important to emphasize that most of the moose harvest

    		takes place outside the 1002 area and should, therefore, remain

    		unaffected.

    WOLVES

    31  2  1	It is important to emphasize that most of the wolf harvest

    		takes place outside the 1002 area and should, therefore remain

    		unaffected.

    ARTIC FOXES

    31 2 2 2	Arctic fox dens are typically in dry tundra communities,

    		especially dry microsites such as mounds, low hills, and

    		south-facing ridges (see Chesemora 1967, 1969 and review by

    		Underwood and Mosher 1982).

    						S-14

          R,    Q, 1.                                                                                                  R.    c. 1.

          POLAR BEAR                                                                                                   BIRDS

          33    1    3         Information is given on the size of the Beaufort Sea population                         34    1   5  5-6     Glaucous gulls have been reported to overwinter near the
                               (2,000 individuals), but no perspective is. offered as to the                                                village of Kaktovik in recent years (H. Audi, Audi Air Inc.,
                               number of bears that' might comprise the segment of the                                                      Kaktovik, 1986).    This species should be added to the list of
                               population normally occurring in the ANWR region of the                                                      birds that occasionally overwinter. There is speculation that
                               Beaufort Sea.                                                                                                the availability of food at dumps and near marine mammal
                                                                                                                                            carcasses have enabled nor* gulls to overwinter in northern
          33    1    4  8      The phrase "...where 1-2 dons were found in 4 of the 5                                                       Alaska in recent years.
                               years..." is ambiguous.       No. suggest revising as follows:
                               "...where 1-2 dons were found in each of 4 years during the                             34    2   1  2       Bartels (1973) is an   obscure and outdated reference; other more
                               5-year period between winter 1981-82, when the INS..." etc.                                                  relevant work (e.g.@ Divoky      1978b, Bartels and Doyle 1984,
                                                                                                                                            Bartels and Zollhoefor 1903,     Johnson at &1. 1975) should also
          33    1    4  13-14  "At least IS dons were located in the 1002 area, 1951-85 (pl.                                                be cited  an documentation for   this statement.
                               IM." Plate 11 shown only 12 locations actually within the
                               1002 area, plus the 5 locations on the sea ice@          Ste suggest                    34    2   2  8-9     "Smaller  -numbers are present   until freezeup in late September
          A                    revising this sentence tot     "At least 15 dons were      identified                                        or early   October."   to this   meant to imply that large numbers
                               within or near the 1002 area, 1952-85 (pl. ll)."                                                             of birds  use the lagoons after freeseup in late September-early
                                                                                                                                            October?

          33    1    4  14-15  Revise sentence tot     "Another five dons have been located on
                               sea ice near the 1002 area."                                                            .34   2   3          Productivity in lagoons generally Is not            higher than in
                                                                                                                                            adjacent offshore areas.      Almost all primary     production (and
          33    1    5  1-2    On Plat* 1A, boundaries of the confirmed coastal donning areas                                               consequently secondary production) is derived from offshore
                               at the Staines and Canning rivers . and at Marsh and Carter                                                  marine waters (Campbell 1981, Scholl at al. 1983, Schell
                               creeks seen to encompass inappropriately large areas relative                                                1984).    The lagoon systems are Important       Iconcentration areas
                               to the identified don locations.       It would help to explain in                                           for feeding waterbirds because prey tends to be more available
                               the text that the boundaries have been drawn, to include                                                     in these shallow waters and because the birds can find
                               associated areas of bluff habitat similar to that In which the                                               protection from wind, wavos and Ice behind the spits and
                              ,dens were found (assuming that this is the case).                                                            barrier islands.

          33    2    6  1-4    "Large numbers of polar bears may occur...". The use of "may"                           5     S. GEESE AND DUCK
                               introduce* ambiguity here.     it would be clearer to say "Large
                               numbers of polar bears have concentrated seasonally in some                             35    1   3   4      Although the majority of these birds      are from .Banks Island, it
                               rears along the coast..... If this Is the case.                                                              should be remembered that several tons of thousands and several
                                                                                                                                            thousands   of snow geese also come from two other colonies in

                                                    S-15                                                                                                          S-16

               C.                                                                                                          c.
                              Canada--Anderson River delta (10    4   birds) and Kendall Island                                            1986). no documentation is        presented here for this very
                              (103 )--and several hundred come from the one colony in                                                      important piece of information.
                              Alaska--gagavanirktok River delta (10   2 birds).
                                                                                                                     35    2    2  3-4     This Information Is poorly documented. See Martin and Moltoret
         35    1   3   6-7    This statement is very intriguing.        Have these few hundred                                             (1981), Richardson and Johnson (1981) and Johnson et al. (1975)
                              birds that. appear to occupy this small pocket of habitat been                                               for details of bird  , migration schedules along the Beaufort Sea
                              examined closely to see If they are neck-collared, I.e., are                                                 coast.
                              from the Sagavanirktok River Delta population, rather than the
                              Banks Island population?                                                               @35   2    3          This information in poorly documented.      See Spindler (1978&,b,
                                                                                                                                           1984), Brakney ot al. (1985009-361), Johnson (1984a), Johnson
         35    1   3   11     The maximum estimate of 325,000+ snow geese present in ANWR was                                              and Richardson (1981, 1982), Johnson at al. (1975).
                              not in 1976, but in 1978 (see Oates at al. 1985: Table 3, for a
                              review of data from 1973 through 1984).                                                35    2    4          This is very important information about spring and summer
                                                                                                                                           harvest of waterfowl, apparently by Kaktovik residents.        It is
         35    1   3   23-24  The snow geese feed extensively on the roots of several: species                                             important to underscore this harvest, especially because it may
       -                      of Briopjwr       (cotton grass).     During fall, these plants                                              affect populations of brant and greater white-fronted geese,
                              transfer energy (in the form of carbohydrates) from the leaves                                               which are already severely depressed in     .the Pacific Flyway as a
                              and stems to the underground roots (whore energy reserves are                                                result of overhunting (see review paper by Raveling 1984).
                              stated over the winter in order to support initial above ground
                              growth the following spring). These high energy roots dominate                         SEABIRDS AND SHOREBIRDS
                              the diet of fall staging snow geese in the 1002 area.
                                                                                                                     35    2    5  11-12   Sabine's guile typically nest in thermokarat marsh complexes at
         35    1   4   6-7    Evidence from Canadian studies (Koski 1977&,b; T. Barry 2986,                                                other locations along the Alaskan Beaufort See coast.         It is
                              per$. com.) indicate that these birds indeed do migrate east                                                 very surprising to road that the Canning River delta is the
                              to the Mackenzie Delta and then south through the Canadian                                                   only-location in the 1002 area where they nest.
                              prairie provinces and Into the western U.S. (Pacific and
                              Central Flyways).                                                                      35    2    5  13      Black quillemoto nest in abandoned buildings, In piles of
                                                                                                                                           drums, among driftwood and other debris on the barrier islands
                              Brant, however, fly west along the Alaskan Beaufort coast, then                                              and spite along the Beaufort Sea coast.       The wording here --
                              south through the Chukchi and Bering seas before arriving at                                                 "Black quillemots breed only on the coastal beaches.". -_ is
                              Isembek Lagoon .(Alaska Peninsula) to feed/stage for the fall                                                somewhat misleading.
                              flight to California and the west coast of Mexico.
                                                                                                                     36    1    1  1       Jaegers, especially parasitic jaegers, chase down adults as
         35    1   4   21     This point is not documented.         Although there are several                                             well as the young of small birds.
                              reliable sources (Martin and Noitaret 1981, Derksen pers. comm.

                                                   6-17                                                                                                         S-18

    p.   c.  _.  1.

    RAPTORS

    36   1   3	Gyrfalcons often begin frequenting meeting cliffs in March

    		(e.g., courtship at the cliffs, etc.), and it is recommended

    		that "...the first week of April..." be changed to the "first

    		week of March.  Rough-legged hawks are also closely tied to

    		microtine populations and often very considerably in lcoal

    		abundance.

    36 1 3 3	The reference to the peregrine falcon infers that this

    		threatened species is commonly present across the entire

    		coastal plain.  In fact, as it is pointed out on p. 38 of this

    		draft report, only a few peregrines are found in the 1002 area

    		and none is known to nest there.  It is especially important

    		with a species that is legally protected as "threatened", that

    		the report not be misleading.

    36 2 1 5-7	During the fall, do the ptarmigan move south, back into the Brooks

    		Range, from whence they came the previous spring?  In other

    		words, are the movements of ptarmigan cyclic--north onto the

    		coastal plain in spring and summer and south into the mountains

    		during fall and winter?  This would seem to be a reasonable

    		adaptation, but since no documentation is given its hard to

    		tell if this is speculation or fact.

    FISH

    36 2 4 1	The word "extreme is not appropriate here.  It use implies

    		something dramatic such as 'no mouth'.  The term "extreme"

    		would more accurately describe fish that live at great depth,

    		in very hot water, air-breathers, live bearers, and those that

    		'fly'.

    36 2 4 5-7	It is misleading to stat that '...populations are easily

    		affected by environmental change...'  Arctic anadromous fishes

    						S-19

    p.   c.  _.  1.

    		have adapted to the particular constraints imposed on them

    		(e.g. as a long-lived species with capability of repeat

    		spawning, they can withstand the loss of a year-class).  [See

    		discussions by Craig (1987) and Craig and McCart (1976).]

    36  2  6	Though some arctic cod may spawn in nearshore waters, they are

    		also thought to spawn and overwinter over vast oceanic regions;

    		thus, in a population sense the nearshore zone is not an

    		"important" spawning and overwintering area for this species.

    		It is incorrect to say that "The nearshore waters are important

    		spawning and overwintering areas".  Those species of fish that

    		are of greatest concern to man for commrcial, subsistence, or

    		sports fish reasons neither spawn nor overwinter in nearshore

    		waters.

    37  1 Table	This table implies (from the heading) that the Sadlerochit

    		River supports a population of pink salmon.  However only a

    		single pink has ever been caught in this drainage (Craig and

    		Haldorson 1985,  Smith and Glesne 1982).

    SOCIOECONOMIC ENVIRONMENT

    39  1  2	Some Porcupine caribou are regualarly taken by residents of

    		Aklavik (where harvests have been on occasion, large),  Arctic

    		Red River and Ft.  Macpherson in the Northwest Territories,

    		Canada.

    40  1  3	The caribou harvest figures given here differ from those given

    		on p. 29, c. 1, _ 6.

    42 2  2	It should be noted that although the NSB Coastal Management

    		Plan has been approved by the State, it has to be approved by

    		the Federal Government before it is effective.  To date, it has

    		nto been approved.

    								S-20

         R.     c. q,                                                                                                        C. 1.

         43     1   2          Subsurface ownership is not     clearly explained. Information in                       46    1    4          It is an overstatement to say that the aesthetic value of the
                               this paragraph appears to conflict with information regarding                                                 1002 area was temporarily reduced as a result of seismic
                               subsurface rights discussed in the section titled Land Status.                                                exploration. Two surveys (1983/84 and 1984/85) were conducted
                                                                                                                                             in winter during little or no daylight with insignificant
         45     2   4          To provide a perspective on the relatively limited recreational                                               environmental effects.
                               usage of ANKR, It would be appropriate to compare these figures
                               with other areas of the State.
                                                                                                                                          CHAPTER III - ASSESSMENT Of OIL AND GAS POTENTI
         45     2   5-6        It in good that this section discusses aesthetics as a separate                                                AND PRTROLEUM GKOLM 01! THE COASTAL PLAIN
         46     1   1-4        issue    Aesthetics      the basis for much of the opposition to
                                    ng  in the 200 i:r
                               leasi               2    ea. It is important for this reason to                         49-73                 Standard endorses the resource estimates as within a reasonable
                               separate   aesthetic     feelings   from   biological    issues    and                                        range, given the database available.       As an addition, it might
                               conclusions.                                                                                                  be helpful to include a detailed explanation of the resource
                                                                                                                                             calucation for the beat documented prospect to illustrate the
                               it is also worth mentioning that without Coastal Plain oil, the                                               approach to a single building block in the overall resource
                               aesthetic experience of wilderness that is perceived to be the                                                estimate.
                               alternate goal to development will be available only to an
                                                                                                                       PRESTO NO
                               elite few. It is also reasonable to remember that the tens of

                               thousands of Americans and other visitors who have enjoyed a
                               once-in-a-lifetime trip to the North Slope in the past decade                           70    2    3          The authors are to be complemented in explaining this aspect of
                               have done so because of the development of Prudhoe Bay.                                                       "risk". Indeed additional explanation of risk and the marginal
                               Prudhoe Bay has not destroyed their arctic experience, it has                                                 probability utilized in the Alaskan and National contezts,would
                               made it possible, unique, and memorable. k small point, but                                                   further enhance the reader's understanding of why the Coastal
                               one worth recording.                                                                                          Plain ranks first in hydrocarbon potential of unexplored areas
                                                                                                                                             in the U.S.

         46     1   1          This section regarding aesthetics states that, "With the
                               exception of the two abandoned DER Line sites on the coast, the
                               entire 1002 area could meet the criteria." This statement                                             CHAPTER IV - DEVELOPMENT AND TRANSPOR-TATION INTRASTRUCTURR
                               ignores the use of the area by Kaktovik residents.
                                                                                                                       EXPLORATORY DRILLIN

         46     1   2          It Is not clear that the 1002 area is the most biologically
                               productive part of ANWR.      The basis for such a statement must                       75    1    3  9-11    We fully support the caution provided here that until there
                               be fully ex2lained and documented.                                                                            have been exploratory and confirmation wells drilled, all
                                                                                                                                             resource estimates must be considered uncertain.           Too often
                                                                                                                                             people want to attribute greater capability to geophysical

                                                     S-21                                                                                                          S-22

                c.                                                                                                         C. 1.

                                technology than it warrants.     It cannot be overemphasized that                                          kept within reason. The only way to do this with deep wells is
                                witho,ut drilling wells, the true oil and gas potential of the                                             to allow year-round drilling.
                                1002 area will never be known.
                                                                                                                     76    1   2           This paragraph should be rewritten to reflect the variety of
           75    2   1   5-9    It is incorrect to state that     sources of gravel have not been                                          options for mobilizing construction equipment and drilling rigs
                                identified. The drilling that was done during the two winters                                              to exploration locations within ANWR.        The assumption that
                                of seismic surveys indicated that virtually the entire region                                              exploration rigs would typically be transported to the drill
                                is underlain with gravel. All information from those surveys,                                              site by Hercules 130 aircraft is not necessarily valid.
                                including the sample.cores, is available to the government for                                             Overland access could be utilized formost sites.
                                examination.
                                                                                                                                           Heavy construction equipment is used to prepare the wellsite
                                Additionally, this paragraph states that water sources are not                                             for the drilling operation and to prepare an airstrip for
                                readily available.     Although this is correct, it should be                                              aircraft    me.king crew   changes,   material    supply,   and if
                                clarified that this is common throughout most of the Arctic and                                            necessary, transport of a drilling rig and related equipment.
                                has been successfully dealt with many times.              over 250                                         Construction equipment may be        transported to exploration
                                exploration wells have been drilled in the North Slope arctic                                              locations by low@ground-prex sure vehicles, or by trucks using
                                                                                                                                           ice roads.     once the equipment and crews arrive on site,
                                desert.
                                                                                                                                           construction   begins for the drilling pad, airstrip and ice
           75    2   4          The exploration experience in NPR-A is worthwhile reviewing in                                             roads to water sources and pad construction material.            The
                                this context.    A variety of plays were tested in the 1970s                                               dr.illing pad can be constructed of a material excavated from
                                program with a wide range of target depths.             It Is not                                          the r4serve and flare pit, ice, grave I - foam-timbe r, or other
                                necessarily true that a @12,000 foot exploratory well can he                                               possible combinations with gravel being the preferred material
                                drilled in a single season.        Further. the presumption that                                           due to thermal stability.
                                wells which cannot be drilled In a single winter season will.
                                require   a multi-season effort should be evaluated on a                              76   2               Although naturally occurring sources of fresh water for
                                case_by-case basis. If significant adverse impacts to wildlife                                             ezploration and developmental use are scarce in the 1002 area,
                                can be avoided, then exploratory operations should be allowed                                              this in true    throughout the North Slope.      Methods by which
                                to continue through the summer.                                                                            water has been  successfully extracted include:

                                The costs of suspending and later reentering a well are very                                               (1)  Excavating deep pools in river and stream beds;
                                high for operational and logistical reasons.          The recently                                         (2)  Excavating deep pools in lakesy
                                drilled KIC well, for example, well cost approximately $50                                                 (3)  Insulation of ponds to prevent freezing;
                                million.    If exploratory wells in ANWR continue to require 2                                             (4)  Desalination of sea water;
                                7
                                    one and remain in the $50 million dollar range, the number                                             (5)  Erecting snow fences to trap snow which could be used with
                                    ".'sploratory wells Industry can afford will be limited.       If                                           snow melters;
                                the full potential of  the area is to be realized, costs must be                                                                 S-24:
                                                     S-23

                  c,  1,                                                                                                V.    c.  1.

                                 (6) Converting gravel extraction pits to reservoirs.                                                         "cuttings" from the well, and (2) to contain formation fluids
                                                                                                                                              originating from a "kick".

           76     2   3          The exploration pad described here Is somewhat outdated.
                                                                                                                        76    1   6           The size of the reserve pit described In the draft document for
           76     1   4          There are not separate camps          at exploration     sites    for                                        a single exploration well in much larger than what has been
                                 construction and drilling operations.        The paragraph should                                            found to be required for multiple development wells drilled in
                                 readi                                                                                                        Prudhoe Bay. This paragraph should be rewritten as follows:

                                 .... The construction/drilling camp contains sleeping and eating                                             Reserve pits for a single exploration well are built to contain
                                 accommodations' for approximately 75 people,           communication                                         approximately 5 bble. of fluid per foot of hole drilled.             A
                                 equipment, power generator units, storage space, shops. and                                                  12,000 ft. well would typically require a 60,000 bbl. reserve
                                 offices.                                                                                                     pit having dimensions approximately equal to 150 ft. x '150 ft.
                                                                                                                                              z 15 ft. deep. A 200-foot-equare flare pit is excavated at the
                                 The   last   sentence   in   the paragraph pertaining to          the                                        corner most distant from the drilling rig, in case it is needed
                                 construction camp should be deleted an it is not applicable.                                                 for gas    flaring during testing.         The   ice-rich    material
                                                                                                                                              excavated from the reserve and flare pits may be used to level
           76     1   4  a       An important aspect of the construction/exploratory drill camps                                              the drill pad or stockpiled for later use in pit reclamation
                                 has been omitted from this section.          Nhen discussing the                                             following well abandonment.
                                 physical equipment, no mention in made of built-in containment
                                 devices, (collection and drip pans) and Impermeable protectors                         76   1    Bottom      This paragraph should be added between the paragraphs at the
                                 (such as impermeable pit liners).       These are a planned and                                              bottom of column 1 and top of column 2.
                                 constructed    part    of   all    exploration    and    development
                                 facilities.   Containment devices are placed under the vast                                                  Following site preparation of the exploration location a
                                 majority of   the equipment, work areas and structures, where                                                drilling rig and related equipment Is mobilized and rigged-up.
                                 there is any   potential for leakage and/or spillage from fuel                                               Rigs can be moved to ANWR locations several different ways.
                                 and chemical storage tanks, piping, skid facilities etc.                                                     The preferred method Is to transport the rig and related
                                                                                                                                              equipment using Hercules C-130 cargo planes.         A typical rig
           76     1   -5 1       The reserve pit designs may or may not (and frequently       do not)                                         move would require, on average, 150 C-130 flights.            Another
                                 include an excavated pit. The pit for an exploration site may                                                method would be to barge a rig and related equipment to a
                                 be a temporary surface pit.                                                                                  coastal location during the summer months and move it to the
                                                                                                                                              exploration location in the winter by trucks using ice roads.
           76     1   S          The purposes of the reserve pit are numbered incorrectly, and                                                A third, but more expensive alternative, would be to haul the
                                 item (1) is misleading.      It should instead read as follows:                                              rig and related equipment over tundra during the winter using
                                 (1) to contain the used drilling muds, completion fluids and                                                 low-ground-pressure vehicles towing sleds.

                                                      S_2S                                                                                                         S-26

                 C.                                                                                                           C.

                                                                                                                                                information. We suggest including road width and       thickness to
          76     2   1  11-17   This. paragraph mentions    the  lack of water    resources in ANWR
                                which is over  stated and  has already been discussed in previous                                               give the reader an idea of the road's dimensions.
                                sections.   The water requirements to drill an exploration well
                                as  stated, here are misleading.          The water      requirements                                           k 6-inch thick tundra Ice airst       .rip is acceptable for use
                                referenced in this paragraph for drilling an exploratory well                                                   according to Pool Arctic Alaska personnel.,. Pool Arctic has had
                                can be deleted and         replacedI  an   followas     ("The    water                                          significant ezperience in airlifting arctic rigs in Alaska.
                                requirements     for    drilling     an   exploratory     well     are
                                approzignately:")                                                                        77   1.  2             The initial portion of this paragraph should be rewritten to
                                                                                                                                                clarify the operation as follows:,

                                   (1) 414,000    gale/mile of ice road construction       and  i4,200
                                gals/mile for daily maintenance                                                                                 Drilling operations begin by installing the rig       over the .  well
                                                                                                                                                location. Differential settlement     due to thawing of the pad or
                                   (2) i,500,000 gals/Hercules airstrip construction and 2,100                                                  surrounding, permafroet from rig      operations is minimized by
                                gals for daily maintenance (Note: The volume figure required,                                                   laying timber under the    Irig so  . that cool air  .may circulate
                                for construction could be reduced if     the air strip was   built  on                                          keeping the foundation as cold a        a possible   ,  Actual well
                                                                                                                                                operations begin by sugaring a hole for the conductor casing 50
                                a frozen lake.)
                                                                                                                                                to 100 ft. below ground level. 6nductor casing is run and
                                  (3) 25.000 gals/day rig and domestic usage.                                                                   cemented in place and diverter equipment install      .ad. --,:ne wall
                                                                                                                                                in spudded and the hole is drilled to a competent. geological
                                Water for the above requirements could be obtained from one         of                                          formation, usually to a depth of about 2,000 ft...
                                the following sources at a combination of         the sources.     See
                                possibilities listed previously under page 76,     column 2.                             77    1   S   7        The term "arctic packed" will not be understood            by people
                                                                                                                                                unfamiliar with arctic drilling terminology so it          should be
          .76    2   2-4        These three paragraphs (Three possible scenarios despite water                                                  replaced.as follows$
                                shortages ares      items 1-3) can be eliminated because the
                                Information has already been presented in previous paragraphs.                                                  .... Also the well is freeze protected with a low freeze point
                                                                                                                                                fluid and suspended...

          76     2   5          This paragraph should read:
          77     2   1               One mile of ice road measuring 30 ft. wide and 6 inches                              77   1   5    11      The word "nonfreezing". should be replaced with "low freeze
                                thick generally requires about 4.14,000 gals.* of, water ... except                                             point" to read as follows:
                                with a minimum thickness of 6 inches...
                                                                                                                                                .... the low freeze point  fluid in the upper   part of....

                                A change from 1. 5    acre-feet to the 414,000 gals. figure is
                                required    to   stay    consistent   with    previously     discussed                    77   2    1           In addition to sharing     roads and airstrips, delineation wells
                                                                                                                                                can often share drilling pads and be         drilled directionally,
                                                       S-27                                                                                     further reducing surface impacts.
                                                                                                                                                                      S-28

                C,                                                                                                                  C.

          77    2    3          While    it may not be appropriate           to   include    a detailed                       79    1    1   3       "ell spacing should range from 40 (not 50) to 320 acres.
                                discussion of the existing regulatory framework here, inclusion
                                of such a section elsewhere In this report is essential. There                                79    1    3   9       Based on major production scenarios and enhanced recovery. the
                                is a tendency in SIB documents to ignore the existing                                                                useful life of production support facilities is likely to be 40
                                regulatory framework leaving the impression that oil and gas                                                         or 50 years rather than the 20-30 years of main production.
                                development proceeds In a regulatory vacuum once leasing takes
                                place.                                                                                        80    1    3-4         Regarding water options, enhancement of existing lakes and
                                                                                                                                                     river oxbows is     another alternative that has been used in
          PRODUCTI                                                                                                                                   Prudhoe Say Unit, (PBU) (e.g. ARCO's Colleen Lake). This              also
                                                                                                                                                     enhances fish and   wildlife habitat by providing year-round          deep
          78    1    4          Even a prediction of 10 years from        the time of leasing to the                                                 water sources.
                                time of production can be considered overly optimistic under
                                the   best    of   circumstances.      The    likelihood    of optimum                        80    2    3   3       Small development areas would likely import the necessary fuel
                                circumstances in small Indeed.            Given -, the lengthy permit                                                rather than construct an on-site crude-oil topping plant.            Arco
                                acquisition process for exploration and especially development,                                                      has one crude oil topping plant at Prudhoe Day, which supplies
                                and the possibility of          indiscriminate seasonal operating                                                    a portion of the fuels utilized In PBU, however, a large
          L                     restrictions, fifteen years could easily pass from the time of                                                       quantity of fuel including unleaded gasoline is shipped in
                                leasing to first production.                                                                                         tanker trucks to the slope.        In addition, the annual sealift
                                                                                                                                                     frequently brings large fuel barge shipments, a portion of.
          70    1    7  4       Replace "surface location" with "gravel pad" as single surface                                                       which to provided to the arctic villages.
                                location in drilling terminology relates to a single well
                                location. The sentence should reads                                                           80    2    4           This paragraph should be rewritten to include the area coverage
                                                                                                                                                     mentioned in the subsequent paragraph, and to delete references
                                .... Directional drilling allows multiple wells to be drilled                                                        to gathering facilities and flare stack which are located *a a
                                from a single gravel pad (fig. IV-1) ...                                                                             separate pad. It should reads

          78    2    2  4       Eliminate the reference to a 2,000 ft. kickoff point and                                                             .... The layout of a pad during drilling operations typically
                                replace It with "kickoff points as shallow as 500 ft" to                                                             includes the followings drilling camp, fuel and water storage,
                                reflect Prudhoe Bay operating experience. The paragraph should                                                       one or two drilling rigs, drilling supplies, reserve pit. flare
                                read as followas                                                                                                     pit and production facilities, covering 20-35 acres.

                                .... drilled  Iwith an angle of deviation between 0* and 45* from                             80    2    5           "A pad thickness of 5 feet requires 160,000-285,000 cubic yards
                                kickoff points as shallow as 500 ft....                                                                              of gravel." should be deleted as the pad dimensions are not
                                                                                                                                                     specified.    it I a difficult to quote volume requirements for
                                                                                                                                                     gravel as the number of wells, the wellhead spacing, reserve

                                                       6-29                                                                                                                S-30

           2.    C. 1,                                                                                                          C. 1.

                                 pit size and production facility area requirements should be                            83     1  rig IV-4    The five-foot clearance should be to the underside of the
                                 specified.    This paragraph should begin as follows:             "The                                        pipeline Insulation, not the underside of the support beam
                                 drilling camp is similar  .....                                                                               ("d/or pipe shoe).       Gravel roads would typically have side
                                                                                                                                               slopes of 2:1 (not 1.511) which would be more typical for work
           81    1    1  4.      The, reference to removing solids to a government -approved site                                              pads.
                                 such as an abandoned gravel pit or an offshore dump gives the
                                 impression that all solids must be removed which is incorrect.                          83     2  2   7       The placement of values based on predetermined maximum        quantity
                                 It should be rewritten to read as follows%                                                                    originated from negotiation stipulations rather than federal
                                                                                                                                               regulation (49 CPR 19S.260).
                                 .... disposal well.    Hazardous solids and solids containing
                                 hydrocarbons must be removed to a governm6nt-approved site,                             84     1  1   14-15   Information    on   the   extensive    amount   of   gravel present
                                 such an an abandoned gravel pit.                                                                              throughout the region has been made available to the government
                                                                                                                                               as a result of the two winters of seismic surveys that were
           81    1    1  6       Offshore dumping is not acceptable for hazardous solids and                                                   conducted for the purposes of evaluating the oil and gas
                                 -hydrocarbon  ,bearing solids. Reference to it should be deleted                                              resource potential.      An evaluation, of, this information will
                                 (line 6).     Additionally, the reference to a flare stack (line                                              show the statement here that 7the availability of adequate
                                 6) should be deleted since it does not belong in this paragraph.                                              gravel supplies on the IOWarea in uncertain" to be incorrect.

           82    1    3  12-14   Given the     certain and dramatic decline in, production from                          84     2  2.   10-16  We suggest changing the wording as follows3            ... contingency
                                 existing North Slope fields before any new production from the                                                plan that, as a minimum, addresses all Federal DeRartmert o
                                      area could possibly be made available, it is farfetched to                                                                 Environmental Protection h9ency and USCG and
                                 discuss the construction of a new trunkline from Prudhoe Bay to                                               State Department of Environmental Cons                         tions."
                                 Valdes.                                                                                                       Siting six specific items of contingency planning in a resource
                                                                                                                                               assessment that are not consistent with 'federal and state
           82    1    7          Differential settlement can be monitored.                                                                     requirements      leads  to   confusion    when    stipulations     are
                                                                                                                                               promulgated.     Further,    the operator     may   have    difficulty
           82    2    3  a       The concept of using existing gravel roads, pads        and fill is                                           complying with the specifics of the stipulation while adhering
                                 practiced     extensively  throughout    the    PBU   for    flowline                                         to existing laws and regulations in preparing and Implementing
                                 containment   Planning.   In the case of actual spills. it has                                                a   plan.     "Site   specific    clean-up   techniques"    could be
                                 proven very   useful.  Maps are maintained and updated every year                                             Interpreted  as ver restrictive and of limited value if applied
                                 showing the   local drainage around each pad and flowline in the                                              in the strictest form because of the variety of spills that are
                                 Western Operating Area (WOA) of the PBU as part of Standard's                                                 Possible given the Infinite variety of weather and ground
                                 contingency   plan.    Culverts and flowline 'casings        ran be                                           conditions.    Responses to what actually occurs could in fact be
                                 identified and blocked to contain spillage or control flow in                                                 hampered by present plans which specify too much detail.              If
                                 an area.                                                                                                      some specifics are desired, the paragraph could continue              as

                                                       9-31                                                                                                          S-32

                  C.                                                                                                     P.   C. 1.

                                fol Iowa, "...the regulations address:        agill prevention an                                              interest and can be accomplished without any deleterious
                                leak detection,      spill detection.     resRqnse and clean mg,                                               effects on the area's wildlife resources.
                                Notification Rrocedures to all          appropriate agencies,      and
                                restoration Including remedial actions,"                                                 ALTERNATIVg B    LIMITED LEASING OF THE 1002 ARE

           84     2 3    1-3    Leak    detection    systems    for   arctic    use   have     limited                   91   1-2              Alternative B In based on the speculative premise that a
                                capabilities.    We suggest adding available arctic engineered                                                 traditions I "core', calving area exists and is necessary for the
                                and des1=2 in line I between "include" and "automatic".                                                        maintenance of a healthy caribou herd.         As discussed in our
                                                                                                                                               general    comments,  this concept is not supported by the
           84     2 3    6      Aerial surveillance has limited application on the North Slope                                                 literature and, in fact, the data shown considerable annual
                                where ground access in available.       PBU uses ground access for                                             variability In the location of calving concentrations.              we
                                the flowlines throughout the field.          Security and operator                                             believe there in sufficient new, or not previously considered
                                surveillance occurs daily.                                                                                     information available to FKS to justify reevaluating the
                                                                                                                                               concept of a "core" calving area. in which case Alternative 0
           85     1 3-5         A marine pipeline east-went (offshore) to transport ANWR crude                                                 will also have to be reexamined.
           85     2             to TAPS Is not a feasible option. Although the technology of
                                offshore Arctic pipelines is advancing, their use will probably                          nTERNATIVE C - FURTHER W[PLORATION
                                be confined to transporting offshore crude to shore.               The
                                report should only consider onshore pipelines.                                           92   1                Ole strongly oppose this alternative.       Further exploration of
                                                                                                                                               this nature would make no positive contribution to the national
           85     2 4    1      Are automatic block values really the best design option for                                                   energy situation.     It would not find oil, and it would not
                                subsea pipelines?                                                                                              provide    enough   now    geological     information    to     effect
                                                                                                                                               substantively any decision on leasing.        Surface and regional
           85     2 4    6      Access for repair and maintenance during the "Ice       season" would                                          geologic information already confirm that the area has oil
                                be difficult. Recommend replacing "would not be possible" with                                                 potential.   A critical evaluation of this potential will not
                                                                                                                                               happen until there is leasing.       On-structure drilling is the
                                                                                                                                               only means by which -the presence of oil can be verified and
                                           CR&PM V                                                                                             evaluated from a commercial perspective.

           ALTERNATIVE A    FULL LEASING Of TOE 1002 ARE                                                                                       It is also important to recognize the cost of operating in the
                                                                                                                                               Arctic and the constraints those costs will place on the extent
           89     1-2           We strongly    support the Department of Interior*s proposed                                                   of industry's exploratory efforts.       The object of expensive
                                recommendation that the entire 1002 area, Alternative A, be                                                    exploratory drilling should be to find oil.             Off-structure
                                authorized for oil and gas exploration and production.            Full                                         drilling will not enhance our knowledge sufficiently to justify
                                leasing of the 1002 area is consistent with the national                                                       the time, the expense, or the delay in the ultimate benefit of

                                                      S-33                                                                                                          S-34

                  C.                                                                                                        C.

                                  producing oil in AM.      Alternative C is simply an expensive.                                            2.  Even if more specific wildlife use maps were used,
                                  means of delaying the ultimate* decision of whether or not to                                              overlaying  them . with the      full and    limitsId developement
                                  lease the Coastal Plain.                                                                                   scenarios shown in Figure V-1 was pointless because, as the
                                                                                                                                             following paragraph (p. 95) states, "Alternatives A and B
             ALTERNATIVE D - NO ACTION                                                                                                       depict hypothetical infrastructures", and "any prediction as to
             ALTERNAT IVE E- WILDERNESS DESIGNATION                                                                                          the various stages of development at any given time on the 1002
                                                                                                                                             area would be highly speculative and perhaps misleading".
             p. 92 through 94     Neither Alternative D or Alternative 9 would allow for                                                     Moreover, the development scenarios shown . in Figure 11-1 are
                                  confirmation    ofI information   indicating    that    substantial                                        extremely schematic and drawn. at a very small scale.      Yet the
                                  petroleum reserves exist In the   1002 area. These alternatives                                            test states that overlaying these two scenarios with the
                                  Preclude   reasoned   planning   for   fixture   national    energy                                        equally vague wildlife use maps "allowed measurement of direct
                                  requirements and deny "a nation the positive benefits that                                                 habitat loss or alteration.     Dote.rminations were then made as
                                  could come from oil and gas production on the Coastal Plain.                                               to the nature and magnitude of direct and indirect habitat
                                                                                                                                             losses, disturbance, mortality, and other potential effects."
                                                                                                                                             It in difficult to see how such measurements, especially
                                    CRhP= V2     ENVIRONMENTAL CONS                                                                          determinations of disturbance and mortality, could have been
           L                                                                                                                                 made using the described approach, or how any substantive
         .9h. ALTERNATIVE A -_JTLk                                                                                                           conclusion could have been reached. The described assessment
             CONSEQUENCES OF EXPLORATORY DRILLING                                                                                            approach can only shake the critical reader's confidence andL
                                                                                                                                             casts doubt on all biological conclusions reached in Chapter VI.

             95   2   3   .8-14   The described procedure by which environmental consequences
                                  were determined is inadequate for the following three reasons.                                             3.  Finally, and most Important, the test implicitly assumes,
                                                                                                                                             for reasons unstated, that predicting "direct and indirect
                                  2.   "ildlife use areas shown on Plates 1-3 are vague and                                                  habitat   losses"   is, a biologically L appropriate means of
                                  general, and are  mapped at an extremely small scale.      Although                                        assessing probable development effects on wildlife inhabiting
                                  they may be helpful in pr  Ioviding the public with a general idea                                         the 1002 area. This relates to the simplistic idea, discussed
                                  of wildlife use areas within the 1002 region, these maps are                                               above, that overlaying maps of general wildlife use areas with
                                  not appropriate to support a professional analysis.       If -- as                                         hypothetical oilfield layout plans is a valid basis for
                                  stated in the subject text -- the maps shown in Plates 1-3 were                                            predicting a wide range of effects on wildlife.        In reality,
                                  Indeed used to develop an assessment of potential development                                              habitat change is only one of many factors that can affect fish
                                  effects on wildli fe, the results can have no real usefulness.                                             and wildlife populations. In the Alaskan Arctic. where habitat
                                  if larger-scale, location-specific maps were used, the text                                                availability has not been shown or convincingly suggested to
                                  should be revised to say so.                                                                               limit most animal species (and in likely to do so only In the
                                                                                                                                             cases of overwintering fish and some bird species that combine
                                                                                                                                             (1) highly exclusive nesting territories with (2) nesting range

                                                       S-35                                                                                                       S-36

               c.                                                                                                              C.
                                limit ad exclusively or predominately to the Arctic Coastal                                                     wildlife populations.      But, from the standpoint of providing
                                Plain), a habitat-based approach to assessing potential effects                                                 realistic impact analyzes and effective protection for animals
                                of development on wildlife may miss the mark entirely. Where                                                    in the arctic, the focus should be on population management and
                                habitat availability In likely to be an important factor in                                                     the mitigation of variables that are known to influence animal
                                limiting the productivity of a         species -- e.g., arctic and                                              movements and behavior.        This position Is supported by MuI6
                                red-throated loons (Davis 1972, Johnson at al. 1975, Bergman                                                    (19822231) who states that, "habitat assessment for (these)
                                and Derksen 1977, Derkson at al. 1981) or dunlin (Holmes and                                                    large herbivores would be more effective and meaningful if the
                                Pitelka 1986, Holmes 1970) -- lose or alteration of habitat is                                                  populations were examined as the primary units of study."
                                one of several factors that can be appropriate for predicting
                                development-related effects on the species in question.              For                                        MuI6 (1982) conducted a study to evaluate the appropriateness
                                species where there is no evidence that habitat availability is                                                 of wildlife habitat assessment techniques in Alaska.                  The
                                or in likely to be a population-limiting factor -- e.g.,                                                        study, funded by FWS through the Institute of Arctic Biology,
                                caribou    (Bergerud    1986,    Bergerud    at   al.    1984)   --    a                                        University of Alaska, Fairbanks, was based on the assumption
                                predominately habitat-based approach is clearly inappropriate.                                                  that to mitigate effectively the imp-ots from large scale
                                This.&*, especially true when factors unrelated to habitat                                                      natural resource development projects,,-'fte has to mitigate the
                                (e.g., predation or human harvest on winter range in other                                                      "habitat losses accruing from such projects" (MuI6, 1982,
           L                    geographic areas) are ignored or do-emphasized as a result of                                                   p.1).   The study was designed to "experimentally examine the
                                applying an across-the-board habitat-based approach to all                                                      effectiveness of the Terrestrial Habitat Evaluation Criteria
                                species.                                                                                                        (HRO Handbook-Alaska for evaluating wildlife habitat                   In
                                                                                                                                                Alaska" (Mul6, 1982, p.7).       In this respect, it,used a far more
           95   2   4    8-9    We would agree that the consideration of three simultaneous                                                     refined habitat evaluation       technique than the overlaying of
                                developments represents a worst case scenario and in actual                                                     maps and gross measurement       of acres that FKS has used for the
                                fact is extremely unlikely.        As a result, the environmental                                               habitat evaluations in the       1002 draft report.      Its findings,
                                consequences predicted on the basis of this three development                                                   however,    are pertinent because the concept and habitat
                                scenario are highly speculative and overstated. They have not,                                                  evaluation procedures Mul4i used are an out growth of the FWS
                                however, received the benefit of proper qualification. . It is                                                  Mitigation Policy and because his evaluation species included
                                incumbent upon the authors to include appropriate caveats and                                                   moose and caribou.
                                cautionary statements throughout this chapter to avoid any
                                misunderstanding     that   the   environmental     consequences     are                                        The habitat models tested did not perform at acceptable levels
                                statements of facts.                                                                                            of accuracy,      and Mu16 concluded that Habitat Evaluation
                                                                                                                                                Procedure (REP) models are reasonable only in theory for those
           97   1   3    6-7    As discussed in our general comments, we believe application of                                                 species of animals that are habitat specialists and/or have
                                the FWS Mitigation Policy to be inappropriate precisely because                                                 very small home ranges with habitat requirements that are
                                it does focus "especially on losses of habitat value".            We do                                         simple enough to model.        Interestingly. the models with the
                                not mean to imply that habitat is not vitally important to all                                                  most problems and greatest inaccuracies were those for moose,
                                                       S-37                                                                                                           S-38

                                                                                                                    R.    C.
        0.   c.
                              caribou and mink,      emphasixing that     fact   that HEP type                                            producing more reliable models, particularly when those models
                              approaches are "simply not workable" (Muli, 1982, p. 130) for                                               are highly data sensitive" (Maurer, 1986).
                              large mobile herbivores, such as moose and caribou, or for                                                  The real issue of concern. however, is whether or not habitat
                              predators and omnivores.                                                                                    "value", or habitat conditions can be- relied upon as valid.
                                                                                                                                          indicators of population status and of potential impacts to
                              The problem he came across is the same one    that invalidates the                                          wildlife associated with said habitat.        In reference to    this
                              habitat approach to impact assessment used in the 1002 draft                                                issue, Maurer concludest I
                              report.  Large mobile herbivores "are habitat generalists that                                                      "Perhaps of greater concern to the manager is the
                              range over wide areas, utilize a variety of habitat types                                                           possibility that populations of species may not be
                              (often seasonally), and exhibit complex so    Icial and behavioral                                                  as closely tied to habitat conditions as has been
                                                                                                                                                  thought previously. Although some species appear to
                              patterns."    (Muli, 1982, p. 130)     Habitat evaluations cannot                                                   be   associated  consistently     with   some    habitat
                              incorporate    the   complexities    introduced    by non-habitat                                                   variables (Moon at al. 1980), many recent studies
                                                                                                                                                  have demonstrated a great deal of variation in
                              variables that influence habitat generalists such as caribou.                                                       habitat   associations  among geographic      locations
                              The problem in that "in addition to habitat. their populations                                                      (Collins 1983a,b; Shy 1984).   Even among study sites
                                                                                                                                                  in   close  proximity,    several   researchers     have
                              in Alaska ma be limited by non-hwnan and human predation.                                                           documented significant variation in us ' of habitat
                              weather, disease, Rarasites, or any other number of other                                                           for foraging (Maurer and Whitmore 1:81, . Franareb
                                                                                                                                                  1983, Mennen and Maslow 1984) .... The results of the
                              densitZ dependent and densitZ   indegendent factors, Attempts to                                                    gresent   study   should   raise   serious
                              model habitat relationshlips for these and other such aRecies                                                       regarding the use of qualitative models, such as
                                                                                        71@1                                                      REP. in monitoring and Predicting the reaRonse of
                              are froucht with diff cllftle,." (Mulii, 1982, p. 130) (Emphasis                                                    bird ageci*s (and verhags other wildlife agecies) to
                              added.)                                                                                                             changes   in    their     habitats.     if    rigorous,
                                                                                                                                                  data-intensive models can 2erform Poorly, it is
                                                                                                                                                  likely    that    subjective.     Poorly      documented
                              Maurer (1986) shares Muli's concern that one cannot rely on                                                         gualitative   models   also    will   present    serious
                                                                                                                                                  iproblems in their use as                        habitat
                              quantitative habitat models to make impact predictions. One of                                                      Qualit    (Bart  at   al.    1984)"   (Maurer,    1986).
                              the major points made by Maurer Is that even rigorous models                                                        (Emphasis added.)
                              depend on specific sets of data collected under a restricted
                              set of conditions and therefore will be of limited generality                          97   2   2           The policy implimentation and stop down process has been uneven
                              and limited use.     Although his conclusions were drawn after                                              and often subjective and impractical in Alaska.          An apparent
                              attempting to predict habitat quality for grassland birds using                                             bias towards acreage concerns and compensation has largely
                              density/habitat correlations, they are relevant to the concept                                              Ignored and under valued genuine mitigation efforts through
                              of using habitat quality in impact predictions and management                                               improved project design and protective field practices.
                              plans.   In his concluding recommendations for management,
                              Maurer emphasizes that all methods of quantifying habitat must                         98   1   2           The designation of FWS Resource Category I for the "core
                              be properly verified; and that as the models are more widely                                                calving area" is inappropriate for several reasons.                The
                              applied, they must be updated.      Regardless, he cautions that                                            habitat   in question     is   not   "unique   or   irreplaceable".
                              even "an updating strategy may not be entirely effective in
                                                                                                                                                                S-40
                                                   8-39

       2,   C,                                                                                                          C. 1, 1,

                            Biologically based methods have not been used to define a                                                   logically   implemented for all production facilities.            An
                            "core" calving area for the Porcupine herd.      And, there is no                                           example would be the placement of impermeable type liners under
                            evidence for a unique area of "core calving habitat" with                                                   exploration facilities during temporary operations.            These
                            definable   special characteristics     that   might    somehow    be                                       types of liners may or may not be applicable or feasible for
                            irreplaceably lost as a result of oilfield development.           We                                        permanent production skids.       Additionally,   the designs of
                            refer you to our general comment 05A for a full discussion of                                               production skids may or may not include contiguous containment
                            this issue.                                                                                                 structures, depending an the risk potential of the operation in
                                                                                                                                        the skid. Additionally, if the KICIASRC land use stipulations
                            The   primary    reason   stated   for   the    Resource    Category                                        are to be applied to all 1002 area leases, they should be
                            classifications of  .ANWR lands Is that they are recommended by                                             printed In full for both public review and for public awareness
                            volic .   once again FWS has relied on policy rather than to                                                of existing protective measures th       Iat will mitigate many
                            bass their rationale on biological assessments.                                                             potential impacts.

                            The other problem with classifying this area as Resource                              99    1   6   9       "Minor fuel spills could also occur." These spills would be
                                                                                                                                        cleaned up with no effects, or at most brief, and minimal
                            Category I Is the mitigation "goal" of NO LOSS of existing
                            habitat value, and the policy guideline specifying that FNS                                                 effects.
       A                    recommendations regarding activities In the area will be that
                                                                                                                  99    2   2           This paragraph does not present    an accurate picture.  He suggest
                            "all losses of existing habitat be prevented".       Typically, In
                            Alaska, this has meant no loss of acres and resulted in the                                                 that It be rewritten an fol2owar
                            recommendation that no development be allowed in a Resource
                                                                                                                                        Exploratory drilling requires construction equipment to prepare
                            Category   I   area.    This   is   contradictory   to    Interior's                                        a stable drilling pad, reserve pit, road to the water source(s)
                            recommendation to lease all of the 1002 area. Either it would
                            have to be recognized and acknowledged by FNS that oil and gas                                              and airstrip. When the wellsite is completed, the drilling rig
                                                                                                                                        and support equipment is transported in with Hercules. C-130
                            development activities do not produce habitat degradation for
                            caribou; or some special consideration would have to be granted                                             aircraft or trucks using ice roads,       depending on distances
                            under the policy allowing or endorsing a waiver from this                                                   between well locations.
                            mitigation goal.
                                                                                                                  99    2   4           The 15 million gallons of water needed to drill one exploratory
       98   2   04          The assumptions (subparagraph 4) state that the land-use                                                    well has been discussed in previous sections. ' To maintain
                            stipulations for exploration drilling on KrC/AsRc lands would                                               consistency,  this paragraph should be changed to read as
                            continue to be in effect for all oil and gas operations in the                                              follows:
                            1002 area.     This assumption implies that a very broad,
                            comprehensive set of stipulations would apply to all future                                                 Water requirements for exploration operations are estimated to
                            activities.   Frequently, stipulations applicable for seismic                                               be as followat
                            and/or  exploration    activities   cannot be economically or

                                                 6-41                                                                                                        S-42

    p.   c. _.  1.

    			(1) 	414,000 gals/mile ice road contruction

    				  4,200 gals/mile for daily maintenance

    			(2) 2,500,000 gals/Hercules C-130 airstrip

    				  2,100 gals/airstrip for daily maintenance

    			(3)	 25,000 gals/day drilling operations and domestic use

    			Although naturally occuring sources of fresh water for

    			exploration and developmental use are scarce in the 1002 area,

    			this is true throughout the North Slope.  Methods by which

    			water has been successfully extracted include:

    			(1)  Excavating deep pools is river and stream beds;

    			(2)  Excavating deep pools in lakes;

    			(3)  Insulation of ponds to prevent freezing;

    			(4)	Desalination of sea water;

    			(5)  Converting gravel extraction pits to reservoirs.

    99  2  4		Spring breqkup and late summer/fall rains should provide

    			sufficient recharge for any lake or river in the 1002 area.  On

    			page 21 of the EIS high water conditions are also discussed.

    			Given the number of sources and technigques for getting water,

    			and naturally occurring recharge of area water resources, it

    			misleads the public to state that water use "could have a major

    			adverse effect".

    99  2  5  4		A minimum thickness for the NPRA ice airstrips was quoted at 12

    			inches.  Recent Hercules C-130 operations have found that 6

    			inch thick tundra ice airstrips are acceptable, so this

    			paragraph should be changed to read as follows:

    			....Ice airstrips on the NPRA were built with a minimum

    			thickness of 12 inches for safety although recent Hercules

    			C-130 operations have found 6 inch thick airstrips to be

    			acceptable....

    								S-43

        R,    c. 1.

                                questioned the technical basis and validity of conclusions in                                                      center around the speculated sources of high concentrations of
                                the draft Snyder-Conn report.         Additionally, ARCO submitted                                                 various components of the reserve pit samples.             The sampling
                                written comments to USPWS which questioned the credibility of                                                      methods used (grabs at the edges. of pits and from under
                                the Synder-Conn study.                                                                                             discharge lines instead of from hose discharge onto the tundra)
                                                                                                                                                   could easily have provided skewed and unrealistic results..

                                Reviewers have questioned the technical basis and validity of
                                conclusions in the draft Nest and Snyder-Conn reports for a                                                        6)   Baseline conditions for the ponds and their ability to
                                number of reasons. These reasons Includet                                                                          sustain heal  -thy invertebrates was not substantiated.          The use
                                                                                                                                                   of a variety of species as indicators, instead of a' few test
                                1)  The conclusions given in the draft reports are based on                                                        species did not provide good study control.             The ponds that
                                only 2 or 3 years of field data.                                                                                   were sampled freeze solid every winter, thus recolonization
                                                                                                                                                   must    occur    every     spring.     The    factors     allowing     the
                                   The experimental design has serious flawas for example Went.                                                    establishment of healthy invertebrate populations may only
                                and Snyder-Conn do not address other variables (natural or                                                         occur during certain periods of the open water season, based on
                                operation. induced) which may cause variation In tundra ponds.                                                     thecharacteristics of the particular pond being studied.
                                Their elimination of controls with hi      gh salinity demonstrate a
                                biased approach     to control selections and the statistical                                                      This section should also mention that the State of Alaska has
                                analysis o f results was not meaningful.                                                                           very     specific    discharge     parameters      allowing      on-tundra
                                                                                                                                                   .discharges only when appropriate.

                                3)   The question to be addressed by the analysis was the
                                statistical .comparison of tundra ponds with reserve pits, in                                                      There are a number of published reports that are much more
                                terms of water quality and aquatic life. The use by the author                                                     comprehensive and with results differing from those of Nest and
                                of the same ANOVA for both reserve pits and tundra ponds cannot                                                    Snyder-Conn on which       impact predictions can be based.          At a
                                not provide this answer, thus the conclusions provided are not                                                     minimum, the recently      published report Final Wellsite Cleanup
                                valid.                                                                                                             on National Petroleum      Reserve - Alaska volumes 1-3 (USGS, 1986)
                                                                                                                                                   should be reviewed and     referenced.

                                4)  The draft report identified specific criteria by which
                                selection of reserve pits and ponds would be made for the                                    100 1      3-4                         arve Rita:     Existing regulations which address
                                study. However, the final sites selected to be sampled for the                                                     this    activity have been         ignored.     The   State of Alaska
                                study did not meet those criteria.         For example, a number of                                                Department     of   Environmental     Conservation     will     promulgate
                                the ponds were actually impoundment areas that may not have                                                        regulations     in   1987 which address         pit   construction and
                                been there prior to construction of the facility.                                                                  close-out requirements.

                                5) Credibility of this report is further compromised by impact                               100 2      2   (03)   These paragraphs concerning minor oil leaks and spills from
                                predictions that cannot be technically justified.          These areas                       101 1      3   (06)   operations gives the reader an exaggerated view of this

                                                      S-45                                                                                                                S-46

                C. q.                                                                                                    P,   c. 1.

                                 potentia I consequence. Minor spills are usually very local in                                                summer growing season).       The speed and success of tundra
                                 nature, occurring an gravel pads an      d/or roads where they can                                            recovery has been found to be positively correlated with the
                                 easily be cleaned up and' where their effects are only short                                                  increase In the moisture level of the areas affected.             Most
                                 term.    Winter operations provide add   itional protection due to                                            spills occurring an tundra tend 'to collect in areas of low
                                 the layer of snow and ice protecting the tundra. Combined with                                                relief.   Conveniently, these areas are wetter.       Standing water
                                 the widespread use of impermeable liners under, most facilities                                               in areas of low relief provides a buffer zone between the plant
                                 and work areas, the tundra In and around most operations                                                      roots and the oil; thus only the upper leafy portions of the
                                 remains untouched.    The effect on the tundra of winter        spills                                        tundra mat are killed as a result of most spills.             Recovery
                                 from .operating equipment is minimal or none.       When accidental                                           success is also dependent      upon, the type of product spilled.
                                 spills occur (line 6), the contminated snow and ice is scraped                                                Crude oil spills have been    observed'to cause less damage than
                                .up and removed for disposal.      There are only 3 months during                                              refined product spills.,
                                 which tundra or waterways are exposed to minor spills. Because
                                 of ADEC regulations requiring the. reporting and cleanup of all                                               Humorous references concerning arctic vegetation recovery are
                                 spills,   even minor discharges are addressed immediately,                                                    available and should be    cited. They include: McKendrick at al.
                                 cleaned up, and the area   restored If necessary.                                                             (1978), Walker at al.      (.1978), Webber at al., (1978), Chapin.et
                                                                                                                                               al. (1980), Johnson at al. (1980), Johnson (1981), Pope 'and
        @ACONSEOUENCZS RESUL-TIN(; IFROM CONCTRUCTTON OF ROADR@         PTPELINES@ AND MARINE XRD                                              Hillman (1982), Pope at    al. (1982), and Brendel (1985).

           PRODUCTION FACILITIES
                                                                                                                                               Diesel fuel spilled on     the tundra may be toxic, especially if a
           VEGETATION, WETLANDS, AND TERRAIN TrPES                                                                                             large quantity of diesel in spilled an dry tundra vegetation,
                                                                                                                                               allowing penetration to the roots and thereby causing death of
           102 2     1-5         To imply that there are "hundreds" of    small areas of vegetation                                            the plant.    Surface only impacts may not effect the roots,
           103 1     1-2         effected by oil spills is a great exaggeration. The number of                                                 allowing recovery within one season or less.            As mentioned
                                 spills for the entire "astern Operating Area (WOA) of the                                                     above, It the area is moist or allows for recovery on the
                                 Prudhoe Bay Unit (PHU) averages around 100 spills per year or                                                 ponded surfaces, the effects may be temporary with recovery in
                                 lose.    Most spills are cleaned up immediately, and In the                                                   the same season. Numerous revegetation references from the mid
                                 majority of cases no vegetative impacts occur.                                                                19809 are available and should be cited.

                                 When referring to those cases where tundra spills do cause                              102 2     4   1       Reserve pit fluids spilled on the tundra may cause some
                                 local damage to the vegetative mat, the report should discuss                                                 impacts, especially if a large quantity of contaminants covers
                                 and cite current work on restoration.       Work funded by the oil                                            dry tundra vegetation, however, it was noted in the recently
                                 industry has demonstrated that with the use of proper oil                                                     published USGS report for vellsite cleanup on the National
                                 recovery and cleanup techniques, followed by simple restoration                                               Petroleum Reserve-Alaska (USGS 1986), "drilling muds eventually
                                 techniques, vegetation in tundra areas inundated by oil can                                                   become    overgrown     by  plants;    salinity    diminishes;      and
                                 recover successfully in a short period of time (as short as one                                               impoundments and thermokarst depressions are colonized by
                                                       S-47                                                                                                           S-48

             c.                                                                                                               C.

                              water-tolerant vegetation, if water depths are not too deep."                                                   'concerning the level of impact that dust and gravel have on
                              Also discussed was that Alaska flora and fauna demonstrate a                                                    tundra wetlands. The assumed 100 foot zone of secondary impact
                                                                                                                                              around all facilities. which is stated as 7,000 acres of
                              certain plasticity which provides a capacity for adapting to
                              several   commonly    occurring    disturbances     associated     wIith                                        vegetation that could be          modified,    has    no scientific
                              hydrocarbons.                                                                                                   justifl.cation.   The actual significance of this sec           Iondary
                                                                                                                                              impact zone in regards to wildlife use of the 1002 area is also
         102 2     5          The use of larger quantities of fuel at exploratory drill sites                                                 not explained.    It has been well observed and documented that
                              may provide a larger potential riskl however, the design and                                                    birds do use areas of tundra adjacent to facilities where snow
                              construction of exploratory pads provide much better spill                                                      melt    has    occurred ' earlier       than     surrounding    areas.
                              prevention    facilities     and   equipment.      This    undoubtedly                                          Additionally, impoundment areas have also been classified as
                              contributes substantially to the           spill   statistics     which                                         dealrabl*,habitats for some species of birds.
                              indicate that over 95% of the spills      that occur ar              -d
                              as minor spills, generally lose than I barrel an: cfr'aq5u3e'nft'ly                       103 2    4    12      The largest spill cited In this         ,sentence occurred at Chen&
                              lose than 10 gallons.                                                                                           River, just outside Fairbanks. The inference that it happened
                                                                                                                                              at Prudhoe Bay should be corrected. It in important to clarify.
                              Similarly. the reference to spills occurring during. seismic                                                    that the spill. reports by the ADZC, stated an 23,000 in number,
        T,
         &                    surveys should be quantified, and It not quantified, deleted.                                                   encompass a such larger, area than Prudhoe Bay.             Standard's
                              Although there were some fuel leaks during the two winters of                                                   average number of spills per year is      .approximately 100 for the
                              seismic explore  .tion in ANWR, they were negligible (totaling                                                  PBU. This paragraph provides a very       misleading pict   Iure of the
                              less than 5 gallons., L. Brooks, GSI, pers. coon.).                                                             the spill potential for an oil development area.

         103 1     1  2       There are cases where diesel fuel spilled an the tundra may be                            104 1     1   9       In addition to stating that most spills that occur in the
                              tozic, however, the references cited in the 1002 draft report                                                   Prudhoe Bay area are small, (lose than 10 gallons) it should be
                              address work done in, the late 1970s. Substantial reveqetation                                                  pointed out that these spills rarely occur off gravel pads and
                              work has been done since.       Current references that should be                                               roads.
                              cited are listed above under p. 103, c. 1, 1. 1-2.
                                                                                                                        104 2     1           (See comment for p. 100, c. 1. 11 1-2. and p.       103, c. 2, 11 2)
         103 2     2          it is  not appropriate for the draft LEIS to quote the Meehan                                                   The draft LEIS repeatedly ignores established environmental
                              report which is still In draft form and out for re                view.                                         protection field practices, promulgated by regulation and
                              Additionally It is Incorrect to use Meehan's model, developed                                                   company policies, for petroleum developments. elsewhere on the
                              for assessing potential habitat concerns             for  birds,   and                                          North Slope.     (e.g., snow removal zones, 24 hr. field spill
                              extrapolate Its reported results to all wildlife in the area.                                                   response teams, field security enforced traffic controls, and
                              Was with regards to birds, Meehan's work showed different                                                       regulated tundra travel procedures)
                              responses in different species.)        In the report, and thus in
                              the draft LEIS, a number of arbitrary assumptions are made

                                                    S-49                                                                                                            S-50

          V.    C.                                                                                                            C. 1. 1.

          104 2      1   7      Add    the   words    "djolan   an      in   front    of   the    word                                        in the Alaskan arctic have determined this level of potential
                                "construction." Appropriate design and construction does          play                                        impact as moderate.
                                a major role In preventing spills of all substances.
                                                                                                                        TERRESTRIAL MAMKhLS
          104 2      3   2      Change   the   word   "moderate"    to   "minor".    Based on the                       CARIBO
                                Information presented in this section and current references on
                                revegetation and spill impacts the expected modifications would                         105 2     3           Some data do not appear to be consistent with some of the
                                have a minor impact as defined in Table VI-1 on page 96.                                                      statements made about use of the area for insect-relief.             In
                                                                                                                                              contrast to statementd refe;rInq to caribou going to the coast
          COASTAL AND MhRINZ MWIROMMENT                                                                                                       for Insect-relief:     1) caribou have sometimes remained Inland
                                                                                                                                              In spite of the presence of abundant insectsi        2) insects were
          105 1      6   2      The word "severely" should be deleted as it implies an impact                                                 not always present during several of the late June - early July
                                of extreme consequence could occur from any size of spill                                                     "insect-relief periods"; and       3i caribou have rapidly left
                                during any time ia this environment.      Based on the history of                                             relatively    insect-free    zones    and   entered    more    heavily
                                Impacts from spills, research Into the environmental effects of                                               Insect-infested zones.     The two most important activities in
                                spills year-round (Owens at al 1984 and Owens at al 1985), as                                                 the 1002 area appear to be calving, and post-calving activities
          L                     well    an  the mitiuatina measures of soill           cleanuo and                                            culminating in the formation of large post-calving aggregations
                                restoration that are part      of industry policy and government                                              and the beginning of post-calving migrations, not ** ... calving
                                regulation,   this is unrealistic.       As stated in the last                                                and seeking relief from insects...".       It In true that caribou
                                sentence of this paragraph, the level    of impact would relate to                                            make use of inseqt-reli@iriiabitats in the area when insects are
                                the volume of oil    spilled,  location, effectiveness of cleanup,                                            present.   During post-calving, caribou seek and make use of
                                time of year, and fish and     wildlife species present.     Even If                                          Insect-relief habitats whenever necessary and wherever they
                                the catastrophic event were to occur, spill cleanup and natural                                               occur locally (whether they be coastal, inland, or somewhere in
                                recovery would take p   lace;  the impacts experienced and their                                              between).    But post-calving aggregations form with or without
                                magnitude   would be     totally dependent on the          Conditions                                         insect harassment.    Insects, when present, act as a local and
                                occurring at the time.       Past ZIS evaluations for potential                                               short-term    modifier    of    these    larger-scale      happenings.
                                spill events I n the Alaskan arctic have determined this level                                                Post-calving use of the 1002     area appears to be based largely
                                of potential impact as moderate.                                                                              an social needs, not just the presence of insects. Generally,
                                                                                                                                              discussions of insect harassment and insect-relief habitat
          105 2      2   3      Change the word "major" to "moderate".       This is based an the                                             appear to ignore this aspect -- if everything implied about
                                historical record of measured impacts from catastrophic spills                                                insects were true, one might expect the caribou, once forced
                                that have occurred world-wide and the recovery time of the                                                    from the hills by insects, to remain on the coastal fringe
                                effected environments.    As a tated on p. 120, c. 1, 1 2, 1. 1.                                              until the snow fell, instead of migrating back inland where
                                "Adverse effects on birds from further exploration are likely                                                 Insects are sometimes present in much greater numbers, or
                                to be minor." Past RIS evaluations for potential spill events                                                 migrating back inland before insects have emerged in any great

                                                     S-51                                                                                                          8-52

         2.   c-                                                                                                         C.

                               number, as has often been the case (D.G. Roseneau, 1987, pers.                                            disturbance simply because it is there, and is available. This
                               comm.). This section should also clarify that mosquitoes are                                              is especially true wheii the species of concern is a habitat
                               the relevant insects in the 1002 area, and that the oestrid                                               generalist.    In other words, habitat of low value to the
                               flies do not emerge until after most of the caribou have left                                             species of concern (such as 4reas not used as frequently by
                               the 1002 area.                                                                                            calving caribou), when considered as parts of a whole, may have
                                                                                                                                         great value and be perfectly satisfactory in meeting the
         105 2    4            Some disturbance-related displacement of CAR animals might                                                animal's needs.
                               occur, but will it matter -- will it be of true biological
                               significance Ito the population? The CAR is increasing In size                       106 1    2           If the   Canning Delta is supporting more calving than the
                               and "pioneering" now range (at least now to the animals that                                              Xuparuk  area, this is apparently relatively new, and probably a-
                               are present today).    Given the size of CAB vs. its current                                              function of increasing hard size (such did not appear to be the
                               range, it is doubtful that some displacement from areas east of                                           case in the early and mid-1970a). The suggestion that calving
                               the Canning River would have more than minor potential for                                                caribou have been displaced by the Prudhoe bay oilfield is not
                               truly adverse impacts to the herd. In fact, -it is doubtful that                                          supportable and should be removed (see below).
                               full exclusion from these areas- would be of more than
                               negligible impact.                                                                   106 Table VI-4.      The information given in Table VI-4 is      dubious at best and Is
                                                                                                                                         too meager to even permit qualitative       comparisons.     Footnote
         105 2     5           The discussion here, and throughout the biological impacts                                                NO. I suggests that about 3,000 animals previously calved. in
                               section raises the question of habitat (available acres) versus                                           the Prudhoe Say development area.    The 3,000 figure referred to
                               habitat value. Here, the discussion is back to habitat, i.e.                                              total herd size and not just to parturient females.              This
                               the direct and Indirect loss of acres with no discussion of                                               information is from Child (1973) and reported by ShIdeler
                               relevant values.    The inference is clearly that modified                                                (1986).   The information is very general, and what proportion
                               habitat has lost value,       and for the purpose of Impact                                               of these animals actually calved in what was then considered to
                               evaluation the land In totally lost and irretrievable.                                                    be the "development area" (generally within a few miles of the
                                                                                                                                         coast between Beechey Point and Mikkelsen Bay) or the immediate
                               With respect to displacement,       not only does      the    impact                                      area of the present day development In unknown.           The Table
                               :83essment assume total loss of an area from which caribou are                                            Implies 3,000. indeed, Child (1973), cited by Shideler (1986),
                                nly partially displaced, but It does not consider               the                                      refers to the       astal  area of Prudhoe Bay as being " ... an
                               possibility that neighboring acreage could increase in value                                              important summerc:auge for a    small population of approximately
                               since the PCH is not limited by habitat availability. What is                                             3,000 animals         Child  (1973) also states that "Lately the
                               not recognized in the displacement arguments is that the vs      lue                                      Prudhoe Say range has become increasingly important as a
                               of any given habitat unit is dependent to a great degree upon                                             calving ground for a small segment of the resident herd that
                               the value of the adjacent habitat unit. While some habitat may                                            over-winters In the area." (i.e.. presumably a small part of
                               be disturbed and therefore lowered in value, adjacent habitat                                             the 3,000 animals).    Child (1973) reports that the incidence of
                               may increase significantly in value and compensate for the                                                calving "...within the oilfield... " for 1971 and 1972 was

                                                    S-53                                                                                                      S-54

          R.   c. 1.                                                                                                            p,   c, 1,

                                 contained in other brief reports -- Child (1971 and 1972).                                                            structures,    and are therefore         incredibly misleading.          As
                                 [These reports were apparently not accessed by Shideler (1986)                                                        discussed in our general comments,              the 2-mile sphere        of
                                 -- nor by Cameron and Whitten in various publications.)                The                                            influence applied repeatedly in the impact assessment                    of
                                 incidence of calving never totaled 3,000 animals.           For example,                                              caribou is based on an incorrect. interpretation of the work
                                 on a May 1971 survey Child (1972) found only 68 caribou                                                               performed by Dau and Cameron (1985).            The table gives less
                                 scattered in coastal habitats between Beechey Point and                                                               experienced readers the Impression that large acreages will be
                                 Mikkelsen Bay -- only 10 cow/calf pairs were Identified among                                                         totally and irretrievably lost, which is R" the case.
                                 them.   [Notet presumably, most of the remainder were cows and
                                 calving was still likely occurring.           Even so, this provides                                                  Even. though there is some validity to the concept of partial
                                 some Measure of the magnitude of calving occurring in the                                                             displacement (versus total) there are no data suggesting that
                                 coastal lowlands near and at Prudhoe Bay in 1971. For the sake                                                        displacement of parturient caribou has any effect at all on
                                 of accuracy, the number of cows and calves in Table VI-4 should                                                       their calving success or on calf survival.                 Therefore, it
                                 be reported as cow/calf pairs.         For instance, the number "13"                                                  should not be inferred (as it is in this Table) that , it
                                 for the year 1972 actually represents 8 cows and 5 calves (see                                                        constitutes an adverse effect.
                                 Shideler 1986).     The number "42" for the year 2973 actually
                                 represents cows, calves =a an unknown number (presumably) of                                                          Also. the text incorrectly reads: "Percent of total US and
                                 yearlings (see Shideler      1986).    Are all of the "51" animals                                                    Canada area potentially Influenced by development" when it
        01                       listed for 1974 cows and    calves? The 1981-1985 "data" reported                                                     should be      reworded to      read:    "percent of      total calving
                                 provide an essentially       meaningless comparison with previous                                                     grounds". As stated, it gives the impression that areas of
                                 years (i.e.. three years      reported, but data are not available                                                    Canada will be affected by development.
                                 for two of them). In susimary, Table VI-4 Is useless and should
                                 be omitted.)                                                                                                          The table also perpetuates the concept that caribou are
                                                                                                                                                       dependent on a small, fixed "core" calving area (i.e., 311.000
          106 1    4-5,          The impact analysis must be revised recognizing that no area                                                          acres -- an area only about 22 miles by 22 miles in size).
                                 fitting the definition of "core" calving area exists and that                                                         This is not true (see our general comments).            The area, should
                                 there is no basis for the 2-mile displacement zone assumed.                                                           be described for what It is, an area used repeatedly but not
                                                                                                                                                       exclusively or even predictably on an annual basis by
          106 2     2            Here it is correctly noted that oestrid flies are not a major                                                         parturient caribou.
                                 feature of the PCH's environment In the 1002 area.
                                                                                                                                                       Further, the number, 50 caribou/square mile is arbitrary, and
          107 Table vi-5         Table VI-5 is confusing because the reader must continually                                                           no density information Is available to support it.               Not only
                                 refer to the text to see if the numbers in the table represent                                                        are there no data to support the reference to 50 caribou/sq.
                                 acres or percentages.       More importantly, the figures given in                                                    mi., it is not clear to the reader whether or not the 50
                                 the table assume total displacement from the assumed 2-mile                                                           represents cows, cows and calves, or pairs.             Most scientists
                                 sphere    of   influence     around    all    facilities,     roads    and                                            would assume that it meant cows for several reasons including:

                                                         S-55                                                                                                                 S-56

              c.                                                                                                              C, 1,

                                1) because calves depend little on the habitat for nutrition.                                                  be ecologically based, i.e. emphasis should be placed on the
                                and 2) because the numbers could be greatly skewed by including                                                factors governing caribou population dynamics,            and impact
                                calves depending on what hour/day the survey took place and how                                                evaluated in this context.
                                many cows had calved at that time.          However, we have been
                                Informed that the figure 50 actually refers to total animals,                                                  The entire discussion of caribou response to development is so
                                mainly cows and calves,       (A. Rappaport,     FWS,   1987, para.                                            focused on a few studies evaluating local, insignificant
                                comm.     Given this Information, there could be       as few as 25                                            responses to disturbance that the authors have failed to
                                c*ws/sq.mi.    (one   per    26   acres),   which    in    not    very                                         appreciate , that caribou elsewhere,         even   In Alaska,       are
                                concentrated.    Even assuminq total        displacement    within a                                           coexisting with significant human developments.
                                "2-mile sphere of Influence", significant numbers of cows would
                                not be displaced (approximately 12,000 cows of approximately                             108 1      2          See discussion under page 105, col. 2. para. S.
                                65.000 cows in the population).
                                                                                                                                               It in doubtful that some measure of displacement into somewhat
                                This table and references to       it should be deleted in their                                               "less desirable" areas will have an effect an productivity.
                                entirety.   If not. the table      must be thoroughly revised to                                               Davis at al. (1985), reporting an the considerable habitat end
                                Indicate that caribou will not be totally excluded from the                                                    sensory disturbances that have occurred In the traditional
         L                      "2-mile sphere of influence"       and the definition of caribou                                               calving grounds of the Delta herd, stated "Again we observed no
                                concentrations must be clarified.                                                                              adverse effects an productivity, indicating that caribou are
                                                                                                                                               more flexible in their selection of calving habitat than
         107 2     2            This paragraph makes    . superficial generalizations about the                                                previously recoqpmised."
                                degree and effects of displacement that do not reflect a full
                                analysis of available Information on the subject. The numerous                           108 1      3          This paragraph In a meaningless description of densities with
                                studies in the Prudhoe Day and Kuparuk areas have resulted       in &                                          no connection to the scology of caribou.
                                considerable pmount of information contained in reports             and
                                papers not apparently consulted (e.g. Fancy 1983, Robus             and                  108 1      4          Overcrowding of the CAB is unlikely to occur. The only records
                                Curatolo 1903, Murphy 1984).                                                                                   of overcrowding refer to populations transplanted to insular
                                                                                                                                               situations lacking predators e.g., reindeer on St. Matthew
                                There is no evidence that caribou ever used the area of             the                                        Island,    muskozen   on   Nunivak    Island.     However,    such an
                                Prudhoe Bay oilfield for a calving ground, and therefore, the                                                  occurrence has never been documented for populations o          f wild
                                lack of calving activity there cannot be taken to mean that                                                    mainland caribou.
                                caribou have been displaced.
                                                                                                                                               The term 'habitat stress' is undefined.         What do the authors
                                As discussed in the General Comments, interpretation of Dau and                                                mean?
                                Cameron's (2985) study is confounded and cannot be used as the
                                basis of a rational impact assessment.       Impact analysis should

                                                      S-57                                                                                                           S-58

               c.                                                                                                             C.

          108 2     4           Dau and Cameron (2985) do not show displacement of 2 miles, but                         110 1      1          The 2-mile interaction area is without proper basis.
                                even if they did, how would that displacement be harmful? Only
                                If displacement Increased mortality would there be an a       ,ffect.                   110 1      2          It might  be noted, that the possibility of calves being trampled
                                Displacement by itself is harmless. See the discussion of Dau                                                 would be highest: when large aggregations are present. This is
                                and Cameron's (198S) work In our general comments.                                                            also the   time when dist  .urbance might cause more calves to be
                                                                                                                                              separated from cows.     Lost calves tend to be very susceptible
          108 2     5           The "core" calving  area concept has to be reconsidered, an does                                              to predator .a.
                                its classification as Resource Category 1.         (See comments on
                                @earlier sectionSO                                                                                            Discussion of  the possible effects of aircraft disturbance (and
                                                                                                                                              other types of disturbance on the calving grounds) on caribou
          1.09 1    2   23      The authors cite    Bell* and Tarvainen (1984) and Davis and                                                  should mention Davis at al. (1985) and        Valkenburg and Davis
                                Valkouburg (1979) out of context. This paragraph discusses                                                    (1985). These investigators found the Delta Caribou Nord to be
                                insect harassment and Its observed effects on caribou during                                                  one of the fastest growing in thei state in spite of
                                the post-calving period on the AM coastal plain. At that                                                      considerable disturbance by aircraft.           They conclude that
                                time and location, caribou are exposed to, harassment by                                                      either the animals have become' habituated to it, or have never
                                mosquitoes.   However, the cited references and descriptions of                                               learned to fear aircraft;-habituation seems the likely answer.
                                extreme    consequences    to   caribou    survival    all    concern
                                infestation by castrid flies. Harassment of Porcupine caribou                                                 Discussion of*enerqy stress and major physiological response 13
                                by oestrid flies occurs later in the sea4so and predominately                                                 vague and   speculative.    It also reflects an apparent belief
                                southeast of the 1002 area after the great majority of caribou                                                that caribou are poorly     adapted to their environment and that
                                have vacated the coastal plain. The issue of insect harassment                                                they areon the brink of     disaster. Caribou, in fact, are well
                                relative to 2002 area development should be kept strictly in                                                  adapted.
                                Its proper context, I.e., relief from mosquitoes, not warble
                                flies and nose buts (oastrid flies).                                                    110 1      2-3        The effects of disturbance will also be partially offset by the
                                                                                                                                              fact that not all areas will be developed concurrently. Many
          109 2     3           The last, sentence implies that PCH animals may not habituate to                                              of the potentially disturbing activities will be relatively
                                oil field developments. Although it may take longer if contact                                                short-term events (e.g., high levels of activities may occur
                                in less frequent, it is logical to assume that PCH animals will                                               along some roads for a few years, but thereafter occur at much
                                habituate to a reasonable degree within a reasonable time to a                                                reduced levels).     Again, it must be stated that the basic
                                variety of activities and facilities based on evidence from all                                               assumption that      All development will occur concurrently
                                other mainland herds. For example the Delta Hord in Alaska has                                                represents a major flaw in the assessment process.
                                habituated to rather extreme disturbance from military activity
                                (Davis and Valkenberg 1985), and the Suohetta Hard in Norway                            111 1      4  7-10    A November I to May 1 limited drilling window is proposed for
                                has adapted to potential barriers including two fences, a major                                               AIM.     For a company to maximize its efforts in the refuge
                                highway used by large trucks,. a -high board snow fence. and a                                                while, minimizing Its costs, It must be able to conduct
                                railroad (Bergerud at al. 1984).                                                                                                    8-60
                                                     B-52

              C.                                                                                                            D.   c.

                                                                                                                            111 2     10            Given the fact that PCH caribou spend little time near the
                               year-round exploration     drilling operations.      under reasonable
                               circumstances, industry     can drill   wells lose than 12,000'. in                                                  coast, there in no reason why facilities should not be located
                               one season and would therefore try       to restrict their activities                                                In this three-mile sane.      Locating facilities that* would, in
                               to winter.     Howeveir, wells deeper than 12,000' require more                                                      fact, significantly reduce the degree of Interaction between
                               time.    If industry in forced to restrict exploratio        Ia drilling                                             caribou and petroleum development.
                               activities to the November I-May 1 window the costs of deeper
                               wells will be ezorbitent - in the range of $50 million each                                  111   2   11            The current practice of placing facilities at least 500 ft from
                               -got operational and logistical reasons. The real disadvantage                                                       a water course has been adequate.. There is so justification
                               in that high costs may limit the number of ezploratory, wells                                                        for 3/4 mile super-buffer zone.
                               that are drilled to 10 or 12 as has been experienced elsewhere
                               in Alaska, e.g. Gulf of Alaska. The complicated nature of the                                112 1     2             The expanding trend of the PCH in the absence of evidence of
                               geology demands that at least 30 wells be drilled If the full                                                        aIvergrasinq. clearly demonstrates that the herd Is not at the
                               Pat, atial of the area Is to be realized. The beat way to find                                                       carrying capacity of the land.
                               hydrocarbons In ANWR In to lower the cost. of drilling and drill
                                                                                                                                                    Nhat in the point of this paragraph?          It is too vague to be
                               moire wells - and the only way to lower costs is to allow
                               year-round drilling.       This sentence should be reworded as                                                       useful.
       T,                      fallowas
         L
                                                                                                                            112 1     3             A major change In      distribution in 2aft possible result of
                               ...Oil exploration,       should be allowed to proceed on a                                                          displacement.   Minor or moderate changes In distribution are
                               year-round basis p      Irovided Industry uses       techniques which                                                two other possible results.         Even if a major chang         a in
                               minimize disturbance of the environment.                                                                             distribution occurs,    it pft M& necessarily DI "...an adverse
                                                                                                                                                    result... ".  Indeed,  given the history and data on the CAN, It
         110 1     4           Given that responses do not automatically translate into                                                             in difficult to imagine that entirely excluding them from the
         111 2     7           negative, biologically significant effects, a flight level of                                                        1002 area (i.e .. ....  a major change in distribution ... ") would
                               2.000 ft for caribou is extreme. It is also unrealistic, given                                                       result in a biologically significant adverse effect on the
                               the commoss occurrence of low ceilings &nd fog.                  A mote                                              population.   It is also difficult to imagine that displacement
                               reasonable approach might be to settle on 500 ft as the                                                              of the PCH will translate into more than minor changes in
                               baseline (responses tend to be moderate at this level), and                                                          distribution.    even    under    full    leasing.      As    long     as
                               then establish flight corridors wherever possible, including                                                         conscientious efforts are made to ensure relatively free
                               instructing pilots flying at lower levels to avoid passing over                                                      movement of the herd (e.g., by elevating pipelines; separating
                               large groups of caribou.         (Notes   during about 4,500 bra of                                                  pipelines    and   roads;    providing     ramps,    if     appropriates
                               Arctic Gas sponsored caribou surveys, Calef's observations of                                                        controlling traffic, if necessary).         There Is no reason to
                               "herding" large groups from altitudes of 2,000 ft were never                                                         expect   any significant      adverse    Impacts    as   a   result of
                               seen, except In cases where the aircraft happened to be flying                                                       development.
                               in the same direction as the caribou were already moving in
                               (D.G. Roseneass, 1987, pers. comm.).]                                                                                                      S-62

                                                       8-61

                 c. 1.                                                                                                           c. 1.

                                  This paragraph contains a very superficial impact analysis that                                                  could lead to a serious population decline.          What is a 20-40
                                  is meaningless.     The whole issue must be revisited making                                                     percent change in distribution?
                                  realistic assumptions and analyzing ecological factors that
                                  affect caribou.                                                                           112 1       5          We agree that the effects on the CAH will be moderate at most,
                                                                                                                                                   but suggest they are more likely to be minor or negligible.
            112 1    3            The percent loss of habitat and acreage figures discussed here                                                   The primary effect could be a slight change           in distributlon
                                  are totally unrealistic and misleading.          Not only are they                                               that in unlikely to translate into a truly biologically
                                  based on worst case development scenarios and the highly                                                         significant effect on the population.         An actual decline In
                                  simplistic     sphere      of  influence"      concept,   but     total                                          numbers Is not likely to occur, even under, full leasing.
                                  displacement   from areas within the "sphere of Influence" which                                                 Indeed. it in reasonable to predict, based an historical data
                                  is -assumed.   it has not  been proven that a 2-mile displacement                                                from the CAR and the biology of caribou, that the CAR will
                                  none around   all facilities in realistic.        If the "sphere of                                              continue to grow In spite of any and all development east of
                                  influence' concept In used to do Impact projections it should                                                    the Canning River.
                                  be properly    defined and supporting evidence cited for each
                                  species to which It Is applied. (See our general comments.)                                                      The analysis of the Impact to the CAB must be reconsidered.

            112  1   4            "Mare may.ba               of relevant experience in estimating
                                  impacts on this hard...",           but information      relevant to
                                  estimating impacts to caribou      could have been used to a much                         112   2     4          McLares and Green (1985) reported the results of a study of
                                  greater extent. We aq      Iree that the estimate of "20-40 percent"                                             experimental disturbance of 'naive' muskozen, The distance at
                                  18 uncertain.     Again, because    there are no convincivg data                                                 which the first animal reacted averaged 345 m. and the distance
                                  suggesting that the herd Is         limited by habitat both the                                                  at which SO% of the herd was alerted averaged 267 m. Two herds
                                  estimate and the possibility of an actual decline in the                                                         that    were    approached     repeatedly     showed    evidence      of
                                  population are not coxvincing. Also, in this paragraph and in                                                    habituation. Muskozen also have easily adapted to captivity.
                                  others,    it   In    implied I  that    changes     in   distribution                                           There in good reason to. expect that the muskozen within the
                                  automatically cause adverse impacts and lead to populat             ton                                          1002 area would habituate to oilfield activities that might
                                  declines.   This is not necessarily the case.         Indeed, if one                                             take place nearby.
                                  considers cari  bou, one might suspect that it is probably not
                                  the . case, except under extreme conditions.             Caribou are                      Ili 2       5 and      N.A. Fraker (pers. comm.) conducted surveys of muskozen in the
                                  especially adaptable to changes in distribution, and they have                            113 1       1          Canadian High Arctic in 1974 and 1975 and observed evidence of
                                  demonstrated this capability repeatedly.                                                                         habituation to aircraft.      His studies were based at Rae Point
                                                                                                                                                   which was the base camp of PanarctiC Oils.                  There was
                                  There in absolutely no basis for predicting a 20-40 percent                                                      considerable     aircraft      traffic,     including      helicopters.
                                  decline In population.         Not even the exaggerated impact                                                   Twin-Otters, DC-3s, Electras, 727s, and 737s.        There was also a
                                  predictions have been logically connected to any mechanism that

                                                         9-6 3                                                                                                           S-64

               C.

                               small herd of muskozen off the        end of the runway.       These                                         population has increased. The exponentially growing population
                               animals sometimes looked up at the aircraft as they passed by,                                               is now calving over relatively large areas.            It Is quite
                               and at other times seemed  to ignore  them completely.                                                       possible that even relatively large amounts of displacement (or
                                                                                                                                            exclusion) from areas currently used by the subpopulation for
                               The effects of disturbance will also be partially offset by the                                              calving may have little effect on either individual or group
                               fact that not all areas will          be developed concurrently.                                             production.   It is agreed that displacement from calving areas
                               Additionally    many potentially disturbing activities will be                                               might have some effect on the muskox, but It is doubtful that
                               relatively short-term events (e.g., high levels of activities                                                it would be of more then minor consequence to the population;
                               may occur along some     roads for a few years, but thereafter                                               long or short term.
                               occur at much reduced   levels). Again, it must be stated that
                               the   basic   assumption    that   all   development    will    occur                  113 2     1           The report of Reynolds and LaPlant does not support the assumed
                               concurrently represents a major flaw in the-assessment process.                                              2-mile sphere of influence.     (Russell (1977) is unavailable to
                                                                                                                                            us.)   Once again the EIS simplistically assumes that the
          113 1    3           Difficulties have been encountered in measuring and even                                                     quantity of real estate translates directly to population
                               detecting the effects of habitat loss and disturbance (in                                                    well-being.
                               particular) an muskozen, (and on other species,             including
                                                                                                                                            "a suggest that the impact analysis be ecologically based.
          L                    caribou).   Using killer and Gunn's (1979) conclusion provides
                               only one side of the story.      Their conclusion is speculative,
                               and to be fair, their statement needs to be paraphrasede          the                  114 11    1           The data on this vigorous population, especially in light of
                               presence of visible responses does not necessarily mean that                                                 the limited amount of surface area that will actually be
                               significant physiological changes or energy drain occur at                                                   affected by development, do not support any predictions of
                               levels sufficient to have major effects (or even moderate                                                    major negative effects on muskozen. Data from this population
                               effects) on the population over time.                                                                        and other transplanted populations in the state suggest that
                                                                                                                                            the present management objective of continued,             naturally
          113  1   3           The   muskox   population    in ANWR    was   recently Introduced                                            regulated growth can be met, regardless of some development an
                               (1969-1970) and is still rapidly expanding.      Their population.                                           1002 lands. The major management effort should be directed at
                               like that of many other Arctic species is far below threshold                                                regulating hunting of the animals.     It is understood that some
                               levels and will remain so as a result of factors other than                                                  hunting of muskox is already allowed in the refuge. It is also
                               habitat.   it Is extremely unlikely that the muskox population                                               interesting to note that part of the population is already
                               will decline as a result of loss of any habitat.                                                             expanding   Into    a    region   containing     development,     the
                                                                                                                                            Sagavanirktok river drainage.
                               Displacement from calving areas   is somehow assumed to translate
                               automatically into negative effects on productivity. That may                                                Just because the Niquanak-Okerokovik-Angun subpopulation Is
                               not be true at all. The animals have demonstrated an ability                                                 somewhat smaller than the other two primary subpopulations, or
                               to expand into and utilize new areas for calving as the                                                      that it currently experiences less immigration.           does not

                                                    S-65                                                                                                         S-66

         V.   C.

                               automatically mean that effects might be more pronounced on                                                   subpopulation and the total Arctic slope population will
                               that subpopulation (assuming development and activities to be                                                 continue to increase for some time.             It is possible to
                               similar in each area). Also, given the expanding nature of the                                                speculate that in spite of some distributional changes or
                               subpopulations, It is reasonable to expect that over the next                                                 occasional mortalities, at some poiht total numbers may plateau
                               few years, the likelihood of both immigration and emigration                                                  at slightly lower levels than if petroleum development had not
                               will increase.                                                                                                occurred.     Even In that event, however, more animals will
                                                                                                                                             probably be   present both during and after development than
         114 1     2           The prediction of a 25-50 percent population decline is                                                       there are today (unless natural events or hunting intercede).
                               surprising given that there in no scientific justification for
                               it.                                                                                     114 2      2          Historically hunting has not been permitted within the North
                                                                                                                                             Slope development areas and workers are not allowed to have
                               It is true that distribution changes may occur under full                                                     firearms.    For production safety reasons     , it in anticipated
                               leasing. However,. development will most realistically proceed                                                that this policy would be applied to development areas within
                               in stages, and not all changes in distribution are likely to                                                  the 1002   area.   All refuge regulations would be followed by
                               occur at one time.       Distributional changes alone may not                                                 petroleum  workers.
                               seriously affect the population.         Given the data on this                         WOLVERINES
                               population, it in not inconceivable that even fairly large
                               shifts in distribution may ultimately be of little consequence
                               to the total population.     It is implied that up to 50% of the                        116 2      5          The logic behind this conclusion of "major effect" is lacking'
                               population may suffer some unspecified form and degree . of                                                   Displacement, avoidance and reduced food arguments are not
                               decline.   This statement is totally unsupported and very                                                     based on sound scientific information.        Additionally, hunting
                               ambiguous.   it is almost   certain to be interpreted to mean a                                               has not been permitted In the North Slope development area and
                               decline in current total    numbers by most readers.      In this a                                           workers are not allowed to have firearms.         It is anticipated
                               decline to some level, or    is It an on-going decline?     Is it a                                           that this policy would continue in the 1002 area for safety
                               decline in productivity,     rate of p opulation growth, or total                                             reasons. All refuge regulations would be followed by petroleum
                               numbers?   A decline in     productivity in 50 percent of the                                                 workers.   If harvest is the major problem, then it should be
                               population may only mean a slower growth rate in the total                                                    controlled by the appropriate regulatory wildlife biologists
                               population. It would not    mean a decline in population numbers                                              and not by prohibiting development.
                               unless the decline occurring in half of the population Is
                               sufficient to offset productivity and recruitment of the other                          POLAR BEAR
                               half.    Acknowledging available data on muskoz population
                               dynamics from these and other transplanted groups, and the                              117 2      8          Development In Block C will have only minor adverse effects, If
                               demonstrated ability of muskozen to expand into and exploit new                                               any, on the continued suitability of the eastern 1002 area for
                               areas, a population decline is unlikely.      in fact, given these                                            polar bear donning.       Developments can be sited away from
                               data, it seems reasonable to predict that both- the ANNE                                                      specific denning habitat such as riverbanks, draws, and leeward

                                                    S-67                                                                                                          S-68

             c.                                                                                                          C. 11,
                              sides of bluffs, where drifting *now    accumulates. Generally it                                           females undoubtedly escaped detection,      the estimate of 12-13
                              is unlikely that many facilities, roads, etc. will be sited in                                              percent suggests that the "ANWR segment" of the 2,000 bear
                              such locations.                                                                                             Beaufort Sea population is very       I small.    Given the      same
                                                                                                                                          Information, and assuming the "ANWR segment" contains some
                                                                                                                                          reasonable number of adult bears (let's say 300 of which 100
        118 1      3          Given adequate  pipeline elevation, it is unlikely that, once
                              in place, they  will act as barriers to the movement of female                                              might be po  .tontial breading females), the estimate. of '12-13
                              polar bears.                                                                                                percent seems unreasonably high.
        118  1     3          True, some reduction in the availability of donning habitat                           118   1   3           Given what is known about the Alaskan and the Yukon coast,
                              might occur, if production facilities were poorly sited.                                                    Including information provided by local residents and available
                              However, the resulting reduction should not be termed "major".                                              data on donning, donning habitat and terrain, it is very
                              The assessment assumes total exclusion of donning over the                                                  doubtful that an "...especially significant area..." far
                              long-term which is not likely. Availability of some habitat                                                 denning will ever be found on land (including south of
                                                                                                                                          Demarcation Day). The vast majority of female polar bears will
                              within coastal donning areas may be reduced in the short-term.
                              However, It Is not unreasonable to speculate that bears will                                                continue to don offshore, just as they probably always have.
                              rouse some areas after production facilities are In place and
                              construction activities completed. This is just one example In                                              If the implications of this paragraph are correct -- i.e., that
                                                                                                                                          the mortality of female polar bears is close to the maximum the
       09                     the   Section   1002    report   where   the    impact    assessment                                        entire Beaufort See population can sustain, and at a level
                              unrealistically assumes "concurrent development" throughout the
                              1002 area while failing to take Into account the duration of                                                where the annual lose of cubs from one or two dens and a few
                              some events -- e.g., all roads are apparently always assumed to                                             adult females might cause the entire Beaufort population to
                              have high levels of activity on them when In fact some roads                                                begin decreasing along the ANKH coast -- then it follows that
                              will almost certainly have much reduced traffic on them after                                               aIubsistence hunting of females must be carefully watched, and
                              production systems are brought on line.                                                                     perhaps even controlled or stopped.

        118 1      3           ... the 12-13 pe rcent of females donning on land..."           Does                 118 2     2           Caribou should be considered in addition to polar bear when
                              this represent the percentage of the total females in the "ANWR                                             siting/orienting pipelines and roads at right angles to the
                              segment" of the Beaufort Sea population that den on land, or                                                coast in some coastal areas (e.g., Camden Bay).
                              does it represent the percentage of #&nl found on land during
                              1983-1985 (see p. 33 -- 87% of dens found offshore)7           Given                  118 2     4           It is not reasonable to classify the exclusion of only one or
                              that only some relatively small, localized areas on the ANWR                                                two bears from consistently used denning areas as more than a
                              coastal plain provide suitable donning habitat, the number of                                               minor impact.     It is difficult to believe, that such minor
                              dens that have been found on land in any one year (1-2, even in                                             exclusion will be of real biological significance to the ANWR
                              recent years when considerably more effort has been made to                                                 segment of    the Beaufort Sea polar bear population (and
                              find them), and allowing for the fact that a few other denning                                              certainly not to the Beaufort Sea population as a whole).          If
                                                   S-69                                                                                                        S-70

                                                                                                                                C.

                                  the ANWR segment is thought important in terms of the Beaufort                                                 variable.    Virtually all studies conducted so far have shown
                                  Sea population,    and is so      precariously balanced between                                                that snow geese flush away from approaching aircraft flying at
                                  mortality of females and recruitment as to sustain more than a                                                 altitudes up to 10,000 feet (Salter and Davis 1974, Davis and
                                  minor impact from such a potentially             small   decline     in                                        Wisely 1974).
                                  reproduction rate (i.e., the output of one or two adult females
                                  annually), then there seems to be little question that any                               120 1      2   6-7    If these estimates     are accurate, the area influenced       will be
                                  current harvest of females of any age should be stopped.                                                       about 12.7 thousand   acres, or about 1% of the total 1.5       million
                                  Declines in reproductive rates     as measured in terms of output                                              acres of coastal plain in the 1002 area.           This seems   like a
                                  of a few. individuals, do not always translate into declines In                                                very low percentage, considering the peripheral influences that
                                  populations.   Even with relatively small populations (as in                                                   no doubt will occur if the birds are affected by increased air
                                  this case), survivability of cubs might be a more important                                                    traffic in the area.
                                  factor.

                                                                                                                           SWANS, GEESE AND DUCKS

           lie 2     4    11-16   Again, the arguments here are not convincing that the        exclusion
                                  of one or two females, from donning areas (even assuming total                           120 1      3   5-7    Other studies that are not documented (e.g., Johnson 1984b,
                                  fidelity of individuals to specific areas) could have more than                                                Doughtery 1979    indicate that if proper mitigation programs. are
                                  minor impact on the population.      If the population is Indeed so                                            initiated, productivity of waterfowl (especially common eiders
                                  precariously balanced, then past and current general lack of                                                   and probably black brant) actually may increase in areas of
                                  management of subsisteace harvests may be the real cause. That                                                 industrial development.
                                  "...similar ... intensive    developments  ... along    the     entire
                                  northern 'coast of Alaska and Cat.ada     ... ** will occur does not                     120 1      3   8-10   This could be the single most important and profound influence
                                  seem very likely. Other developments might occur somewhere in                                                  on birds of 1002 development.         Snow geese do interrupt fall
                                  the vast area, but not all sections of the coast are of high                                                   feeding and do flush at the approach of aircraft flying at
                                  petroleum potential.     Even the   development scenario used for                                              altitudes an high an 10,000 feet (see p. 119, c.2, 1 6, 1. 6-8).
                                  impact analyses In this report      Is acknowledged. by the authors
                                  to be a worst case scenario and     very unlikely.      Realistically,                                         It will be important to maintain strict aircraft corridors
                                  if other developments were to        occur, the resulting pattern                                              (preferably close to the coast, but not right along it) during
                                  would probably resemble the wide     spacing found between current                                             the 30-45 day fall staging period for lesser snow geese (15
                                  and abandoned DEN Line facilities rather than continuous                                                       August to 15-30 September);
                                  complexes of  active facilities, pip6lices and roads.
                                                                                                                           120   1    5   6-13   Wright and Fancy (1980) suggested that the increased mortality
                                                                                                                                                 on waterfowl nests at Pt.     Thomso n may have been caused by foxes
                                                                                                                                                 following human scent to      bird nests in the two      study areas,
            119  2    6   6-8     The meaning    of this   sentence is    uticlear.   The response of                                            rather than as a result      of poor housekeeping at      the drilling
                                  fall-staging   snow geese  to aircraft overflights is. not highly                                              camp.

                                                                                                                                                                       S-72

               C. 1.                                                                                                     C. 1.

          120 1     6  1       There  is a possibility that a major spill could kill                                SEABIRDS AND SHOREBIRDS
                               waterfowl. Based on the history of Incident in PBU, however,
                               this is not likely to be the case unless a large oil spill                           123 1     4  6-7     Regarding the mortality of birds due to strikes with towers,
                               occurs very early in the season contaminating large areas of                                              antennas, wires, and other structures, the only work done on
                               first-of-the-season open-water. Based on analysis In spill                                                this subject for the North Slope has been in the Lisburne
                               contingency plans for the area, it is unlikely that even if a                                             Field.    The   Lisburne Field Monitoring report         should be
                               catastrophic incident occurred and waterfowl were oiled and                                               referenced as well as the small number of actual bird
                               subsequently died, that effects to the bird population could be                                           fatalities.   A comparison of the lower 48 mortality rates would
                               measured. This is stated in the ADEC analysis on the seasonal                                             also be useful.
                               drilling restrictions made In June 1984 (Final Finding and
                               Decision of the Commissioners      g2garding the oil industry',                      RAPTORS
                               Capability to Clean Ug Spilled Oil during Broken lea Periods in
                               the Alaska Beaufort Sea), as well as many other references.                          123 2     3  1-3     There in experimental evidence contrary to these statements.
                                                                                                                                         Ellis (1981) conducted extensive experiments for the U.S. Fish
          121 2     4  12-14   We suggest revo  .rding the last sentence in this paragraph, as                                           and Wildlife Service and the U.S. Air Force concerning the
                               followst  "The judicious placement of transportation corridors                                            effects of supersonic military jet flights (with sonic booms)
                                                                                                                                         near nesting peregrine and prairie falcons in Arizona.            He
          L                    south of coastal tundra swan nesting areas and away from snow                                             found that negative responses by falcons were brief and never
                               goose staging area.a would be particularly Important."                                                    limited productivity.     He concluded that "the birds were
                                                                                                                                         incredibly tolerant of stimulus loads which would likely be
          122 2     1          There in no justification for the statement concluding that
                               "..displacement of these geese from 45 percent of their                                                   unacceptable to humans."
                               preferred staging habitat, a reduction In the Banks Island
                               population or change in distribution of an average of 5-10                           123 2     3          Raptors are not "...acutely sensitive to disturbance ... ". This
                               percent could occur."    First, there to no explanation of how                                            grossly overstates the case.        Indeed, the entire issue of
                               the displacement translates directly to changes in distribution                                           disturbance to raptors has been blown out of proportion In
                               or population also.    Second, we strongly disagree with the                                              recent years.     Many "potential" effects have been imagined
                               wording that equates a change in distribution to a change in                                              (often with little actual knowledge of the birds' behavior),
                               population size, especially a change of " ... 5-10 percent...".                                           but few have been realixed, and few are supported by data.
                               Davis and Wisely (1974) showed that snow geese did accommodate                                            Over   the   years,   the   repetitive    process    of    compiling
                               to aircraft traffic on the North Slope of the Yuko    .n Territory;                                       environmental assessments has resulted    in some of the potential
                               there is no reason to assume that accommodation will not occur                                            effects taking on more than their fair share of reality.         The
                               in the 1002 area of Alaska.                                                                               more fact that birds are "disturbed" and respond in some way,
                                                                                                                                         even repeatedly, should not be interpreted to mean that the
                                                                                                                                         birds will typically abandon nests or that there will be a
                                                                                                                                         biologically significant effect.     Indeed, if this were true,

                                                   S-73                                                                                                       S-74

               C,                                                                                                         C.

                               there would   not be a    large, robust,    growing population of                                           approximately 1/4 mile of actual "buffer".        To be safe. the
                               peregrine    falcons    nesting    successfully    along     heavily                                        Alaskan Peregrine Falcon Recovery Team decided to increase that
                               commercially fished sections of   the Yukon River. On the Yukon.                                            buffer further. and recommended a I mile buffer zone.          Later,
                               many pairs nest successfully within a few hundred feet of                                                   based on the tendency to believe that "more is better", a new 2
                               fishwheels, , set-nets and heavy boat traffic, and often within                                             mile component was added to the I mile buffer zone for certain
                               1/4 mile of camps and villages, where they are typically                                                    activities.     In  recent years,    authors of various impact
                               disturbed several     times a day.      Again,   if raptors were                                            statements and  operational stipulations have begun interpreting
                               "...acutely sensitive to disturbance...", how would one explain                                             the current buffer z    .ones as areas within which the nesting
                               that on. the Seward Peninsula, gyrfalcons and rough-legged hawks                                            birds will. automatically respond In some detrimental way to     any
                               commonly nest on cl .iffs along road corridors, and in in close                                             activities   barely crossing into those         zones.    This   has
                               proximity to active mining operations.      It is quite true that                                           apparently happened because of a      lack of familiarity of     the
                               repeated harassment can cause abandonment of nests, but these                                               definition, and logic supporting the original sizes of           the
                               birds clearly exhibit a great deal of tolerance to a variety of                                             buffer zones for raptors.        In  other words,     there is no
                               situations, especially to those activities not specifically                                                 recognition of the considerable       "buffer" distance that     had
                               directed at them. Distances at which repeated disturbance may                                               previously been incorporated.     If the recommended buffer zones
                               actually begin to take a toll tend to be relatively short. If                                               are incorrectly interpreted to mean           that the birds     are
                               the birds are nesting in high -superior" positions, or are                                                  disturbed when these lines are crossed,       then it follows that
                               naturaliv buffered bv terrain features the distance          between                                        people might Incorrectly assume that these birds, raptors, must
                                           a nearby' activity can be surprisingly short.
                               them and                                                                                                    be 3m= sensitive to "disturbance".        In general, this is not
                               Generally, for a disturbance to have real biological effectson                                              true at all.
                               pairs .of raptore (and especially on populations), the activity
                               must bei at close range (usually within a few hundred yards), or                                            The Terror Lake   rough-log example   is not especially convincing
                               be specifically directed at the birds. It is hardly surprising                                              because numbers of nesting rough-legs can and do change
                               that gyrfalcons nested within one mile of an active airstrip in                                             abruptly from     year-to-year.     Given the number of years
                               NPRA.   One might trace perceptions that raptors, such as                                                   involved, it is   also possible that fewer birds nested in the
                               gyrfalcons and peregrines, are "acutely sensitive" to being                                                 area because of   natural events.     Extreme caution must be used
                               disturbed to' the fact that people either do not know, or have                                              when interpreting observations like these.      Is there any solid
                               forgotten, that buffer zones originally recommended to protect                                              data backing up the supposition that the hiatus in nesting was
                               nest sites were just that -- buffer zones. When the concept of                                              actually caused by construction activities? if the pairs' nest
                               a-buifer zone was first created, peregrine falcon experts took                                              sites were located very close to the activities then there may
                               into account the   .distances at which birds would usually become                                           very well be a valid relationship.         If the nest sites were
                               defensive and stay away from eggs and chicks.     Then, to "err on                                          located farther afield, especially beyond 1/2 mile, then
                               the side of caution", they doubled, or even tripled that                                                    possible relationships become questionable.       [Comment provided
                               distance. For example, the original recommendation to restrict                                              by D.G. Roseneau, 1987, pore. comm.]
                               activities    within   1/2   mile    Of   active. nests     included

                                                    S-75                                                                                                         S-76

         R.    Q, 1,                                                                                                   P.   c.
         123   2   5           It is agreed that adverse effects to reptors would be minor.                                                  grounds may well reflect (at least in part) the difference in
                                                                                                                                             the locations of the herds' ranges relative to the Apring
         123   2   6 and       Given the number of subadult golden eagles vs. the size of the                                                migratory routes of the eagles.       Most golden eagles migrating
         124   1   1           calving element of the PCH (even assuming double or triple the                                                into interior and northern Alaska, and the central and northern
                               current eagle population estimates), there would have to be a                                                 Yukon Territory, pass through     . the Whitehorse area into the
                               very major decline in PCH before one can realistically imagine                                                upper Tanana and Yukon river drainages.         The timing is such
                               more than a minor Impact occUrring to golden eagles.                if                                        that many arriving subadult eagles have good chances of
                               changes occurred in the distribution of the PCH, the subadult                                                 contacting elements of the PCH during its spring migration
                               eagles could (and almost certainly would) easily shift their                                                  'northward out of central Yukon wintering grounds.          In years
                               distribution to match the. PCH distribution, just as they almost                                              when the PCH winters almost entirely in the Chandalar district
                               certainly do when distribution of the PCH varies naturally.                                                   of Alaska, many eagles might still tend to contact this herd
                               (D.C. Roseaeau, 1987, porn. comm.)                                                                            before   filtering    westward    throughout. the     Brooks    Range.
                                                                                                                                             Subadult eagles are not headed for eyrie sites and may tend to
         124 2     Concl.      Changes in the atwibution of subadult eagles resulting from                                                   wander,   a reflection of their opportunistic tendencies.
                               changes In the -stribution of the PCH are unlikely to be of                                                   Subadult eagles. arriving north of the St. Elias an4i "Laska
                               biological consequence to the saglis population. Changes would                                                ranges, may be attracted to and "short-stopped" by caribou
        T,                     have no greater significance than those observed under natural                                                Inhabiting the central         and  northern    Yukon    (PCH).    and
                               conditions In re spouse to annual variations in PCH distribution                                              east-central and northeastern Alaska (Fortymile Hard and PCH).
                               (subadult eagles are highly mobile, see above comment). Given                                                 instead of passing over this large accessible potential prey
                               the number of subadult golden eagles that are usually present                                                 base and continuing towards western Alaska, the subadult eagles
                               it is not reasonable to expect any decline in their numbers                                                   say stop and closely follow the movements of the PCH and
                               unless there in a very large decline In the size of the caribou                                               Fortymile Bard.     Currently, fewer golden eagles appear to
                               herd. The ratio of these highly mobile nonbreeding predators                                                  frequent the range of the rortymile Herd than frequent the
                               to the migrating prey base (i.e., caribou) in verl large.           it,                                       range of the PCH. If the Fortymile Hard were to Increase again
                               Is also doubtful that there Is a Alrect l1near relationshl                                                    by several tons of thousands of animals, more eagles would
                               between the size of the PCH and the number of subadult eagles                                                 probably attend it.      However, If the herd were to continue
                               preying an it. From all reports, and from genera      I observations                                          increasing, doubling, tripling, or quadrupling in size, one
                               (mid-19709 to present), the large Western Arctic Herd (WAR)                                                   might expect concurrent increases in eagles to become ever
                               appears to have fewer subadult eagles associated with it even                                                 smaller, and for their numbers to eventually "stabilize".
                               though there are large numbers of adult golden eagles nesting                                                 fluctuating   in response      to other factors,      regardless of
                               in portions of the Colville-Utukok-Xokolik-Kukpowruk uplands                                                  Increasing herd size.      [It In interesting to note that the
                               and western Brooks Range.      If this difference in numbers of                                               current estimates of the number of subadult eagles frequenting
                               subadults between the two areas is as real an available                                                       the PCH calving grounds do not appear to be much different from
                               information suggests, the difference between the number of                                                    rough estimates made In the mid-1970s, when the PCH was
                               subadults frequenting the WAR and PCH calving and post-calving                                                smaller.]    (Comment provided by D.G. Roseneau, 1987, pore.
                                                    S-77                                                                                     comm.)
                                                                                                                                                                   S-78

           R_   c.                                                                                                     P.   c, 1.

                                                                                                                       SUMMARY OF RECOMMENDED MITIGATION FOR THE 1002 ARE

           125  1    3          The tone of the impact assessment is one of overstatement. Key                         Pages 145-147
                                fish issues are (1) winter water withdrawal. (2) adequacy of
                                culverts for fish passage (this was the conclusion of the study                        Stipulation I         We  support   the concept of consolidating          facilities    and
                                of klyeaka Pipeline impa.   .cts to aquatic environments (Aquatic                                            designing   all    structures    to   minimize   effects    on    the
                                .Environments Ltd.    1905)],    and   (3)   disturbance   of    fish                                        environment.   No suggest modifying this stipulation to read:
                                overwintering habitats.                                                                                      "...Locate nonessential facilities Putside caribou calving
                                                                                                                                             areas where feasible and Rrudent."

           125 2     1          Loss of fresh water       fish habitat will be minor.          Direct
                                mortalities  will be few, at most, and will not significantly                          Stipulation 2         This is a standard engineering practi   ce; however, it should be
                                affect the fish populations.      Not considered here in that the                                            recognized that other factors will be involved in the final
                                creation of gravel pit water sources and other reservoirs may                                                design criteria for each structure.        He suggest adding the
                                provide increased productive fish habitat.                                                                   words "feasible and urudent" to the end of the sentence.

           12S 2     2   4      Sticklebacks   are one of the more successful freshwater fishes                        Stipulation 3         Gravel sources are prevalent throughout the 1002 area. Gravel

                                in the Arctic, both in terms of widespread distribution and
         21                                                                                                                                  may provide.  in a any cases the most feasible option from an
                                abundance. We arm not aware of any study which has found them                                                operational and economic standpoint.      It is not reasonable to
         -A                     to be an "important   food  source" for other fish.   They are very                                          limit the use of gravel for exploration wells, especially those
                                poor swimmers compared. to salmonids.      It is no .t reasonable to                                         deeper th  .an 12,000' that cannot be completed during the
                                                                                                                                             November I-May 15 period.       The "thin pad" concept can be
                                require that culverts be designed for stickleback passage.
                                Culverts should be designed for passage of key fish species                                                  utilized to minimize gravel quantities.             He suggest the
                                identified because of their economic or subsistence value.                                                   following wordingi       "The use of gravel         for . exploration
                                                                                                                                             operations should be minimized where feasible and prudent."

           EFFECTS ON SOCIOECONOMIC ZVVIRO1D9=
                                                                                                                       Stipulation 4         Rehabilition plane are included as a section of the Exploration
           125 2     6          The I economic benefits, given     the North Slope Borough CIP                                               Plan of Operations.
                                Program and taxation, should be explained.
                                                                                                                       Stipulation 5         Change the word "prohib    It" to "restrict."       Maintenance and
           SUMMARY                   4PACTS, ALTERNATIVE A                                                                                   spi.11 response require access. An. in the PRO this access can
                                                                                                                                             be restricted to protect the active layer of the tundra during.
           131-132              Rather then comment on this summary we refer you to          comments                                        certain times of the year.         in PSU all off-tundra travel
                                already provided In the detailed sections.                                                                   involves specially designed and approved vehicles to minimize
                                                                                                                                             ,surface Impacts; operations arethen conducted by permit     only.

                                                      S-79                                                                                                         S-80

          R.  C.                                                                                                         c.

          Stipulation 6       Under  reasonable circumstances, wells less than 12,0001 can be                       Stipulation 9        There are several problems with caribou        ramps that must -be
                              drilled In one season and Industry would try to restrict their                                             understood. When ramps are used, pipelines are usually at an
                              the operation to winter. Deeper wells will require more time,                                              Intermediate height, forcing many caribou to         use the ramps
                              and there is     no logistical or operational reason drillin       g                                       rather than   cross under the pipe.      To allow   the passage of
                              should not be allowed to continue into summer.                                                             large numbers of animals, ramps would have to be very wide, and
                                                                                                                                         the situation could still present some difficulty. The other
                              Allowing operations on a year-round basis will considerably                                                problem is that the convergence of the romp and pipe creates
                              reduce costs. Exploration costs will figure prominently into                                               visual -barrier that could cause a local avoidance response.
                              the ultimate success of any exploratory effort In ANWR because                                             The beat option is to design a uniformly elevated pipeline
                              It will dictate the number of exploratory wells that are                                                   wherever feasible and prud.ents and where elevated pipelines are
                              ultimately drilled.     The recent RIC well, for example, was                                              not possible, ramps should include wide "fans".
                              14,000', required two seasons to drill and cost approximately
                              $50 million.   if costs remain this high, it is fair to predict                       Stipulation 10       We support, this In theory, but for operational and maintenance
                              that less th-, a doxen wells will ever be drilled in ANWR                                                  reasons it may not always be the beat or safest option. Spill
                              unless an early discovery in made. The complicated nature of                                               detection and surface access will play significantly in the
                              the geology demands that if the full potential of ARWR     in to be                                        design of oil transport structures. This stipulation should be
                              realised, Industry will have to drill.30 plus wells. Recent                                                modified to readi Bury pipelines where feasible and prudent.
          A
                              examples of  exploratory efforts limited by costs and lack of
                              ecoureging results include the Gulf of Alaska, Lower            Cook                  Stipulation 11       Typoa,   terrain,   caribo .    This mitigative point Is not
                              Inlet. Bavaria Basin and  ,Offshore Beaufort Sea, where only    6-20                                       consistent with NSB permitting policies concerning the need for.
                              wells were drilled in each area.                                                                           pipeline maintenance roads to allow for periodic inspection and
                                                                                                                                         saints ... ce 'of lines for spills and spill response.            In
                              We suggest that this stipulation be revised as followas "Oil                                               addition, this stipulation is Inconsistent with the stipulation
                              exploration should be-a2lowed year-round except In those areas                                             2 and other sections of the report which requires consolidation
                              where summer activity would have a significant adverse impact                                              of facilities by using roads as construction work pads for
                              on wildlife populations."                                                                                  pipelines. The edge of the road should be no more than 30 ft.
                                                                                                                                         from the furthest pipe for side boom stringing.

          Stipulation 7       We suggest that gravel removal    and water removal   be addressed
                              separately recognizing the different regulatory authorities                           Stipulation 12       This stipulation in surprising since the farther south oil
                                                                   r
                              covering each action.     The habitat issues are different and                                             field facilities are sited, the greater the potential exposure
                              should be mitigated on both a seasonal and case by case basis.                                             of calving caribou to those facilities, and the greater the
                                                                                                                                         contact with migrating herds.

          Stipulation 8       We fully support  this stipulation.
                                                                                                                                         We suggest any stipulation on the location of facilities be
                                                                                                                                         deleted.   The issue will be evaluated during the SIS process

                                                   S-81                                                                                                       S-82

           R,    C,  1,                                                                                                      c, 1.

                                 following a discovery when the location of the oil is also                             Stipulation Is        This stipulation should be modified to readt       "Survey suitable
                                 known.   If a decision must be made at this juncture regarding                                               habitat in the area of operations annually to locate nesting
                                 the location of surface facilities, we suggest for biological                                                peregrInes and other raptors."
                                 reasons that they be clustered an close to the Beaufort Sea as
                                 feasible.   (The concept of minimizing contact with caribou as                         Stipulation 19        This' stipulation should be, modified to read:         "Monitor for
                                                                                                                                              female polar bear in the area of operations."
                                 much an possible by keeping structures as close as possible to
                                 the coast@wax the primary conclusion of a six-year mitigation
                                 study undertaken   for the Arctic Gas Project.       The basis for                     Stipulation 20        Construction of development facilities will have to be allowed
                                 this conclusions   was, that nearly all contact with calving                                                 on a y ear-round basis.    Construction of exploration locations
                                 animals would be   eliminated,  and any contact that might occur                                             wIIII have to be authorized In October, even near the coast, if
                                 would be limited  to brief encounters.]                                                                      they are to be drilled during the Novembe        -r I-May 15 winter
                                                                                                                                              drilling window. This atipula.tion,should be deleted.

                                 There are engineering problems inherent in siting facilities
                                 very close to the coast, so we suggest the following wordings                          Stipulation 21        Historically the possession 'of firearms has     been prohibited in
                                 "Oilfield support facilities should be clustered an close to                                                 the vicinity of olifield facilities.
                                 the   coast     an  feasible    and   prudent.    consistent     with
                                 environmental     hazard    considerat.ions.   Long     uninterupted                   Stipulation 21        This species in not legallk protected and there in no data
                                 distances should be maintained between support,clusterx."                                                    suggesting that it has ever. been threate    .nod by. development.
                                                                                                                                              (ase comissat, p. .23, cal. 2, 1 4a) This stipulation should be
           Stipulation 13        Monitoring programs must be kept highly focused if they are to                                               deleted.
                                 provide useful information.
                                                                                                                        Stipulation 24        It may be administratively efficient to establish a performance
           Stipulation 14        This stipulation should be      modified to    require a 500 ft.                                             standard stating that there should be no changes in lagoon
                                 setback from major,rive  .re and a 100-ft. setback from all other                                            water chemistry as a result of development,            however,    in
                                 fish hearing streams and lakes in accordance with current State                                              practice   this   is   not    a  feasible   or   prudent    standard.
                                 standards that have proved effective.                                                                        Basically, it Is easy to characterize the coastal waters in
                                                                                                                                              terms of what in expected under certain river discharge flow
           Stipulation 15        No recommend separate altitude restrictions for large and small                                              conditions, and wind velocities, whether it is early seasonor
                                 aircraft.   For small aircraft, a minimum altitude restriction                                               late season.    However, the occurrence of these conditions is
                                 Of 1,000 ft. AGL is adequate.      We also recommend establishing                                            extremely variable both temporally and Spatially.. This makes
                                 corridors.for very low altitude flights during fog conditions.                                               it difficult to describe specifically what the water quality
                                                                                                                                              characteristics will be. in a given area at a given time.
           Stipu ,lation 16      See the comment on raptors (page 123, col.2) provided by 0. G.                                               Therefore, with the inabili   .ty to determine the **baseline" water
                                 Roseneass. A I-mile buffer should be adequate.                                                               quality to an exact salinity and temperature, it would be
                                                                                                                                              difficult at beat to establish a causal linkage between a

                                                       S-83                                                                                                        S-84

          R.    c. 1.                                                                                                       c, 1.
                                development    activity    and    an   observed    water     quality                   Stipulation 26       Rather than establish another set of flight altitudes and area
                                condition--the water quality might vary naturally within the                                                closures, we suggest creating flight corridors and setting
                                range that in observed post-development.                                                                    altitude minimums at 1,500' for large aircraft and 1,000' for
                                                                                                                                            small aircraft.

                                The coastal waters of the Beaufort Sea are characterized as
                                being estuarine because of the Interaction and mixing of the                           Stipulation 27       This suggests that all camps and pump stations must be fenced.
                                marine ocean   waters with the freshwater discharges of rivers                                              Fencing causes excessive snow drifting which can significantly
                                and streams. The coastal waters of Simpson Lagoon were studied                                              obstruct surface facilities and access points, obscure spills
                                in the 1970a and the Prudhoe Bay/Gwydyr Bay waters in the                                                   from detection, cause excess spring ponding and require excess
                                mid-Beaufort   are& have been studied intensively since 1981.                                               operation time and equipment for maintenance.          Delete this
                                This habitat   is beat described an an "ecotone" between the                                                stipulation.

                                marine   and   freshwater ecosystems.      At certain times and
                                locations the  boundary between the marine and freshwater masses                       Stipulation 30       Control, use and disposal of fuel and hazardous wastes will be
                                is distinct,   fairly narrow (in terms of distance seaward from                                             in accordance with state and federal regulations.        We suggest
                                the shore) and may be evident from froth lines on the surface.                                              the following wording:     "Provide plans for control, use, and
                                At other times and locations, the boundary may be broad, such                                               disposal of fuel and hazardous wastes in accordance with state
                                                                                                                                            and federal regulations.,,
                                as in Simpson Lagoon, where mixing has occurred and the water
         -4                     maa* in somewhat enclosed. This ecotone is extremely variable
                                in time and spacew perhaps more so than other habitats because                         Stipulation 31       Numerous state and federal laws regulate the handling of
                                of its strong three dimensional character.       It is a boundary                                           hazardous wastes. This stipulation should be changed to read:
                                condition that expands and contracts seasonally, even daily or                                              "Provide treatment storage and disposal of hazardous wastes in
                                hourly, with.anow and rainfall, wind speed and direction, river                                             accordance with federal and state laws and regulations."
                                discharge, etc. The annual variability in similarly large, and
                                has produced the descriptive phrase, "a typical atypical year
                                in the arctic".                                                                                       COMM VII OIL AM GAS -- NATIONAL mm Fog ymsn
                                                                                                                                        SOURCES AND THE 1002 AREA'S POTENTIAL CONTRIBUrl

          Stipulation 25        Eliminate time and area closures/ restrictions so exploration
                                and development operations can be conducted on a year-round                            The authors are to be commended for a lucid and concise summation of the 1002
                                basis.   Certain construction work such as placement and                               area's potential contribution to the national need for oil and gas. The account is
                                compactio n of unfrozen gravel must be carried out during the                          conservative in that it focuses on the impact of the mean conditional resource
                                July-mid-September period.    Also, field production operations                        estimate of 3.2 billion barrels of recoverable oil for the full leasing
                                must continue on a year-round basis.                                                   alternative. It would also have been appropriate to show the Impact of the 5% case
                                                                                                                       and the high end economic scenario.

                                                     S-85                                                                                                       S-86

           R_     c. 1.                                                                                                R,   C,
           New.significant  medium and long-term economic trend    .a have been induced in the past                         4.  Review of     the existing regulatory framework and standard industry
           IS months by the oil price collapse. Because of this and the resultant depression                                    practices in Arctic Alaska that accomplish environmental mitigation, and
           in the U.S. domestic oil industry, the trends projected for domestic oil production                                  revision of the impact conclusions and mitigation recommendations to
                                                                                                                                reflect the same;
           and imports may be significantly worse than shown In Table VII-2. The figure for
           domestic oil production of 8.2 million barrels per day in the year 2000 is very
                                                                                                                            5.  Revision of the development scenarios reflecting a more sequential             and
           optimistic.   Oil imports may be as much as 70% of domestic oil needs by the year
                                                                                                                                staggered series of field developments rather than the assumed concurrent
           2000, not 47% as projected in Table V11-2.        Because of.declining U.S. production
                                                                                                                                development of 3 major fields@ and revision of the impact conclusions to
           (the U ,S. is the world's largest oil consumer and importer) and similar declines in
           Von-OPEC sources (e.g. North- Sea) even modest    increases in consumption growth rates                              reflect the sames and
           will eventially put significant upward pressure on oil prices.             Higher. price
           scenarios (in real dollars) should not be discounted                                                             6.  Update of Chapter V11 to reflect the, impacts of 1986 price collapse an
                                                                                                                                future U.S. energy situation and the contribution          of ANWR's Potential
         ,.The Department    of Energy in revising its petroleum          forecasts which will be                               petroleum resources
           published in a  report in February 1987. We recommend that Chapter       VII be revised
           to incorporate  those findings which should reflect the factors discussed above.

                                    STANDARD OIL COMPANY               lam
          4                                                 RE)COMWEIMATIONS

           The drift 1002 draft report will establish        a basis for    the compilation    of a
           credible final report to Congress supporting      full. leasing  (Alternative A) of the
           ANNE Coastal Plain with the following recommended revisLonst

                  1. A critical review of the applicability'of the USFWS Mitigation policy as
                    applied to the North Slope of Alaska and the major species of concern
                    caribou, muskozen, polar bear, snow geese, and arctic chari

                  2. Revision of. the impact assessment methodology to evaluate the population
                    limiting factors on caribou and other:wildlife species of concern;

                  3. Re-evaluation (and   additional literature research) of the baseline data
                    and impact.analyses relating to caribou, including the "core calving area"
                    concept, the "sphere of influence" hypothesis, the interaction of wildlife
                    with oil field facilities, and the -importance of insect relief areas to
                    caribou during their annual migration cycle;
                                                     6-87                                                                                                         S-88

                                                  LITERATURE CITED                                                            Beak Consultants Ltd. 1976. A study of the influence of seismic exploration
                                                                                                                                        on muskozen and caribou on Banks Island, N.W.T.           Unpubl. rep. for
                                                                                                                                        Panarctic Oils Ltd. Calgary. 267 pp.
               ADEC (Alaska Department of Environmental Conservation) and ADNR (Alaska
                         Department of Natural Resources).      1984. Final Finding and Decision                              Bellrose, F.C. 1976. Ducks, goose, and swans of North America. Stackpole
                         of the Commissioners Regarding the Oil Industry's Capability to Clean                                          Books, Harrisburg, PA. 543 pp.
                         Up Spilled Oil During Broken lee Periods in the Alaska Beaufort Sea.
                         Juneau. 41 pp.                                                                                       Bents, P.J. 1985. Observations and banding of peregrine falcons (Falco
                                                                                                                                        peregrings) and other raptors on the middle and lower Yukon River,
               ASCE (Arctic Slope Consulting Engineers). 1986. The Arctic national Wildlife                                             Alaska, 1965.    Unpbl. rep. by SE24 for USFWS Office of Endangered
                         Refuge.   Its people, wildlife resources, and oil and gas potential.                                           Species, Anchorage. 26 pp.
                         Anchorage. 38 pp.
                                                                                                                              Bents, P.J., D.G. Roseneau, and A.M. Springer. 1982. Numbers, status and
               Banfleld, A.W.F. 1954. Preliminary investigation of the barren-ground                                                    diets of peregrine falcons (Falco veregrinus). and observations of
                         caribou.    Part Is Former and present distribution, migration and                                             other raptors and ravens on the middle and lower Yukon River, Alaska,
                         status. Can. Wildl. Serv. Manage. Bull., Ser. 1, No. IOA.                                                      1982. Unpl. rep by Falco Enterprises, Fairbanks, for        USFWS Office of
                                                                                                                                        Endangered Species, Anchorage. 22 pp.
               Bartels,  R.F. 1973.     Bird survey techniques on Alaska's north coast. Unpub.
                         M.Sc. thesis.' Iowa State Univ. Ames, Iowa 47 pp.                                                    Bents, P.J., D.G. Roseneau, and A.M. Springer. 1983. Numbers, status and
                                                                                                                                        diets of peregrine falcons (Falco veregrinus), and observations of
               Bartels,  R.F. and N.J. Zellhoefer. 1983. Migratory bird use of the coastal                                              other raptors and ravens on the Middle and lower Yukon River, Alaska,
                         lagoon system of the Beaufort Sea coastline within the Arctic                                                  1982.   Unpl. rep. by Falco Enterprises, Fairbanks, for USFWS Office
                         National Wildlife Refuge, Alaska, 1901 and 1982. Pp. 61-75 la: G.W.                                            of Sndangered Species, Anchorage. 19 pp.
                         Garner and P.  -E. Reynolds (ads.).   1982 Update report, baseline study
                         of fish and wildlife and their habitats.          U.S. Fish and Wildlife                             Bergerud, A.T. 1971. The population dynamics of Newfoundland caribou.
                         Service, Anchorage. 379 pp.                                                                                    Wildl. Monogr. No. 25. 55 pp.

               Bartels, B.F. and T. Doyle. 1984. Migratory bird use of the coastal lagoon                                     Bergerud, A.T. 1974. Decline of caribou in North America following
                         system of the Arctic National Wildlife Refuge, Alaska, 1983.              Pp.                                  settlement. J. Wildl. Manage. 38(4):757-770.
                         169-199 in: G.W. Garner and P.E. Reynolds (ads.).              1983 Update
                         report, baseline study of fish and wildlife and their habitats. U.S.                                 Bergerud, A.T. 1978. Caribou. Pp. 83-101 ja J.L. Schmidt and D.L. Gilbert
                         Fish and Wildlife Service, Anchorage. 614 pp.                                                                  (ads.).   Big game of North America. Stackpole Books, Harrisburg, PA.
                                                                                                                                        494 pp.

                                                         L-1                                                                                                           L-2

    Bergerud, A. T.  1980.  A review of the population dynamics of caribou and wild

    	reindeer in North America.  Pp. 556-581 in E. reiemrs, E. Gaare, and

    	S. Skjenneberg (eds.).  Proc. 2nd Inst. Reindeer/Caribou Symp., Roros,

    	Norway, 1979.  Direktoratet for vilt og ferskvannsfisk, Trondheim.

    Bergerud, A. T. 1986.  Caribou, wolves, and man.  In press.

    Bergerud, A. T., R.D. Jakimchuk, and D.R. Carruthers.  1984.  The buffalo of

    	the North:  caribou (_angifer tarandus) and human developments.

    	Arctic 37 (1):7-22.

    Bergman, R. D., and D. V. Derksen.  1977.  Observations on arctic and

    	red-throated loons at Storkeersen Point, Alaska.  Arctic 30:41-51.

    Blokpoel, H. and W. J. Richardson.  1980.  On the predictability of spring

    	migration of snow geese across southern Manitoba, Canada.  Working

    	Paper 9.  In:  Proc. 14 Annu.  Meeting Bird Strike Comm.  Europe.  The

    	Hague,  Oct. 1979.

    Brakney, A. W., M. A.  Masteller, and J. M. Morton.  1985.  Ecology of lesser snow

    	geese staging on the coastal plain of the Arctic National Wildlife

    	Refuge, Alaska, fall 1984,  Pp. 245-262 in:  G. W. Ganer and P. E.

    	Reynolds (eds.).  1984 Update report, baseline study of fish and

    	wildlife and their habitats.  U.S. Fish and Wildlife Service,

    	Anchorage. 777 pp.

    Brendel, J.  1985.  Revegetation of arctic tundra after an oil spill:  a case

    	history.  Proc. 1985 Oil Spill Conference, Los Angeles.  Pp. 315-318.

    Cameron, R.D., and K.R. Whitten.  1979.  Distribution and movements of caribou

    	in relation to the Kuparuk Development Area.  First interim report.

    	Rep. by Alaska Dept. of Fish and Game to ARCO Alaska, EXXON, and

    	Sohio Alaska Petroleum Company.  Fairbanks. 32 pp.

    						L-3

    Cameron, R. D., and K. R. Whitten.  1980.  Distribution and movements of caribou

    	in relation to the Kuparuk  Development Area.  Second interim report.

    	Rep. by Alaska Dept. of Fish and Game to Arco Alaska, EXXON, and

    	Sohio Alaska Petroleum Company.  Fairbanks. 35 pp.

    Cameron, R. D., K. R. Whitten, W. T. Smith, and D. D. Roby.  1979.  Caribou

    	distribution and group composition associated with contruction of

    	the Trans-Alaska Pipeline.  Canadian  Field-Naturalis 93 (2):155-162.

    Cameron, R. D., K. R. Whitten, W. T. Smith and D. J. Reed.  1985.  Sampling errors

    	associated with line-transect surveys of caribou.  2nd North Amer.

    	Caribou workshop, Montreal. 8 pp.

    Campbell, W. B. 1981.  Primary production and nutrients.  Pp. 199-258 in:

    	Beaufort Sea barrier island-lagoon ecological processes studies:

    	final report, Simpson Lagoon.  Envir. Assess. Alaskan Cont. Shelf.

    	Vol. 8.  BLM/NOAA, OCSEAP.  Boulder, CO 359 pp.

    Chapin F. S., and M.C. Chapin.  1980.  Revegetation of an arctic disturbed

    	site by antive tundra species.  J. Appl. Ecol.:449-256.

    Chesemore, D. L. 1967.  Ecology of the arctic fox in northern and western

    	Alaska.  M.S. thesis, Univ. of Alaska.  College.  148 pp.

    Chesemore, D. L. 1969.  Den eoclogy of the arctic fox in northern Alaska

    	Can. J. Zool. 47:121-129.

    Child, K.N.  1971.  Alaska Cooperative Wildlife Research Unit, Univ. of

    	Alaska, Fairbanks.  Quarterly Report 22(4):3-4.

    Child, K.N. 1973.  The reactions of barren-ground caribou (rangifer tarandus

    	granti) to simulated pipeline and pipeline crossing structures at

    	Prudhoe Bay, Alaska.  Completion rep. to Alyeska Pipeline Service Co.

    	by Alaska Cooperative Wildlife Research Unit, Univ. of Alaska,

    	Fairbanks.  50 pp.

    							L-4

                Craig, P.C. 1987. Anadromous fishes in the arctic environment            a                                      Davis, J.L., P. Valkenburg, and R.D. Boertje.      1985. Disturbance and the
                           precarious or relatively stable existence? Biol. Pap. Univ. Alaska.                                            Delta Caribou Herd.      Pp. 2-6 in:      A.M. Martell and D.E. Russell
                           In press.                                                                                                      (ads.) Caribou and human activity.        Proc. Ist North Amer. Caribou
                                                                                                                                          Workshop, Whitehorse, Yukon, 28-29 Sept. 1983.           Can. Wildl. Serv.
                Craig, P. and L. Haldorson. 1986. Pacific salmon in the North American                                                    Spec. Publ. Ottawa.
                           Arctic. Arctic 39(l)j2-7.
                                                                                                                                Davis, R.A. 1972. A comparative study of the use of habitat by arctic loons
                Curatolo, J.h. 1975. Factors influencing local movements and behavior of                                                  and red-throated      loons.    Ph.D.   dissertation, Univ. of Western
                           barren-ground caribou (Rangif= tarandus granti). M.S. dissertation,                                            Ontario. London, Ont. 290 pp.
                           Univ. of Alaska, Fairbanks.
                                                                                                                                Davis. R.A., and A.M. Wisely. 1974. Normal behavior of snow geese on the
                Curatolo, J.A., and D.G. Roseneau. 1977. Distribution and movements of the                                                Yukon-Alaska    Worth Slope     and the effects of          aircraft-induced
                           Porcupine caribou herd in northeastern Alaska and the. Yukon                                                   disturbance on this behavior. Arctic Gas Biol. Rep. Ser. 27tl-8S.
                           Territory, 1976.   Unpbl. rep. by Renewable Resources Consul. Serv.,
                           Ltd., Fairbanks, for Northern Engineering Serv., Ltd., Calgary.                                      Derkeen,  D.V., T.C. Rothe, and N.D.   Eldridge. 1981. Use of wetland habitats
                           54 pp.                                                                                                         by birds in the National     Petroleum Reserve - Alaska. ' USDI Fish and
                                                                                                                                          Wildlife Service, Resource   Pub. 141. Washington, D.C. 27 pp.

                Curatolo, J.A., S.M. Murphy, and N.A. Robus. 1982. Caribou responses to the
                           piIpal ine/road complex in the Kuparuk Oil field, Alaska, 1981. Rep. by                              Divoky, G.J. 1978. Identification, documentation and delineation of coastal
                           Alaska Biological Research to ARCO Alaska, Inc. Fairbanks. 65 pp.                                              migratory bird habitat in Alaska.        1. Breeding bird use of barrier
                                                                                                                                          Islands in the northern Chukchi and Beaufort seas.          Pp. 482-548 Ja:
                Dau, J.R., and R.D. Cameron. 1985. Effects of a road system on caribou                                                    Environ. Assess. Alaskan Cont. Shelf, Annu. Rep. Princ. Invest., Oct.
                           distribution during calving.         Fourth   Internet.     Reindeer/Caribou                                   1978, Vol. 1. BLM/NOAA, OCSEAP. Boulder, CO.
                           Symp., Whitehorse, 22-2S Aug. 1985. 16 pp.
                                                                                                                                Doll, D., W.P. McCrory, and J.D. Foist. 1974. Distribution and movements of
                .Davis, J.L., and P. Valkenburg. 2979. Caribou distribution, population                                                   the Porcupine caribou herd in the Yukon, 1973. Chap.         1 (56 pp.) int
                           characteristics, mortality, and responpes to disturbance in Northwest                                          K.H. McCourt and L.P. Horstman (ads.).           Studies of    large mammal
                           Alaska. Vol. 1, pp. 13-52 Jai P. Lent (ad.).          Studies of selected                                      populations in northeastern Alaska, Yukon and Northwest Territories,
                           wildlife and fish and their use of habitats on and adjacent to the                                             1973. Arctic Gas Biol. Rep. Serv., Vol. 22.
                           National Petroleum Reserve in Alaska, 1977-1978.        U.S. Dept. of the
                           Interior, Anchorage. 226 pp.                                                                         Duffy, D.C. 1979. Human disturbance and breading birds. Auk 96:815-816.

                Davis, J.L., R.T. Shideler, and R.E. LeResche. 1977. Fortymile caribou herd                                     Doughty, R.N. 1979. Rider husbandry in the North Atlantic: trends and
                           studies. Final rep., Fed. Aid in Wild. Rest. projects W-17-6 and                                               prospects. Polar Record 193447-459.
                           W-17-7. Alaska Dept. of Fish and Game. Juneau.
                                                                                                                                                                         L-6

                                                          L-5

    Edwards, R.Y.  1954.  Fire and the decline of a mountain caribou herd.

    	J. Wildl. Manage. 18:521-526.

    Elison, G.W., A.G.  Rappaport, and G.M. Reid.  1986.  Reprot of the caribou

    	impact analysis workshop,  Arctic National Wildlife Refuge, 19-20

    	Novermber 1985.  U.S. Fish and Wildlife Service, Fairbanks.  39 pp.

    Ellis, D.H.  1981.  Responses of raptiorial birds to low level military jets

    	and sonic booms.  Unpub. rep. by Inst. for Raptor Studies, Oracle,

    	AZ, for U.S. Fish and Wildlife Service and U.S. Air Force.  59 pp.

    Fancy, S.G.   1982.  Movements and activities of caribou at Drill sites 16 and

    	17, Prudhoe Bay, Alaska -- the second year.  Final rep. by LGL

    	Ecological Research Associates, Fairbanks, for the Prudhoe Bay Unit

    	owners.  48 pp.

    Fancy, S.G.  1983.  Movements and activity budgets of caribou near oil

    	drilling sites in the Sagavanirktok River floodplain, Alaska.  Arctic

    	36(2):193-197.

    Fancy, S.G., R.J. douglass, and J.M. Wright.  1981.  Movements and activities

    	of caribou at Drill Sites 16 and 17, Prudhoe Bay, Alaska.  Fin. rep.

    	by LGL Alaska Ecological Research Associates for the Prudhoe Bay Unit

    	owners.  Fairbanks.  48 pp.

    FWS (U.S. Fish and Wildlife Service).  1981.  U.S. Fish and Wildlife Service

    	mitigation policy -- Notice of final policy.  Fed.  Reg.

    	46(15):7644-7663.

    FWS (U.S. Fish and Wildlife Service).  1982.  Arctic National Wildlife Refuge

    	coastal plain resource assessment.  Initial report, baseline study of

    	the fish, wildlife, and their habitats.  Section 1002C, Alaska

    	National Interest Lands Conservation Act.  Anchorage. 507 pp.

    							L-7

    FWS (U.S. Fish and Wildlife Service).  1983.  Arctic National Wildlife Refuge

    	coastal plain resource assessment.  1982 update report, baseline

    	study of the fish, wildlife, and their habitats.  Section 1002C,

    	Alaska National Interest Lands Conservation Act.  Anchorage. 379 pp.

    FWS (U.S. Fish and Wildlife Service).  1984. Arctic National Wildlife Refuge

    	coastal plain resource assessment.  1983 udate report, baseline

    	study of the fish, wildlife, and their habitats.  Secition 1002C,

    	Alaska National Interest Lands Conservation Act.  Anchorage. 614 pp.

    FWS (U.S. Fish and Wildlife Service).  1985.  Arctic National Wildlife Refuge

    	coastal plain resource assessment.  1984 update report, baseline

    	study of the fish, wildlife, and their habitats.  Section 1002C,

    	Alaska National Interest Lands Conservation Act.  Anchorage.  Vol. I,

    	pp. 1-361; Vol. II, pp. 362-777.

    FWS (U.S. Fish and Wildlife Service).  9186.  Arctic National Wildlife Refuge

    	coastal plain resource assessment.  Final report, baseline study of

    	the fish, wildlife, and their habitats.  VOl. I. 392 pp.

    Gunn, A. 1984.  Aspects of the management of muskoxen in the Northwest

    	Territories.  In:  D.R. Klein, R.G. White, and S. Keller (eds.).

    	Proc.  First Internet.  Muskox Symp.  Biol. Pap. Univ. Alaska, Spec.

    	Rep. No. 4:33-40.

    Gunn, A., R. Decker, and T.W. Barry.  1984.  Possible causes and consequences

    	of an expanding muskox population, Queen Maud Gulf area, Northwest

    	Territories.  In:  D.R. Klein, R.G. White, and S. Keller (eds.).

    	Proc. First Internat.  Muskox Symp.  Biol. Pap. Univ.  Alaska, Spec.

    	Rep. No. 4:41-46.

    Heard, D.C., and G.W. Calef.  1986.  Population dynamics of the Kaminuriak

    	caribou herd, 9186-1985.  Rangifer (Special Issue No. 1): 159-179.

    						L-8

               Belle, T., and L. Tarvainen. 1984. Effects of insect harassment on weight                                        Johnson,  L.A., Z.B. Sparrow, T.F. Jenkins, C.M. Collins, C.V. Davenport, and
                         gain and survival in reindeer calves. Rabgifer 4:24-27.                                                          T.T. McFadden.    1980.   The fate and effects of crude oil spilled on
                                                                                                                                          subarctic permafrost terrain in Interior Alaska.         U.S. Cold Regions
               Renshaw, J. 1968. The activities of the wintering caribou in northwestern                                                  Research and Engineering Laboratory,           Springfield Va.       National
                         Alaska in relation to weather and snow conditions. Int. J. Biometeor.                                            Technical Information Services Rep. 80-28. 68 pp.

                         12:21-27.
                                                                                                                                Johnson,  S.R. 2984a. Birds and marine mammals. Pp. 26S-324 in:
               Holmes. R.T. 1970. Differences in population density, territoriality. and                                                  Environmental characterization and biological use of lagoons in the
                         food supply of dunlin on arctic and subarctic tundra. In: A. Watson                                              eastern Beaufort Sea.      U.S. Dept. Comm., NOAA, OCSEAP       . Final Rep.
                         (ad.). Animal populations in relation to their food resources. Brit.                                             24t129-579.
                         Ecol. Soc. Symp. 10003-317.
                                                                                                                                Johnson,  S.R. 1984b. Habitat use and behavior of nesting common eiders and
               Holmes, R.T., and F.A. Pitelka. 1968. Food overlap among coozisting                                                        molting oldsquaws at Thetis Island, Alaska, during a period of
                         sandpipers on northern Alaskan tundra. Systematic Zool. 17005-318.                                               industrial activity. Unpub. rep. by LGL Alaska Research Assoc-, Inc,
                                                                                                                                          Anchorage, for Sohlo Alaska PetroU        Co. Anchorage. 65 pp.

               Jakimchuk, R.D. 1980. Disturbance to barren-ground caribous a review of the
                         effects   and implications of human developments and activities.         Rep.                          J.ohnson, S.R., N.J. Adams, and M.R. Morre   .11. 197 1S. The birds of the
                         by R.D. Jakimchuk Management Associates Ltd. to Polar Gas Project.                                               Beaufort  Sea.    Rep. by LGL    Ltd.,  Toronto, to Canada Dept. Envir.,
                         140 pp.                                                                                                          Victoria,  B.C. 310 pp.

               Jakimchuk, R.D.,    B.A. DeBack, H.J. Russell, and G.P. Semenchuk. 1974. A         study                         Johnson,  S.R., and W.J. Richardson. 1981. Birds. Pp. 109-383 in:
                         of the    Porcupine Caribou Hard, 1971. Chap. 1 (112 pp.) int R.D.                                               Barrier   island-lagoon ecological . process studiess           Final Rep.,
                         Jakimchuk (ad.).     The Porcupine Caribou Hord - Canada.         Arctic Gas                                     Simpson   Lagoon.    Envir. Assess. Alaskan Coat.          Shelf.   Vol.    7.
                         Biol. Rep. Serv., Vol. 4.                                                                                        BLM/NOAA, OCSZAP. Boulder. CO. 678 pp.

               Jingfors, K., and P. Lassen. 1984. Munkoz responses to a seismic test                                            Johnson,  S.R., and N.J. Richardson. 1982. Naterbird migration near the Yukon
                         operation: preliminary observations. ins D.R. Klein, B.G. White, and                                             and Alaskan coast of the Beaufort Seat            II. Moult migration of
                         S. Keller (ads.).      Proc. First Internat. N     .uskox Symp.   BLol. Pap.                                     seaducks in summer. Arctic 35(2):291-301.
                         Univ. Alaska, Spec. Rep. No. 0127.
                                                                                                                                Keleall,  J.P., and D.R. Klein. 1979. The state of knowledge of the Porcupine
               Johnson, L.A. 1981. Revegetation and selected terrain disturbances along the                                               Caribou Hard. Trans. 44th N. Am. Wildl. Rat. Resour. Conf.:SOB-5il.
                         Trans-Alaska Pipeline.      U.S. Cold Regions Research and Engineering
                         Laboratory, Sprinfield, VA.      National Technical Information Services                               King, J.G. 1970. The swans and geese of Alaska's arctic slope. Wildfowl
                         Rep. 81-12. 115pp.                                                                                               21tll-17.

                                                         L-9                                                                                                              L-10

    Klein, D.R. 1967.  Interactions of Ragifer tarandus (reindeer and caribou)

    	with its habitat in Alaska.  Finnish Game Res. 30:289-293.

    Klein, D.R. 1968.  The introduction, increase, and crash of reindeer on St.

    	Matthew Island. J. Wildl. Manage. 32(2):350-367.

    Klein, D.R. 1971.  The reaction of reindeer to obstructions and disturbance.

    	Science 173:393-398.

    Klein, D.R. 1980.  Reaction of caribou and reindeer to obstructions -- a

    	reassessment.  Pp. 519-527 in E. Reimers,  E. gaare, and S.

    	Skjenneberg (eds.).  Proc. 2nd Int.  Reindeer/Caribou Symp., Roros,

    	Norway, 1979.  Direcktoatet for vilt og ferskvannsfisk, Trondheim.

    Koski, W.R.  1977a.  A study of the distribution and movements of snow geese,

    	other geese and whistling swans on the Mackensie Delta, Yukon North

    	Slope, and Alaskan North Slope in August and September, 1975.  Arctic

    	Gas Biol.  Rep.  Ser. 35(2):1-54.

    Koski, W.R. 1977b.  A study of the distribution and movements of snow geese,

    	other geese and whistling swans on the Mackenzie Delta, Yukon North

    	Slope, and eastern Alaskan North Slope in August and September,

    	1976. Unpub. rep. by LGL Ltd., Edmonton, for Can. Arctic Gas Study

    	Ltd., Calgary. 69 pp.

    Leader-Williams, N.  1980.  Population dynamics and mortality of reindeer

    	introduced into South Georgia. J. Wildl. Mange. 44(3):640-657.

    Lensink, C.J. 1973.  Population structure and productivity of whistling swans

    	on the Yukon Delta, Alaska.  Wildfowl 24:21-25.

    Lent, P.C. 1966.  The caribou of northwestern Alaska.  Pp. 481-517 in N.J.

    	Wilimovsky and J.N. Wolfe (eds.).  Environment of the Cape Thompson

    	region, Alaska. U.S. Atomic Energy Comm., Div. Tech. Info. 1250 pp.

    							L-11

    Lent, P.C.  1980.  Synoptic snowmelt patterns in arctic Alaska in relation to

    	caribou habitat use.  Pp. 71-77 in E. reiemrs, E. Geare, and S.

    	Skjenneberg (eds.).  Proc. 2nd Int. Reindeer/Caribou Symp., Roros,

    	Norway, 1979.  Direktoratet for vilt og ferskvannsfisk, Trondheim.

    Mahoney, S.P.  1982.  The Grey River caribou study.  Final report, year 3.  May

    	1, 1981 - May 1, 1982.  Newfoundland Div. of Wildlife. 319 pp.

    Martell, A.M., and D.E. Russell (eds.).  1985.  Caribou and human activity.

    	Proc. 1st N. Am. Caribou Workshop, Whitehorse, Yukon.  Can. Wildl.

    	Serv. Spec. Pub. Ottawa. 68 pp.

    Martin, P.D., and C.S. Moistoret.  1981.  Bird populations and habitat use,

    	Canning River delta, Alaska.  Unpub. rep. for U.S. Fish and Wildlife

    	Service, Arctic National Wildlife Refuge.  Fairbanks.

    Mauer, F.J., G. W. Garner, L.D. maritn, and G.J. Weiler.  1983.  Evaluation of

    	techinques for assessing neonatal caribou calf mortality in the

    	Porcupine caribou Herd.  Pp. 201-379 in: 1982 Update report baseline

    	study of the fish, wildlife, and their habitats.  ANWR Prog.  Rep. No.

    	FY83-6.  U.S.  Dept. Interior, Fish and WIldl.  Serv.  Anchorage.  379

    	pp.

    Mccourt, K.H., J.J. russell, D. Doll, J.D. feist, and W. McCroroy.  1974.

    	Distribution and movements of the Porcupine Caribou Herd in the

    	Yukon, 1972.  Chap. 2. (89 pp.) in:  R.D. Jakimchuk (ed.).  The

    	Porcupine Caribou Herd - Canada.  Arctic Gas Biol. Rep. Ser., Vol. 4.

    McKendrick, J.D., and W.M. Mitchell, 1978.  Fertilizing and seeding oil

    	damage arctic tundra to effect vegetation recovery, Prudhoe Bay,

    	Alaska.  Arctic 31 (3):296-304.

    McKnight, D.E., and B.L. Hilliker.  1970.  The impact of oil development on

    	waterfowl populations in Alaska.  Proc. Ann. Conf. Western Assoc.

    	State Game and Fish Comm.  50:286-297.

    						L-12

               McLaren, N.A., and J.E. Green. 1985. The reactions of muskoxen to snowmobile                                   Pope, P.R., and S.O. Hillman. 1982. Arctic Coastal Plain tundra
                          harassment. Arctic 38(3):188-193.                                                                            restoration: a new application.       Pp. 93-108, Proc. Fifth AMOP      Tech.
                                                                                                                                       Seminar -- 1982. Edmonton.

               Miller, D.R. 1971. Seasonal changes In the feeding behavior of barren-ground
                          caribou on the taiga winter range.       Pp. 744-755 An Proc. let Int.                              Pope, P.R., S.O. Hillman, and L. Safford. 1982. Arctic Coastal Plain tundra
                          Symp. on Behavior of Ungulates in Relation to Management. Calgary.                                           restorationt first year report on a new application technique. Proc.
                                                                                                                                       33rd Alaska Science Conference. Fairbanks, Alaska.

               Miller, F.L., and K. Gunn. 1966. Effects of adverse weather on neonatal
                          caribou survival -- a review. Rangifer (Special Issue Mo. 1):211-217.                               Raveling, D.G. 1964.. Geese and hunters of Alaska's Yukon Delta: management
                                                                                                                                       problems and political dilemmas. Trans. North Am. Wildl. and Nat.
               Murphy, S.M. 1984. Caribou use of ramps for crossing pipe/road complexes,                                               Ron. Conf. 49%555-S75.
                          Kuparuk Oilfield, Alaska.       Unpubl.    rep. by Alaska Biological
                          Research, Fairbanks, for ARCO Alaska, Inc., Anchorage. 52pp.                                        Reynolds, P.Z., and D.J. LaPlant. 1985. Effects of winter seismic
                                                                                                                                       exploration activities on muskoxen in the Arctic National Wildlife
               Murray. D.F. 1980. Threatened and endangered plants of Alaska. U.S. Dept.                                               Refuge, January-May 1984. lat G.N. Garner and P.R. Reynolds (ode.).
                          of Agriculture, Forest Service, and U.S. Dept. of Interior, Bureau       of                                  1984 Update report, baseline study of the fish, wildlife, and their
                          Land Management. Anchorage. 59 pp.                                                                           habi .tats. U.S. Fish and Wildlife Service, Anchorage.

               MU16, H.S.   1962. An assessment of a wildlife habitat evaluation methodology                                  Richardson, N.J., and S.R. Johnson. 1981. Waterbird migration near         the Yukon
                          for Alaska. H.S. thesis. UnLv. of Alaska, Fairbanks. 215 pp.                                                 and Alaskan coast of the Beaufort Seat I. Timing, routes and numbers
                                                                                                                                       In spring. Arctic 34(2)tloe-121.

               Northcott, P.L. 1904. Impact of the Upper Salmon Hydroelectric Development
                          on the distribution and movement of the Grey River caribou hard in                                  Robus, N.A. 1983. Caribou movements in the CPF 2 - Oliktok region, Kuparuk'
                          1982. Env. Assess. Div., Dept. of Environment. Govt. of Newfoundland                                         Oil Field, Alaska, 1982. Rep. by Alaska      Biological Research for ARCO
                          and Labrador. 83 pp.                                                                                         Alaska. Inc. Fairbanks. 74 pp.

               Oates, R.N., M. McWhorter, and D. Douglas. 1987. Species accounts of                                           Robus, N.A., and J.A. Curstolo. 1983. Movements of caribou along the Oliktok
                          migratory birds at eight study areas on the coastal plain of the                                             Road and in the Kalubik Creek region, Kuparuk Oilfield, Alaska,
                          Arctic National Wildlife Refuge, Alaska. 1985 Update report, baseline                                        1983.   Unpubl. rep. by Alaska Biological Research, Fairbanks, for
                          study of the fish, wildlife and their habitats.            U.S. Fish and                                     ARCO Alaska, Inc., Anchorage. 61pp.
                          Wildlife Service. Anchorage.
                                                                                                                              Roby, D.D. 1980. Winter activity of caribou on two arctic ranges. Pp.
               Ogilvie, N.A. 1978. Wild geese. Buteo Books, Vermillion, SO. 350 pp.                                                    537-544 An E. Reimers, E. Gears, and S. Skjonneberg (ads.).             Proc.
                                                                                                                                       2nd Int. Reindeer/Caribou Symp., Roros, Norway, 1979. Direktoratet
                                                        L-13
                                                                                                                                       for vilt og ferskvannsfisk, Trondheim.

                                                                                                                                                                      L-14

    Roseneua, D.G.  1979.  Caribou in the western DeLong Mountains, Alaska:  a

    	preliminary impact assessment.  Pp. 1-53 in R.J. Douglass, P.J. Bente,

    	and D.G.  Roseneau.  Interim  report on biological research conducted in

    	the western Delong Mountains during 1978.  rep. by LGL  Alaska

    	Ecological Research Associates for WGM Inc. Fairbanks.

    Roseneau, D.G., and P.M. Stern.  1974.  Distribution and movements of the

    	Porcupine Caribou Herd in northeastern Alaska, 1972.  Arctic Gas

    	Biol. Rep. Ser., Vol. &. 208 pp.

    Roseneau, D.G., P.M. Stern, and C. Warbelow.  1974.  Distribution and movements

    	of the Porcupine Caribou Herd in northeastern Alaska.  Chap. 4 (197

    	pp.)  in:  K.H. McCourt and L.P. Horstman (eds.).  Studies of large

    	mammal populations in northern Alaska, Yukon and Northeast

    	Territories, 1973.  Arctic Gas Biol. Rep. Ser., Vol. 22.

    Roseneau, D.G., J.A. Curatolo, and G. Moore.  1975.  Distribution and

    	movements of the Porcupine Caribou Herd in northeastern Alaska and

    	the Yukon Territory, 1974.  Chap. 3 (104 pp.) in:  R.D. Jakimchuk

    	(ed.).  Studies of mammals along the proposed Mackenzie Valley gas

    	pipeline route from Alaska to British COlumbia.  Arctic Gas Biol.

    	Rep. Ser., Vol. _ _.

    Roseneau, D.G., and J.A. Curatolo.  1976.  Distribution and movements of the

    	Porcupine Caribou Herd in northeastern Alaska and the Yukon

    	Territory, 1975.  Chap. 1 (82 pp.) in: R.D. Jakimchuk (ed.).  Studies

    	of mammals along the proposed Mackenzie Valley gas pipeline route,

    	1975.  Arctic Gas Biol. Ser., Vol. 36.

    Roseneau, D. G., P.J. Bente, and A.M. Springer.  1980.  Numbers and status of

    	peregrine falcons (Falco peregrinus) on the middle Yukon River, lower

    	Yukon River, and in the Arctic National Wildlife Range.  Unpbl rep.

    	by Falco Enterprises, Fairbanks, for the USFWS Office of Endangered

    	Species, Anchorage.  53 pp.

    					L-15

    Roseneau, D.G., C.E. tull, and R.W. Nelson.  1981.  Protection strategies for

    	Peregrine falcons and other raptors along the proposed Northwest

    	Alaskan Gas Pipeline Route.  Unpbl. Final Rep. by LGL Alaska Res.

    	Assoc.  Inc., Fairbanks, for Northwest Alaskan Pipeline Company, Salt

    	Lake City.  Vol. 1, 218 pp.; Vol. 2, 114 pp.

    RRCS (Renewable Resources Consulting Services, Ltd.)  1985.  Calving and

    	post-calving distributions of Central Arctic Caribou, 1981-1985.

    	Unpubl. map folio prep. for Alyeska Pipeline Service Co., Inc.,

    	Anchorage.

    Russell, D.E., and A.M. Martell.  1985.  Influence of the Dempster Highway on

    	the activity of the Porcupine Caribou Herd.  Pp. 22-26 in A.M.

    	Martell and D.E. Russell (eds.).  Caribou and human activity.  Proc.

    	1st N. Am. Caribou Workshop, Whitehorse, Yukon.  Can.  Wildl. Serv.

    	Spec. Pub. Ottawa.

    Russell, J.  1977.  Some overt responses of muskoxen and caribou to seismic

    	activities, northeastern Banks Island.  Northwest Terr. Wildl. Serv.,

    	Yellowknife.  85 pp.

    Salter, R.E., and R.A. Davis, 1974.  Snow geese disturbance by aircraft on

    	the North Slope, September 1972.  Arctic gas Biol. Rep. Ser.

    	14:258-279.

    Shank, C.C. 1979.  Human-related behavioral disturbances to northern large

    	mammals:  a bibliography and review.  Rep. to Foothills Pipe Lines

    	(South Yukon) Ltd.  Calgary.  246 pp.

    Schefffer, V.B.  1951.  The rise and fall of a reindeer herd.  Sci.  Monogr.

    	73(6):356-362.

    Schelle, D.M.  1984.  Primary production and nutrient dynamics in Simpson

    	Lagoon and adjacent waters.  U.S. Dept. of Comm., NOAA OCSEAP Final

    	Rep. 24:69-112.

    								L-16

                 Schell, D.M., D.M. Parrish, and P.J. Ziemann. 1984. Primary production                                          Smith, W.T., and R.D. Cameron. 1985. Reactions of large groups of caribou to
                            nutrient    dIynamics   and  trophic    energetics.     Pp.   433-467     -in:                                 a pipeline corridor on the Arctic Coastal Plain of Alaska.              Arctic
                            Environmental character ization and biological use of lagoons in the                                           .38t53-57.
                            eastern Beaufort Sea.     U.S. Dept. of Conn., NOAA, OCSEAP Final Rep.
                            24:129-579.                                                                                          Solman, V.Z.F. (ad.). 1971. Studies of bird hazards to aircraft. Canad.
                                                                                                                                           Wildl. Serv. Rep. No. 14. 105 pp@

                 Scotter,   G.W. 1967. Effects of fire on barren-ground caribou and their
                            forest habitat in northern Canada. Trans. North       Am. Wildl. and Nat.                            Spindler, N.A. 1978a. Fall staging of lesser snow geese on the Arctic
                            Resour. Conf. 32:246-259.                                                                                      National Wildlife Range.       Unpub. rep. by U.S. Fish and Wildlife
                                                                                                                                           Service, Fairbanks.. 11 pp.
                 Shideler, R.T. 1986. Impacts of human developments and land         use on caribou                              Spindler, N.A. 1978b. Bird populations utilizing the coastal tundra, coastal
                            a literature review. Vol. Ili Impacts of oil and gas development on
                            the Central Arctic Hord.     Alaska Dept. of Fish and Game Tech. Rep.                                          lagoons, and nearshore waters of the Arctic National Wildlife Range.
                            86-3. Juneaui 126 pp.                                                                                          Unpub. rep. by U.S. Fish and Wildlife Service, Fairbanks. 23 pp.

                 Shideler, R.T. 1986. impacts' of     human developments and land use on caribou: a                              Spindler, M.A. 1964. Distribution, abundance and productivity of fall
                                                                                                                                           staging lesser snow geese an coastal habitats of northeast Alaska and
                            literature review. Vol.   Il. Impacts of oil and gas development on the
         L                                                                                                                                 northwest Canada, ige3. Pp. 74-101 in: G.M. Garner and P.E.
                            Central Arctic herd. Tech. Rep. go. 86-3. Habitat Div., Alaska Dept.                                                                                                                 Reynolds
                            of Fish and Came. Juneau. 128 pp.                                                                              (ads.). 1983 Update report, baseline study of the fish, wildlife and
                                                                                                                                           their habitats.     Unpub. rep. by U.S. Fish and Wildlife Service,
                 Skoog, R.O. 2968   *  Ecology of the caribou   (Rangifer tarandus granti) In                                              Anchorage, 614 pp.
                            Alaska. Ph.D. dissertation, Univ.    California, Berkeley. 699 pp.
                                                                                                                                 Springer, A.M., D.G. Roseneau, P.J. Bents, W. Walker 11, and R.G. Clarke.
                 Smith. M., :and R. G Iloans. .1982. Aquatic studies onthe North Slope of the                                              1979. Numbers and status of peregrine falcons on the Colville River,
                            Arctic National Wildlife Refuge, 1981 and 1982.       Fisheries Resources                                      middle Yukon River, and lower Yukon River, Alaska- 1979.               Unpubl
                            Progress Report FY      83-1.    U.   S.   Fish and Wildlife Service,                                          rep. by LGL Alaska Ecol. Res. Assoc., Fairbanks, for the USFWS Office
                            Fairbanks. 71pp.                                                                                               of Endangered Species, Anchorage. 69 pp.

                 Smith, T.E. 1984. Population status and management of muskozen on Nunivak                                       Underwood, L., and J.A. Mosher. 1982. Arctic fox. Chap. 23 (pp.491-503) In:
                            Island. Alaska. in: D.R. Klein, R.G. White, and S. Keller (eds.).                                              J.A.Chapman and G.A. Feldhamer (eds.).             Wild mammals of North
                            Proc. First Internet. Nuakoz Symp.      Biol. Pap. Univ. Alaska, Spec.                                         America. Johns Hopkins Univ. Press, Baltimore. 1148 pp.
                            Rep. No. 4%52-56.
                                                                                                                                 Urquhart, D.R. 1973. Oil exploration and Banks Island wildlife -- a guide
                                                           L-17                                                                            for the preservation of caribou, muskox, and arctic fox populations
                                                                                                                                           an Banks Island, N.W.T.       Unpubl. rep., Northwest Tarr. Game Mgt.

                                                                                                                                           Div., Yellowknife.. 105 pp.

    Valkenburg, P., and J.L. Davis.  1985.  The reaction of caribou to aircraft:

    	a comparison of two herds.  Pp. 7-9 in:  A.M. Martell and D.E. Russell

    	(eds.).  Caribou and human actiivty.  Proc 1st North Amer.  Caribou

    	Workshop, Whitehorse, Yukon, 28-29 Sept. 1983.  Can.  Wildl. Serv.

    	Spec.  Publ., Ottawa.

    Valkenburg, P., and J.L. Davis.  1986.  Calving distribution of Alaska's

    	Steese-Fortymile caribou herd:  A case of infidelity?  Rangifer

    	(Special Issue No. 1):315-323.

    Walker, D.A., P.J. Webber, K.R. Everett, and J. Brown.  1978.  Effects of

    	crude and diesel oil spills on plant communities at Prudhoe Bay,

    	Alaska, and the derivation of oil spill sensitivity maps.  Arctic

    	31(3):242-259.

    Walters, C.J., R. Hilborn, and R.M. Peterman.  1975.  Computer simulation of

    	barren-ground caribou dynamics.  Ecol.  Model.  1:303-315.

    Walters. C.J., R. Hilborn, R.M. Peterman, M. Jones, and B. Everitt. 1978.

    	Porcupine caribou workshope draft dreport on submodels and scenarios.

    	Unpubl. rep., Inst. of Animal Resource Ecology.  Univ. of British

    	Columbia, Vancouver. 42 pp.

    Webber, P.J., and J.D. Ives.  1978.  Damage and recovery of tundra vegetations.

    	Environ. Conserv. 5(3):171-182.

    White, R.G., B.B. Thomson, T. Skogland, S.J. Person, D.E. Russell, D.F.

    	Holleman, and J.R. Luick.  1975.   Ecology of caribou at Prudhoe Bay,

    	Alaska.  Pp. 150-201 in:  J. Brown (ed.).  Ecological investigations

    	of the Tundra Biome in the Prudhoe Bay region, Alaska.  Spec.  Rep.

    	No. 2, Biol. Pap. Univ. Alaska, Fairbanks.

    Whitten, K.R., and R.D. Cameron.  1982.  Calving distribution and initial

    	productivity in the Porcupine Caribou Herd, 1982.  Pp. 591-599 in:

    	1983 Update report, baseline study of the fish, wildlife, and their

    	habitats.  U.S. Fish and Wildl.  Serv.,  Anchorage.  614 pp.

    						L-19

    Whitten, K.R., and R.D. Cameron.  1983.  Population dynamics of the Central

    	Arctic Herd, 1971-1981.  Acta Zoologica Fennica 175:159-161.

    Whitten, K.R., G.W. Garner, and F.J. Mauer.  1984.  Calving distribution,

    	initial productivity, and neonatal mortality of the Porcupine Caribou

    	Herd, 1983.  Pp. 359-420 in:  1984 Update reprot, baseline study of

    	the fish, wildlife, and their habitats.  ANWR PRog. Rep. No.

    	FY84-12.  U.S. Fish and Wildl. Serv., Anchorage. 614 pp.

    Whitten, K.R., F.J. Mauer, and G. W. Garner.   1985.  Calving distribution,

    	initial productivity and neonatal mortality of the Porcupine Caribou

    	Herd, 1984.  Pp. 527-621 in:  1984 Update report, baseline study of

    	the fish, wildlife, and their habitats.  Vol. II, ANWR Prog. Rep. No.

    	FY85-18.  U.S. Fish and Wildl. Serv., Anchorage. 614 pp.

    Williams, T.M., and D.C. Heard.  1986.  World status on wild Rangifer tarandus

    	populations.  Rangifer (Special Issue No. 1):19-28.

    Wilmore, S. B.  1974.  Swans of the world.  Taplinger Publishing Co., New

    	York.  229 pp.

    Wright, J.M., and S.G. Fancy.  1980.  The response of birds and caribou to the

    	1980 drilling operation at the Point Thomson _4 Well.  Final report.

    	Unpub. rep. by LGL Alaska Research Assoc., Inc., Fairbanks, for EXXON

    	USA, Anchorage.  62 pp.

    						L-20

                                                                                                                                                        TESTIMONY OF.
                                                                                                                                           STANDARD  ALASKA PIRODU.CTION COMPAIR.Y

                                                                                                                                                           ON THE
                                            APPENDIX
                                                                                                                                    DRAFT LEGISLATIVE  ENVIRONMENTAL  IMPACT STATEMENT
                                SAPC Testimony,  January 5, 2907                                                                                          FOR THE:
                                 SPC Testimony,  January.9, 1987
                                                                                                                                        ARCTIc NATIONAL   WILDLIFE REFUGE, ALASKA

                                                                                                                                           COkSTAL-PLAIN  RESOURCE  ASSESSMENT

                                                                                                                                                                                q.

                                                                                                                                                     January 5,   1987

                                                                                                                                                     PRESENTED    BYt

                                                                                                                                                    ROGER C. HERRERA

                                                                                                                                             MANAGER EXPLORATION AND   LANDS

                  Mr. Chairman:                                                                                                       In discussing the inappropriateness of this policy in
                                                                                                                                      Alaska, reference must be made to the recently initialed
                                                                                                                                      U.S./Canadian Porcupine Caribou Agreement of December 3,
                  My name is Roger Herrera and I am representing the Standard
                  Alaska Production Company with whom I am employed as Manager                                                        1986.
                  of Exploration and Lands.                                                                                           The Fish and Wildlife Service mitigation policy was deliber-
                  The 1002(h) report has       two g Irest attributes which are not                                                   ately excluded by the U.S. Government from thee Agreement.
                  often seen in environmental Impact statements - it is short                                                         If the use of the mitigation policy Is unacceptable to the
                  and readable.     The authors are to be complimented because                                                        Goverment in its efforts to achieve conservation of the
                  these praiseworthy characteristics have probably resulted in                                                        Porcupine Caribou herd in conjunction with the Government of
                  the report having been read in           its entirety by a large                                                    Canada, what justification is there to impose it on industry
                                                                                                                                      in order to achieve exactly the same results on the Coastal
                  number of people.      The nature of     the decision to      be made
                  regarding the Coastal Plain of           Arctic National      Wildlife                                              Plain?
                  Refuge obviously demands a careful       and dispassionate assess-                                                                             ervice mitigation policy and some of
                  ment of the knowledge gained from the six years of concen-                                                          The Fish and Wildlife S
                  trated study in the area.           It is our opinion that the                                                      the biological conclusions In the report result from an
                  1002(h) report sets out that Information in a meaningful and                                                        assumption that fish and wildlife populations using the ANKR
                  relatively balanced way. It is an adequate document to make                                                         Coastal Plain are indiscriminately limited by habitat avail-
                  judgments on the issue.                                                                                             ability.    There Is no evidence to support this assumption
                                                                                                                                      and, in fact, the report does not cite or discuss any evi-
                  You have previously heard testimony from the Alaska Oil            and                                              dence to justify that position.
                  Gas Association.      Standard Alaska Production Company           was,                                             Meeting birds on the North Slope are in general much more
                  involved in the preparation of that statement and endorses                                                          influenced by weather than they are by habitat, and there
                  it in its entirety. We believe that the Coastal Plain of                                                            are no examples of mammal population size or productivity
                  ANNE must be opened in full to responsible leasing, explora-                                                        which has been limited by Worth Slope habitat availability.
                  tion, development, and oil production (Alternative. A). Only                                                        V-4h- h... . - 4. N-14-A
         OD       in that way will our future state and national interests be                                                         ------- -      d n
         -4       adequately considered.      We must plan to boost our domestic                                                      levels in the Worth American Arctic, and it is. generally
                  reserves and production, and at the same time indulge in                                                            accepted that caribou productivity is limited principally by
                                                                                                                                      wolf predation on the fall, winter, and spring ranges, auq-
                  responsible conservation if we are to preserve our lifestyle.                                                       mented by human harvest.        It is therefore not logical to
                  The Coastal Plain of ANKH figures prominently both as a                                                             suggest that animal species distribution or abundance would
                  possible source of major oil supplies and as a means to                                                             change in any biological, meaningful way as a result of the
                  :ssuage man's yearnings for the aesthetics of solitude,                                                             limited, low-density oilfield construction approach used in
                   canary, and wildlife.                                                                                              Arctic Alaska.      Recent bird studies (Troy at al 1986) and
                                                                                                                                      fish studies (Craig 1986) support this conclusion, and the
                  Without Coastal Plain oil it is perhaps pertinent to          .mention                                              steadily increasing caribou populations during the period of
                  that the aesthetic experience of wilderness that is. per-                                                           oilfield development also indicate that habitat is not a
                  ceived to be the alternate goal to development will be                                                              confining.facter.
                  available only to-an elite few.          It is also reasonable to                                                   The only biologically effective approach to assessing and
                  mention that the tens of thousands of Americans and other                                                           mitigating any effects of development on wildlife is to
                  visitors who have enjoyed a once-in-a-lifetime trip to the                                                          determine how industry activities will alter population-
                  North Slope in the past decade have done so because of the                                                          limiting factors for each species of concern, and then to
                  development of Prudhoe Bay.        Prudhoe Bay has not destroyed                                                    apply mitigative       measures     that   avoid    those     limiting
                  their arctic experience, it has made it possible, unique,                                                           factors.    That is quite different from and more practical
                  and memorable. A small point, but one worth remembering.                                                            than the Fish and Wildlife Service policy of preserving
                                                                                                                                      "habitat value".     Such a policy usually translates into pro-
                  One aspect of the report requires comment at this stage,                                                            tecting land from change, or ensuring that all change is
                  namely the bias recognizable in the chapters dealing with                                                           "natural".     This ignores Arctic biology and makes Policy
                  caribou.    Thin bias has lead to an emphasis on a proposed
                  mitigation measure, the utilization of the Fish and Wildlife                                                        dominant over biology.        it imposes a particular point of
                  Service mitigation policy.                                                                                          view on the real world without determining whether the real
                                                                                                                                      world conforms with the imposed viewpoint.

                In this case the policy is flawed and should be scrapped in
                Alaska.   Likewise some of the proposed mitigating measures
                which result from the policy are unnecessary and often
                counter-productive.   Many of the mitigating measures that                                                                         TESTIMONY OF
                have been proposed have been proven to be effective on the
                North Slope and are fully supported by Standard Alaska                                                                       THE STANDARD OIL COMPANY
                Production Company.   Our ain with regard to environmental
                protection in the same an the Department of laterior's, but                                                                            ON THE
                we feel strongly that the end result of oil production with
                minimum and acceptable environmental impact cannot be                                                            DRAFT LEGISLJLTIVE ENVIRONMENTAL IMPACT STATEMENT
                achieved using the Fish and "ildlife mitigation policy In
                the Arctic.                                                                                                                           FOR THE
                TWO other points about the caribou sections of the report3                                                           ARCTIC NATIONAL MILDLIFE REFUGE, ALASKA
                First, the report would be greatly strengthened and balanced
                If reasonable use had been made of the Information and                                                                  COASTAL PLAIN RESOURCE ASSESSMENT
                analysis of     the expert caribou       Canadian    biologists,
                Bergerud, Jaklachuk, and Bonfield.       Their work has been
                largely ignored In the draft LEIS and the dismissal of the
                dissident views of Bergerud on Page 110 an "widely disputed"
                in a distortion unworthy of the authors.           Second, the
                so-called core calving areas of the Porcupine hard and the
                "space constraints" which the caribou are supposedly sub-
                jected to at that time of the year, ignore the fact that
                many tons of thousands and In some years, hundreds of thou-
                sands of Porcupine Caribou calve In Canada. The maps In the
                report are misleading and less than scientific In not
                depicting the full calving range.

                It is our intention, Mr. Chairman, to comment In detail an
                this and other issues In a separate written submission which
                we hope,will be carefully considered.

                                                                                                                                                  January 9. 1987

                                                                                                                                                  Washington, D.C.

                                                                                                                                                   PREBENTED, BY:

                                                                                                                                                   ROGER C. HERRERA

                                                                                                                                           MANAGER EXPLORATION AND LANDS

                                                                                                                                         STANI)ARD ALASKA PRODUCTION COMPANY

                  Mr. Chairman:                                                                                            It is perhaps worth mentioning, in passing, that the statis-
                                                                                                                           tics on oil spills contained in the report are no doubt
                  My name is Roger Herrera and I am Manager of Exploration and                                             correct and represent the facts of life working outside at
                  F,ands for the Standard Alaska Production Company.     Today 1                                           40 or 50*F below zero in a harsh environment.      What is not
                  am preventing testimony for The Standard Oil Company.                                                    mentioned is the fact that the vast majority of those spills
                                                                                                                           occur on gravel pads or roads and that all of them are
                  Standard is the largest producer of oil from the State of                                                totally cleaned up.
                  Alaska and has been present as an explorer and producer in
                  Alaska since the late 1950's. The 1002(h) report has drawn                                               A recognition of this effort Is seen in the figure of 83% of
                  on many scientific and technological studies carried out by                                              Alaskan respondents (November 1986 Dittman poll) who believe
                  or for Standard Oil as in recognized in the bibliography.                                                that the oil industry can operate safely in wildlife refuges
                  Based on our long experience of operating in the Arctic, we                                              in Alaska.
                  believe the report is thorough, balanced, and fair in its
                  description of the coastal plain ecosystem and assessment of                                             The success of future development of the coastal plain of
                  scenarios of development. It needs some modification in the                                              ANWR will be achieved In two ways. One, by continuous and
                  caribou section to make it more realistic, and it does not                                               friendly consultation and coordination between industry,
                  justify some of the proposed mitigation measures, especially                                             native residents and refuge managers and other Fish and
                  the use of the Fish and Wildlife Service mitigation policy.                                              Wildlife Service personnel, and secondly, by repeating and
                  That policy, which concentrates on preserving habitats                                                   enhancing the philosophy and practice which has worked so
                  rather then populations of animals, cannot benefit wildlife                                              well at Prudhoe, Kuparuk, Milne Point, and Endicott.      Surely
                  in Alaska.    Alaska, in particular the North Slope and                                                  those two requirements are not beyond our capability?
                  coastal plain, in unique in having more habitat than animal
                  species  can ever occupy.       Consequently,    administrative                                          Before closing let me mention some aspects of the report
                  efforts to protect habitat above all does little or nothing                                              that require attention. The maps depicting caribou calving
                  to benefit populations such as caribou, polar beari musk                                                 areas are less than truthful and If they have been used to
                  oxen. ate. The concent and nractice of mitioation In akin                                                arrive at the conclusions on caribou concentrations, etc.,
         OD       to motherhood and totally accepted by my company, but I know                                             those conclusions must be wrong., Caribou calving areas have
                  from 25 years experience in the Arctic that the Fish and                                                 been mapped annually deep into - Canadian territory, and not
                  Wildlife Service mitigation policy in a poor protective                                                  to depict the total calving area on the maps Is unscientific
                  mechanism and it should be changed.                                                                      and akin to joining the flat earth society. This should be
                                                                                                                           rectified.
                  The success of our mitigation efforts in the post is perhaps
                  measured by the results of a recent public opinion poll in                                               The three mile buffer xone precluding development facilities
                  Alaska (Dittman November 1986).    Eighty-six percent of the                                             at the coast to protect caribou insect. relief areas is
                  respondents thought that the oil industry has operated in an                                             unnecessary.   Caribou use of that zone is sporadic and
                  environmentally safe manner at Prudhoe Bay. Only five per-                                               ephemeral and southern areas of the coastal plain are much
                  cent gave negative replies.     That accolade was earned not                                             more important to the herd than the northern fringe.
                  because of protective environmental regulations and stipula-
                  tions, although they obviously played a part, but prin-                                                  Standard 'Oil supports Alternative A.       We appreciate the
                  cipally because the operating oil companies pursued a                                                    opportunity to testify and will submit detailed written
                  philosophy of care for the environment and the animals.                                                  comments in due course.
                  This was done for two reasons. First and foremost, because
                  we are human beings too and have the same appreciation of
                  wilderness and the aesthetics of scenery or seen of caribou
                  as anyone else.   Secondly. there is a clear logic and self-
                  interest in not doing this wrong in the Arctic.       A simple
                  Z
                  xample in an oil spill -on a gravel pad or the tundra. The
                    ill itself cost the value of the oil - perhaps a few
                  dollars, but the cost of clean up is usually measured in
                  thousands, tons of thousands, or millions of dollars.       The
                  incentive not to spill oil quickly becomes very clear, as
                  does the incentive to design better equipment to prevent oil
                  spills.

                                                                                                     THEREFORE TENNECO TAKES THE POSITION THAT THE CONTROVERSY PRESENTLY
                                STATEMENT ON THE DRAFT REPORT
                                                                                                     SURROUNDING ANWR IS NOT SO MUCH A QUESTION OF WHETHER THE MINERAL
                          "ARCTIC NATIONAL  WILDLIFE REFUGE, ALASKA,                                 RESOURCES BENEATH THE REFUGE SHOULD BE EXPLORED FOR AND DEVELOPED, AS
                             COASTAL PLAIN RESOURCE ASSESSMENT"                                      IT IS A QUESTION OF WHEN THOSE POTE*TfAL PETROLEUM DEPOSITS WILL BE
                                           AND LEIS
                                                                                                     EXPLORED FOR AND DEVELOPED.
                              BEFORE THE SECRETARY OF INTERIOR
                                         SUBMITTED BY                                                THE PRINCIPLE ARGUMENT AGAINST THE OPENING OF ANWR FOR PETROLEUM
                                                                                                     EXPLORATION AND DEVELOPMENT APPARENTLY IS THE PRELIMINARY FINDING IN
                        TENNECO OIL COMPANY EXPLORATION & PRODUCTION
                                               ON                                                    YOUR DRAFT REPORT THAT THE PORCUPINE CARIBOU HERD WILL BE ADVERSELY
                                        JANUARY 9, 1987                                              IMPACTED BY DEVELOPMENT ACTIVITIES.         INCIDENTAL TO THAT FINDING.

                                                                                                     CERTAIN HABITAT HAS BEEN PLACED IN RESOURCE CATEGORY I, AND BY SO

                                                                                                     DOING, THE P07ENTIAL FOR MITIGATION IS NEGATED.         AS A PROFESSIONAL
          MR. SECRETARY, I Am DR. MICHAEL ZAGATA, DIRECTOR OF THE ENVIRONMENTAL
                                                                                                     WILDLIFE BIOLOGIST. I QUESTION THIS HABITAT CLASSIFICATION BECAUSE I
          AND SAFETY DEPARTMENT FOR. TENNECO OIL COMPANY.       MY PURPOSE IN BEING
          HERE IS TO ADDRESS ONE OF THE ISSUES RAISED IN YOUR DRAFT REPORT, IE.                      AM RELUCTAN  IT TO.CONCLUDE, BASED ON AVAILABLE. INFORMATION       THAT NO
                                                                                                     MITIGATION IS POSSIBLE.       WITH MORE INFORMATION SPECIFIC TO THE
          THE POTENTIAL IMPACT OF OIL AND GAS. EXPLORATION AND DEVELOPMENT ON                        PORCUPINE CARIBOU HERD, I    .BELIEVE EFFEGTIVE MITIGATION MEASURES CAN
          THE PORCUPINE CARIBOU HERD.        I WILL FOCUS ON THE CARIBOU ISSUE
                                                                                                     BE FOUND. MOREOVER, THE LONG-TERM IMPACT OF PETROLEUM DEVELOPMENT ON
          BECAUSE IT IS SYMBOLIC OF THE HEART OF     THE PRESENT DEBATE CONCERNING
                                                                                                     THOSE CARIBOU WILL DEPEND ON THE "TOOLS" WHICH REFUGE PERSONNEL HAVE
          THE NEED TO EXPLORE FOR AND CONSIDER THE DEVELOPMENT OF THE OIL AND                        AT THEIR DISPOSAL FOR RESOURCE' MANAGEMNT, AND/OR THEIR USE OF SUCH
          GAS RESERVES BENEATH THE ARC71C NATIONAL WILDLIFE REFUGE.                                  TOOLS.

          ALTHOUGH THE UNITED STATES, INDEED THE WORLD, CURRENTLY ENJOYS AN
                                                                                                     TENNECO HAS A STRONG CORPORATE POLICY TO PROTECT THE ENVIRONMENT AND
          ABUNDANT SUPPLY OF PETROLEUM, WE MUST LEARN FROM HISTORY THAT THAT
                                                                                                     HAS A HISTORY OF CONDUCTING ITS BUSINESS IN A MANNER THAT MITIGATES
          SUPPLY IS CYCLIC.    IT IS LIKELY THAT DURING THE NEXT DECADE THE U.S.
                                                                                                     ADVERSE IMPACTS ON THE ENVIRONMENT AND WHERE, OPPORTUNITIES EXIST.,
          WILL EXPERIENCE ANOTHER SHORTAGE.     WHEN THAT HAPPENS. AMERICANS AS A
          NATION  WILL,   FOR  A VARIETY OF      REASONS,   FIND WAYS    70 EXPLOIT                  ENHANCING THE ENVIRONMENT.     INDEED, TENNECO'S MANAGEMENT CONSISTS OF
                                                                                                     MANY PEOPLE, WHO IN THEIR PRIVATE. AS WELL AS PROFESSIONAL LIVES,        ARE
          POTENTIALLY COMMERCIAL DEPOSITS OF PETROLEUM.
                                                                                                     CONSERVATION MINDED. TENNECO THEREFORE TAKES THE POSITION THAT IT

                                                                                                     SHOULD  BE   EXPECTED   TO  CONTINUE   CONDUCTING   ITS  BUSINESS    IN   AN
          MR. SECRETARY, TENNECO CONCURS WITH YOUR FINDINGS THAT THE COASTAL
                                                                                                     ENVIRONMENTALLY RESPONSIBLE MANNER AND CAN BE EXPECTED TO SEEK WAYS
          PLAIN IN ANWR POTENTIALLY CONTAINS ENORMOUS DEPOSITS OF PETROLEUM.
                                                                                                     TO MINIMIZE ADVERSE ENVIRONMENTAL IMPACTS.

             TENNECO DOES NOT FEEL THAT THE ANWR ISSUE SHOULD PIT PRO Vs

             ANTI -DEVELOPMENT INTERESTS AGAINST ONE ANOTHER.             AS AMERICANS, IT IS
                                                                                                                OF THE EXISTING ROYALTY COULD BE DEDICATED FOR ANWR IN THE SAME WAY A
             IN ALL OF OUR BEST INTERESTS TO DETERMINE THE AVAILABILITY OF A                                    PERCENTAGE OF THE OFFSHORE ROYALTY IS DEDICATED FOR THE- LAND AND
             POTENTIALLY ENORMOUS ENERGY SUPPLY.         IT IS ALSO IN OUR BEST INTEREST                        WATER CONSERVATION FUND.        THIS WOULD GIVE ALL OF THOSE WHO USE THIS
             THAT WE DO.IT IN AN ENVIRONMENTALLY RESPONSIBLE MANNER.                                            ENERGY A CHANCE       TO CONTRIBUTE TO THE SOUND STEWARDSHIP OF THE

                                                                                                                RENEWABLE RESOURCES ASSOCIATED WITH ANWR.
             WE ARE COMMITTED TO THAT END AND THAT IS WHY WE FEEL THAT NOW IS THE
             MOST OPPORTUNE TIME TO DETERMINE IF THAT ENERGY RESOURCE- REALLY                                   THANK YOU FOR THIS OPPORTUNITY TO PRESENT OUR VIEWS AND I LOOK
             EXISTS.      WE HAVE A SHORT TERM OVERSUPPLY OF ENERGY AT PRESENT.            THIS                 FORWARD TO WORKING WITH THE DEPARTMENT AS THE ANWR ISSUE IS FURTHER
             GIVES US     THE LUXURY OF SOME ADDITIONAL TIME - TIME TO           CONDUCT, THE                   EXPLORED.    I WOULD BE HAPPY TO ANSWER ANY QUESTIONS YOU MAY HAVE
             RESEARCH     NEEDED TO DETERMINE THE POTENTIAL FOR ADVERSE AND/OR                                  RtGARDING  TENNECO'S POSITION.
             POSITIVE     IMPACTS ON THE CARIBOU HERD, TIME TO CONSIDER AND TEST

             MITIGA71ON    MEASURES.     AND   TIME    TO   CONSIDER      OPPORTUNITIES     FOR

             ENHANCEMENT.    THAT TIME   WILL BE LOST IF. A TWIST OF FATE ERODES THAT

             SURPLUS. AND  CREAIES A CRISIS SITUATION BEFORE ANY ACTION IS TAKEN.

             WE HAVE THE TIME NOW        TO SIT TOGETHER, NOT         AS  ENVIRONMENTALISTS,

             DEVELOPERS   OR REGULATORS. BUT AS PEOPLE CONCERNED          WITH OUR WI-LDLIFE

             HERITAGE An OUR ENERGY       FJJTURE.  IF AN ENERGY CRISIS DEVELOPS BEFORE
             WE RESOLVE   SUCH QUESTIONS N07 ONLY WILL THE CHANCE BE LOST BUT THE

             DEVELOPMENT   OF THE PETROLEUM RESOURCES' MAY PROCEED AT A -PACE THAT IS

             NOT IN THE   BEST INTERESTS OF THE WILDLIFE RESOURCE.

             THE ANWR     ISSUE PRESENTS A "GOLDEN" OPPORTUNITY           TO SHOW THAT OUR
             APPROACH     TO ENVIRONMENTALLY SENSITIVE ISSUES HAS         MATURED-.    TENNECO

             IS READY     AND WILLING TO UNDERTAKE THE CONSTRUCTIVE       STEPS NECESSARY TO

             BUILD THE    CONFIDENCE NEEDED BY ALL THE PLAYERS IN THIS ISSUE IF WE'RE

             GOING TO     WORK TOGETHER.    INDEED WE INVITE THOSE        PLAYERS TO BEGIN A

             POSITIVE     DIALOG ON THIS . ISSUE.   THE SUBJECT OF SUCH A DIALOG NIGHT

             WELL INCLUDE THE CREATION OF A WILDLIFE TRUST FUND           FOR ANWR PATTERNED

             AFTER THE EXISTING LAND AND WATER CONSERVATION FUND.          A PERCENTAGE

           CC:  D. B. JOHNSON

                C. S. KHOO

                J. BARNES

                D. S..TAYLOR

                H. A. BRISC OE

                                                                                                            U.S. Fish  & Wildlife Service
       J
          to M  ff       1-06D 1AA                                                                          January 19,
         60VI W                                                                                                            1987
        V,c,. P,(-@.d@nt                 S"ife 5(X)                                                         Page 2
                                         WaShinglon DC 20036

                                                                                                            reduce the nation's   energy security risk and expand efforts
                                                                                                            toward achieving national energy security. Accordingly, this
                                                                                                            resource assessment    is timely and vitally important.
              January 19, 1987                                                                              THE NATION'S NATIONAL AND ECONOMIC SECURITY IS AT RISK
                                                                                                            Consideration of this matter is timely and critical under present
                                                                                                            circumstances. It is well known that decisions by foreign
                                                                                                            producing countries caused a decline of more than 40 percent in
                                          DRAFT ARCTIC NATIONAL WILDLIFE REFUGE                             crude oil prices during 1986. This precipitous drop in.revenue
                                          COASTAL PLAIN RESOURCE ASSESSMENT                                 makes an increasing number of producing wells uneconomic.              . ..
                                          AND LEGISLATIVE ENVIRONMENTAL IMPACT                              Consequently, U.S. production has fallen. While barely down in
                                          STATEMENT,                                                        the first quarter of 1986 when compared to the first quarter of
                                                                                                            1985, production fell 2.9 percent in the second quarter and
                                                                                                            3.1 percent in the third quarter. By the end of the year U.S.
              Direct .or                                                                                    production had fallen by 700,000 barrels per day. At the same
              U.S. Fish and Wildlife Service                                                                time, U.S. consumption was up 1.2 percent in the first quarter,
              Division   Iof Refuges                                                                        up 2.4 percent in the second quarter, and up 3.8 percent in the
              Main Interior Building,    Room 2343                                                          third quarter.
              18th and C Streets, N.W.                                                                      The net effect   is that the growing difference between domestic
              Washirigto .n, DC  20240                                                                      consumption and production has been.filled with increased oil
                                                                                                            imports which are up 23 percent.over 1985. Significantly,
              Gentlemen-
                                                                                                            petroleum imports@have risen to 38 percent of.U.S. oil
       C40                                                                                                  consumption, a higher level of d.ependence than      at the time   of  the
              Texaco appreciates this Opportunity     to present its   views on  the                        I-973-74 embargo  L Every knowledgeable forecast     shows an.
              captioned report. While we have some suggestions for change, we                               increasing dependence-upon imports.
              comwnd the U.S. Fish and Wildlife Service for its exhaustive
              efforts in developing   a comprehensive, well balanced resource                               The sharp drop in prices not only affects existing wells,        but
              assessment@ We strongly recommend Alternative A, the opening         of                       also impacts the drilling of new wells and-thereby future
              the entire ANWR coastal plain for oil and.gas leasing.                                        production. Production declines normally over a period of time
                                                                                                            and drilling of new wells and the discovery of new reserves.help
              The report is timely when placed in the context of a potential                                to offset this decline. Lower prices, however, limit the number
              national security and economic crisis resulting from the collapse                             of wells drilled and the risk operators are willing to take to
              of-energy prices. One of the Administration's highest priorities                              find new reserves. As a result, exploratory Activities have been
              must be to complete its energy national security study requested                              severely curtailed. The consequence is that future production
              by the President and to establish policies which will increase                                from U.S.'wells will be less than it would have been at higher
              domestic production, while at the same time decrease reliance on                              crude price levels and, therefore, imports will be increased. As
              insecure sources of imported crude oil and petroleum products.                                crude prices risej as,they inevitably will, exploration will
              As part of an overall national security strategy expeditious                                  accelerate. Given the long lead times involved in bringing
              Administration and Congressional action should Also be taken to                               Arctic production to market, however, it is important that
              Open the Artic National Wildlife Refuge (ANWR) for leasing.                                   -affirmative action be initiated now to open the ANWR coastal
                                                                                                            plain for oil and gas exploration. Even if oil and gas leasing
              Selection of Alternative A will provide a clear signal that        this                       were authorized now, energy production from-the coastal plain
              nation is taking steps to provide for its energy security.         49                         would not help offset increasing dependence on oil imports until
              with the Strategic Petroleum Reserve, Alternative A is not an                                 the late 1990*s at the earliest.
              instantaneous solution. once legislative authority has been
              given, weLestimate that leasing in the remote, harsh climate of                               Worldwide lower   prices, over a period of time, also reduce the
              the AMR coastal plain would not commence before the early 1990's                              productive capacity outside the U.S. dub to the normal decline in
              and significant production would not start before the late                                    production from older wells and to the      reduction in cash flow to
              1990's. Nevertheless, its potentially large new reserves can                                  pay for new drilling and exploration.       That fact means that,
                                                                                                            increasingly, world consuming nations,      especially those requiring

                       otwif@ion of T(-xjr.(, Inc

             U.S. Fish   Wildlife Service                                                              U.S. Fish & Wildlife  Service
             January 19, 1987                                                                          January 19,  1987
             page 3                                                                                    Page 4

             larger imports, become  more vulnerable  not only to  international                       consumption). Also, a few months supply is certainly significant
             cartels, but also to the political and   economic decisions of the                        when compared  with the remaining estimated 10-month supply from
             more radical.producing states. Before    an actual oil shortage
                                                                                                       Prudhoe Bay, the.largest oilfield ever discovered in North
             occurs, artificial shortages may be created, as in the 1976's, by                         America. The resource assessment supports the fact that the
             one or a few producing nations. The consequence, as before,                               coastal plain is.ourbest opportunity for finding another field
             would be rapidly, upwardly spiraling crude oil prices and major                           as large as Prudhoe Bay.
             overall economic and political disruptions. Accordingly,.the
             United States increasingly faces the real possibility of a return                         Skepticism has also been   expres,sed about the possibility of
             to serious energy problems. Future problems tend to be                                    finding commercial-sized  oil fields in the coastal plain. The
             complacently deferred. Prudence dictates otherwise..                                      Department of Interior-has estimated that there is a 19 percent
                                                                                                       chance of success. That level of risk is very good in the oil
             There is compelling evidence that a continuation of-existing                              business. Historically,    the chance of an exploratory well
             trends will result In an excessive and imprudent level of                                 encountering a commercial oil discovery is about five percent.
             imported crude oil and petroleum products within the next 2-3                             Therefore, the opportunity for a commercial oil discovery within
             years. Our national security interests demand that the U.S.                               the coastal plain is nearly four times better than average.
             Government promptly adopt policies designed to insure that U.S.
             crude oil production not decline below a target minimum level.                            Others wanting to delay the exploration of the ANWR coastal plain
             Such policies could include improved financial incentives to the                          point out that there is presently a surplus of productive
             domestic producing industry including consideration of an oil                             capacity in the world and that the domestic industry's current
             import fee or minimum "floor price.' The appropriate remedy can                           economic condition precludes heavy involvement in new frontier
             be determined once the objective as to the desired future level                           areas. Such statements ignore the long lead-time necessary
                                                  (See Attachment entitled
             of U.S. production is determined.                                                         before there will be production from the coastal plain. Even
             "Effect of Petroleum Imports on U.S. Crude Oil Production" which                          with favorable legislative action in the near future, actual
             was a portion of Texacol-s comments filed with the Department of                          production from the coastal plain probably will not occur until
             Energy in connection with its energy security study for the                               the late 1990's, under a best case scenario.
             President.)
             THE ANWR REPORT IS IMPORTANT                                                              Timely exploration of the coastal plain, and the hoped for
                                                                                                       production from substantial new reserves, would act as a buffer,
             The Department of t e InterTor's resource assessment clearly                              or mitigating influence, against forecasted crude oil shortages
             indicates that the coastal plain constitutes a tremendous                                 and rapidly escalating crude oil prices.
             opportunity for thediscovery of new petroleum reserves.
             Consistently, the coastal plain is considered by many                                     DEVELOPMENT OF ANWR COASTAL PLAIN PROVIDES SIGNIFICANT BENEFITS
             knowledgeable explorationists to be one of the most prospective                           Aside from its national security benefits the economic benefits
             areas, if not the most prospective, in the United States.                                 associated with the exploration and development of the coastal
             Resource estimates reach easily into the billions of barrels.                             plain are substantial. Oil production from the coastal plain
             Production from the coastal plain may equal, or perhaps even                              would provide a significant, new source of tax and royalty
             exceed, the resource potential of Prudhoe Bay, which now accounts                         revenue to federal, state and local governments. Moreover,
             for nearly 20 percent of the oil production in the U.S. The true                          development of the petroleum resources within the coastal plain
             nature and extent of this resource can be determined only through                         would create jobs as a result of the new demand for goods and
             the drilling of wells. Hopefully, this potential production will                          services not only in Alaska, but also in other states.
             be available timely and mitigate the increasing dependence upon                           Additionally, the negative U.S. balance of payments for
             foreign oil supplies.                                                                     international trade would be reduced.

             Those who oppose ANWR coastal plain development argue that the                            Equally important, t he opening of the ANWR coastal plain to oil
             reserve potential of the coastal plain may be too small to                                and gas activities, provides necessary acknowledgment that this
             justify leasing, as it may represent only a few months supply of                          nation is taking steps to meet this future problem, which
             oil for the nation at its current consumption rate. This                                  certainly has an impact upon the nation's military defense.
             argument lacks substance because this nation currently has less                           While weapons are important, the availability of sufficient
             than a five-year supply of domestic reserves (existing domestic                           petroleum products has to be a concern. The nation also needs to
             crude oil reserves divided by total domestic petroleum                                    know, as soon as possible, if hydrocarbons are not present in the

               U.S. Fish & Wildlife Service                                                                  U.S. Fish    Wildlife   Service
               January 19, 1987                                                                              January 19,  1987
               Page 5                                                                                        Page 6

               ANWR coastal plain. That.information would allow energy,                                      questions and still not provide conclusive answers.        Accordingly,.
               policymakers to restructure their plans for future energy                                     further drilling could be warranted.
               requirements.
                                                                                                             We agree with the statement,.   "Areas without  mapped structures may
               ALTERNATE A IS THE PREFERRED OPTION                                                           prove to be of greaterl.lesser-or equal potential. Without
               In view of the national benefits which could be derived from                                  exploratory drilling as a confirmation and delineation tool, 611
               development in the coastal plain, Texaco believes that                                        (reserve) estimates must be considered uncertain." Therefore, it
               Alternative A should be adopted by Congress. Alternative B                                    is necessary to have Access to the-entire-.coastal plain.'
               prohibits leasing on part of the area used by the Porcupine
               caribou herd for calving. However, the need for this exclusion                                Date Reserve Estimates     In  order to avoid misrepresentation of
               is not well-documented in scientific literature. Alternative C                                the resource as .sessmerit, we suggest'that Table III-1 on page 50
               would delay leasing and development indefinitely and calls for                                bereviBed to include the dates that.reserve figures for each
               off-structure drilling which would provide additional information                             basin were developed. In the event additional wells have been
               but would not establish the presence or absence of oil reserves.                              drilled in a particular basin which would impact,reserve
               Alternatives D (no action) and E (wilderness) are unacceptable                                estimates, such estimates,should be revised accordingly.
               since each would preclude any development whatsoever. Given the
               decline in U.S. production, Texaco believes it would be imprudent.                            Exp uition and Production of the Coastal Plain Can Prciceed With
                                                            "clearly the most
               to leave untested what the report terms,                                                        nim   A    rguimpacts - Th. resource assessment portion of        the
               outstanding oil and gas frontier remaining in the                                             report wa:v:o    cted under a statistically-based, "most-likely       .
               United States..."                                                                             case scenario. In contrast, virtually all of the environmental
                                                                                                             impact discussions are based on a "worst" case scenario. Also,
               RECOMMENDATIONS ON THE REPORT                                                                 it seems to have been overlooked that the consolidation of
               Acknowledge A-Aditional Strii-c-tures - The resource assessment                               facilities and the imposition of reasonable operating
               identifies 26 major,Btructures w1thin the coastal plain based on                              stipulations can frequently fully mitigate an environmental
               an Ellesmerian play concept. We believe there may be                                          concern.
               insufficient information to Assess properly other more complex
               plays which were not mapped. Accordingly, it would be desirable                               The report  states that  "Long-term losses... would be the
               to have the statement, "No prospects were adequately resolved                                 inevitable  consequence" of development. Development "will result
               within the detached and highly deformed Mesozoic and Tertiary                                 in long-t"grm changes in wildlife habitats, wilderness environ-
               rocks," reflect that assessment of these areas had not been made.,                            ment, and native community activities" (emphasis added). The
               The reportalso states "...in these and several other plays                                    language is inconsistent with the facts and other quotes from the
               (referring to all play concepts except the folded Ellesmerian/                                same section of the report, suchas "The amount of reduction and
               Pre-Mississippian) the estimated accumulation sizes, though                                   its long-term significance for herd.viability is highly
               perhaps substantial, are often of such size as to be of little        or                      speculative" (emphasis added).
               no current economic interest if occurring singly, and are often
               mapped with great difficulty." Texaco believes this statement                                 ANIMAL AND PLANT LIFE WILL BE PROTECTED
               could be misleading by discounting the viability of these play                                Texaco agrees that caribou of    the Mr-cupine herd are the most
               concepts based on current price assumptions. That assessment                                  conspicuous biological community on the coastal plain, but we
               should be based,upon projected prices at the time of production.                              believe that designation of USF&WS Resource Category 1 for a
                                                                                                             portion of their widespread calving area in the Jago River area
               Also in the report is the   statement, "If most of the Ellesmerian                            is not justified. The terms "traditional," "core calving area,"
               rockB.are missing in most   of the 1002 area, the assessment number                           "uniqueF and "irreplaceable" are inappropriate in this case.
               would be reduced considerably. Drilling one or two wells in                                   Concentrated calving has been observed in the Jago highlands
               critical areas would resolve this question.' it implies that the                              during only five 'of the past 14 years which indicates that the
               El,lesmerian play trend must exist for development to occur and                               calving habitat is not fixed at any one location along the
               that one or two wells will prove the presence or absence of this                              calving habitat from Canning River to the Babbage River in
               play. Texaco strongly believes that there can be economic plays                               Canada. Therefore, all of this area is An acceptable calving
               in the ANWR coastal plain without this particular geologic play                               habitat and there is nothing traditional about the Jago
               being present and that such test wells may raise many new                                     highlands.   It just happens that on the average, the interaction
                                                                                                             of migration, forage, predators and weather conditions have

             U.S. Fish & Wildlife Service                                                          U.S. Fish  Wildlife Service
             January 19, 1987                                                                      January 19, 1987
             Page 7                                                                                Page 8

             combined to place some of the herd in that area when their calves                     developed to bring that oil to U. S. markets, the fish and
             were due to be born in five out of 14 years Iof observation.                          wildlife resources of the Prudhoe Bay area remain extremely
             Additionally, the discussions of possible adverse effects on the                      healthy." we expect that same result to occur on the coastal
             herd seems to ignore experience gained at Prudhoe Bay, Kuparuk                        plain.
             River, Milne Point and Endicott despite the statement in the                          ENVIRONMENTAL PROTECTION STIPULATIONS
             report that "The evidence generated during the 18 years of                            Texaco believes the Department of the interior can responsibly
             exploration and development at Prudhoe Bay indicates minimal                          manage any oil and gas activities which may be authorized by
             impact on wildlife resources. Hence, it is reasonable to assume                       Congress. In this regard, the proposed environmental protection
             .that development can proceed on the coastal plain and generate                       stipulations,.with a few exceptions, appear to be reasonable and
             similar minimal effects." Despite weak scientific evidence to                         consistent with current oil industry practice in the Arctic. Our
             support a distinction between the Central Arctic Herd and the                         comments on the exceptions follow-
             Porcupine Caribou Herd, the report states "The lack of observable
             adverse effects from displacement exhibited by the Central Arctic                          First, there is a prohibition on all exploratory activity
             Herd would be unlikely for the Porcupine Caribou Herd."                                    T-rom May 1 to November 1. Texaco believes that activitie
                                                                                                                                                                 s
             Texaco believes that industry has proven the ability to  function                          likely to cause little interference with animal behavior
             in the Arctic without adversely affecting the caribou population.                          shouldbe permitted as part of a research program approved
                                                                                                        by the Fish and Wildlife Service to determine effects on
             with similar protective measures during the coastal plain                                  wildlife. Activities in this category would be those
             development, we see no reason why the.Porcupine Caribou Herd                               confined to the drill pad and would include drilling and
             should not continue to flourish in the same manner as the Central                          testing of wells. As currently stated, the stipulation
                                                                                                        could cause single exploratory wells to take two or more
             Arctic Herd.
         L                                                                                              years to complete.,
             At several points in the report, the suggestion is offered that
             oil and gas exploration and development would "eliminate the                               Second, there is, in the Arctic Slope Regional
             wilderness character of the area.* Texaco acknowledges that any                            Corporation/U.S. agreement, a requirement that ice pads be
             activity within ANWR will affect its character. However, only                              used for wells being drilled up to 10,600 feet. We suggest
             about one-tenth of one percent of the surface acreage WillLbe                              that this stipulation be revised to allow the use of pad
             involved and the duration of use of the land is limited                                    material in order to ensure a safe and successful completion
             Thereafter, the equipment would be removed and a naturai                                   of the operations plan. Bottomhole depth is often not the
             regenerative process would begin to return the wilderness quality                          most important criteria in determining how long it takes to
             to the Iarea.                                                                              complete an operation. A stipulation, stating a preferred
                                                                                                        use of ice pads where a drilling program can be prudently
             It is useful to observe that the many predictions of  adverse                              accomplished with its use, would beLacceptable.
             biological impacts, prior to construction of the trans-Alaska
             pipeline, have proven false.. Animal and plant life have                                   Third, the restriction on surface occupancy in the 3_Mile
             flourished and the state and nation have shared an era of great                            corridor along the coast to only marine facilities and
             economic prosperity due to the pipeline and associated oil                                 infrastructure is an unnecessary prohibition of other
             development. The extension of oil and gas activities to the ANWR                           temporary and essential facilities. Other mitigating
             coastal plain, therefore, would involve a known and proven                                 measures already ensure caribou passage and minimize
             process.                                                                                   disturbance to wildlife. Texaco recommends the stipulation
                                                                                                        provide, at least, for temporary exploration Land essential
             Texaco fully expects that oil and gas operations on the coastal                            production facilities on a site-specific basis.
             plain would have only minor or negligible impacts on plant and
             animal life residing there. We fully support the conclusion,                               Fourth, we believe the stipulation which indicates a
             drawn by the Department of the Interior, on page 169 which states                          preference for buried pipelines should be reconsidered.
             in part ". . . the production of oil from North America's largest                          Arctic experience has shown that burial of pipelines is
             oil field at Prudhoe Bay has taught us much about how to protect                           unnecessary to accommodate movements of animals where
             environmental values. Even though billions of barrels of oil                               elevation or ramping is used. Further, buried pipelines may
             reserves have been brought on line and the infrastructure                                  not be environmentally preferable due to permafrost. Texaco

                                                                                                                                                                                         ATTACHMENT

               U.S. Fish & Wildlife Service
               January 19, 1987                                                                                                         EFFECT OF PETROLEU14 IMPORTS ON U.S. CRUDE OIL PRODUCTION
               Page  9

                                                                                                                             Absent a shift in U.S. energy policy, the continuation of current crude oil
                     recommends that any proposed stipulation adopt the wording                                              price levels ($14-$15 a barrel) will substantially increase U.S. oil import
                     of the State of Alaska policy on pipeline design, siting and                                            dependence by causing a decline in U.S. production and an increase in domestic
                     construction which states that adequate elevation, ramping                                              consumption.
                     or burial of pipelines will be required in areas identified
                     as important caribou movement.                                                                          Projections completed by the Congressional Budget Office. American Petroleum
                                                                                                                             Institute, the National Petroleum Council (NPC), Congressional Research
                     Fifth, the stipulation on the         construction of docks      and                                    Services, Data Resources Inc., and the Department of Energy indicate U.S.
                     oEa-useways is overly restrictive in calling for no change in                                           crude oil production, which was 8.9 million barrels a day in 1985, could fall
                     water chemistry. Minor changes in water conditionB should                                               by up to 3 HMB/D in 1990. The attached chart entitled "U.S. Net Oil Imports"
                     be acceptable as long as there is no measurable impact on                                               shows a composite projection from four recent ly-ava I lab le studies of U.S.
                     marine species.                                                                                         production dropping to 6.3 HHB/D in 1990. And DOE has projected that by 1995,
                                                                                                                             U.S. oil production will range between 5 and 7 MMB/D. assuming oil prices of
                     Sixth, the closure of a 3/4 mile zone along rivers is an                                                $20 and $30 per'barrel, respectively.
                     excessive restriction to protect a riparian habitat.
                     Maximum effort should be required to protect critical                                                   When combined with a 2 percent annual increase in U.S. oil consumption,
                     habitats.     However, essential production facilities should                                           amounting to as Mich as 2 HKB/D of incremental demand, the United States would
                     be allowed on a site-specific basis.                                                                    be dependent on crude and product imports for more than 50 percent of its
                                                                                                                             needs by 1990. a level higher than that experienced during the energy
               SUMMARY                                                                                                       disruptions of the 1970's.    This point is illustrated on the attached chart
                                                                                                                             entitled "U.S. Oil Import Dependence."      And according to the recent NPC
               The nation is now facing a future energy security crisis which                                                survey's lower price scenario, imports would rise to 11.4 HKB/D in 1995 and
               will result in product price increases and/or supply shortages.                                               account for 60 percent of total consumption. Such dependence raises a number
               As in the 19720-c- the timing will ha r1a+-rmini%A h         V  fnr@iqrn                                      of economic, energy and national security concerns which should be promptly
               political and economic decisions.           Similar to military_d@fense,                                      considered+by the 6.S. Government..
               national plans and actions should be prudently undertaken to
               mitigate or avoid the energy crisis.                                                                          1.   Exploration cutbacks will. reduce future U.S. oil production.

               The subject report provides a resource assessment and legislative                                             The downturn in U.S. exploration and development is evident by the decline in
               environmental impact statement for the Arctic National Wildlife                                               active rotary rigs from over 4,000 in 1981 to roughly 900 in mid-November
               Refuge Coastal Plain.        The report makes clear that this area has                                        t986. This dramatic drop in rigs will have a marked downward impact on future
               the potential to provide very significant volumes of oil. The                                                 levels of oil production.
               report also makes clear that oil and gas activities can be ac-
               complished in an environmentally safe manner.                                                                 Reductions by 40-50 percent in domestic exploration and production budgets
                                                                                                                             relative to 1985 already are having a severe negative impact on the infrastruc-
               Based upon the foregoing, there can be little doubt that the                                                  ture of the U.S. oil Industry, drilling contractors. oil field equipment
               discovery of new reserves of petroleum would benefit the United                                               suppliers, etc.   The financial resources of many independent producers have
               States. Accordingly, to mitigate the prospective national energy                                              been virtually depleted. The seismic crew count Lis down 80 percent from 1981;
               security crisis, we strongly recommend Alternate A, the opening                                               (i.e. 80) large and small companies have cut back sharply on R&D budgets;
               of the ANWR coastal plain, as the prudent, most viable option.                                                service companies are going bankrupt; equipment I, being sold to foreign
                                                                                                                             suppliers or scrapped; and, skilled professional ind technical personnel are
               Sincerely,                                                                                                    losing their jobs and transferring to other          :7idu@tries.  This gap in
                                                                                                                             infrastructure services will have a severe negatt@e effect in the 1990's.

                                                                                                                             Announced and projected reductions in oil indu@tr, @pcnding and oil field
                                                                                                                             activity are linked closely with projections .,i eclicivg 1*.S. production.
                                                                                                                             Accordingly, it is    noteworthy that a rCLent              @-v the Independent
                                                                                                                             Petroleum Association of America (IPAA) of it5            :.Lrd rh.it at S13 per
                                                                                                                             barrel their drilling activity would fall by 85 -.r -!nt @--een 11485 and 1990.
                                                                                                                             Similarly, a recent   American Petroleum Institt:- -r%-v%- @ lind that total
               JDA:caj                                                                                                       capital and operating expenditures for explvratt@n in,l ;,rtiductton (in 1985
                                                                                                                             dollars) would drop from $70 billion in 1985 to          1,ii:Ivn In IQQI if the
                                                                                                                             price of oil were at $15 per barrel during that perL,-d. and that total wells
                                                                                                                             drilled would decline from about 75.000 in 1985 to about il.000 in 1991.

                  2.   Natural Gas Production  will  be similarly  affected.
                                                                                                                                 OPEC's crude oil production could reach 24 MMB/D          up more than 50 percent
                  If crude prices remain in    th $15/bbl. range until 1990, protracted cutbacks                                 from 1985.   With current available OPEC capacity estimated at only about
                  in exploration and developme:t will also significantly reduce U.S. domestic                                    27 MMB/D. OPEC's potential to control the market will be greatly enhanced.
                  natural gas production capability. During this period, demand is likely to be                                  There is little doubt OPEC could establish an effective oil production sharing
                  in the 17-18 TCF/year range.    The combined effect of supply and demand should                                arrangement with only this small amount of surplus capacity.
                  eliminate the domestic surplus gas deliverability in the U.S. by 1990. if not
                  earlier.                                                                                                       National security expert Henry M. Schuler has written that over 95 and 85 per-
                                                                                                                                 cent, respectivelyt of the "installed but currently unutilized production
                  As a result. DOE cannot expect that surplus domestic supp      1ies of natural    gas                          capacity" is located in OPEC countries and -the Middle East.       When the output
                  will be available in the 1990's to replace crude oil supplies for those                                        of currently unutilized production capacity,is absorbed. non-communist nations
                  industrial consumers capable of switching fuels.       In 1985, industrial primary                             will turn to proved but undeveloped reserves, over 76 percent which are
                  energy was supplied 43 percent by oil, 42 percent by natural gas and 15 per-                                   located in OPEC and 69 percent In the Middle East.
                  cent by coal. Only one-third (1.2 MMB/D) of the oil is used for manufacturing
                  heat and power, in which the potential for substitution of gas for oil is                                      API. in a study recently completed ("Two Energy Futures"), concludes that OPEC
                  greatest.   If it is assumed that half of the oil could be replaced by gas.                                    will obtain effective control over world oil prices when demand for OPEC oil
                  this would be 600 MB/D of oil. equivalent to about 1.2 TCF/year.              It is                            exceeds approximately 80 percent of OPEC's current productive capacity.           The
                  doubtful that as much as I TCF/year of surplus gas would be available after                                    forecast increase in world oil consumption of 4 MMB/D by 1990 combined with a
                  1990 to substitute for disrupted oil supplies to Industrial consumers with                                     4 MKB/D decline in non-OPEC production would result in a demand for OPEC
                  fuel switching capability.                                                                                     production in 1990 well above 80 percent of its current productive capacity of
                                                                                                                                 approximately 27 MMB/D.
                  3.   Surplus production capacity will be unavailable in the 1990's           outside
                       OPEC.                                                                                                     4.   The Strategic Petroleum Reserve (SPR) provides inadequate insurance.

                  The trend over the next several years toward declining domestic production as                                  The SPR was authorized by law in 1975 with the intent to store up to I billion
                  imports increase will characterize not only the U.S but many other non-OPEC                                    barrels of oil.   This level was subsequently lowered to a 750 million barrel
                  countries as well.    As a result, if today's levels of oil prices generally                                   SPR to  be developed by 1991, deferring any decision on the remaining 250
         L        prevail through 1990, the world oil surplus that averaged 11 MMB/D in 1985                                     million barrels. The current SFR of 505 million barrels provides a level of
                  could largely disappear by 1990.                                                                               protection to the United States during a time of disruption.              But it is
                                                                                                                                 unlikely that the@ SPR will be doubled between 1986 and 1990 to provide the
                  The sudden drop in crude and product prices is and will continue to have an                                    same margin of protection against the growing U.S. oil import dependence which
                  effect on consumption. The demand for light-end products is increasing in the                                  exists today.
                  United States and abroad.    The worldwide decline in residual fuel demand has
                  been reversed as many utilities and industrial users with dual-fired capacity                                  The current SPR could replace net oil imports for about 82 days, if oil
                  increase their use of fuel oil rather than natural gas or coal.          Free World                            imports remain at August (1986) levels. but would fall to 50 days of
                  demand for petroleum is expected to increase by some I MMB/D in 1986, compared                                 protection if Imports were to increase to 10 MKB/D by 1990.          (10 MMB/D is a
                  with a decline in 1985.                                                                                        composite figure compiled from several forecasts.)          To provide a 100 day
                                                                                                                                 supply would require a SPR of 970 million barrels (assuming imports of 9.7
                  Free World oil demand could easily reach 50 MMB/D by the end of the decade, an                                 MMB/D).   To reach this level would require a fill rate of approximately
                  increase of over 4 MMBID from the 1985 level.        But non-OPEC production will                              315,000 barrels per day for the next four years!       This would cost $7 billion
                  fall substantially as the combination of low prices and drastically reduced                                    (for the oil alone at $15) and would severely impact government expenditures.
                  exploration will particularly affect production from the U.S.. North Sea                                       The physical facilities for injecting and storing additional SPR oil would
                  (U.K.), and Canada.                                                                                            also have to be expanded at a substantial cost.            In addition. a similar
                                                                                                                                 doubling of security stocks would be required In other IEA countries if the
                  Although the downturn in exploration and development has been most dramatic in                                 current margin of protection is to be maintained.
                  the U.S., drilling activity is also down sharply throughout the world,             In
                  Canada for example, 113 rigs were operating in mid-November, compared with 305                                 5.   Alternative supplies of energy will not be available to the U.S. in 1990.
                  a year ago. other areas, such as the North Sea. have b@en similarly affected.
                  According to a recent Hughes Tool Survey, rigs operating outside North America                                 At present price levels,       the synthetic/renewable energy contribution to
                  were 305 less than in 1985 with lower activity in every section of the world,                                  meeting U.S. energy needs is and will continue to be minimal.              Optimistic
                  including the Middle East.     A composite non-OPEC picture is available from a                                projections for shale oil, coal liquefaction, coal gasification, solar energy,
                  recently released study by Chase Econometrics which projects a decline in                                      methanol, et al have, for the most part, proved unattainable even at crude oil
                  non-OPEC crude and NGL production by 4 MMB/D to 21 X.MB/D in late 1988 within                                  price levels prevailing before the current decline.       The U.S. established the
                  one of its two low-price scenarios.                                                                            Synthetic Fuels Corporation in 1979 with a firm commitment to replacing oil
                                                                                                                                 with new sources of indigenous production.       The goals set by the Administra-
                  The net effect of rising world demand and declining non-OPEC production will                                   tion for the Synfuels Program were 500,000 KB/D by 1987 and 2 MMB/D by 1992.
                  be a dramatic increase in OPEC's output and control over the market. By 1990,                                  With the suspension of further Synfuel Corporation funding. it appears the

                                                           -2-                                                                                                            -3-

                Administration and Congress have little faith today in the potential synfuel
                contribution.

                The recent nuclear accident at Chernobyl is expected to sharply limit the
                growth of the nuclear industry, particularly in the U.S. Ahrost no new orders
                for a nuclear powered utility in the U.S. have been made in the last decade.
                While coal and natural gas continue as alternatives to petroleum, there will
                be no significant alternative for transportation fuels and hone heating oil in
                the medium term. If a crude oil import supply disruption should occur in the
                early 19901s, some coal or natural gas would probably be available to substi-
                tute for residual fuel for boilers. However, dual-fired capacity is limited.                                                     FREE-WDRED REFINIM CAPACITY AND OIL DEMAND
                Also, there is a %xving industry consensus that natural gas supply shortfalls                                                                       (MB/CD)
                are inevitable,because reserve additions aren't keeping pace with consumption.

                6.   Conclusion

                The U.S. oil industry is presently undergoing a massive restructuring.                                                                          1979                 1981                1985
                axigets for oil and gas exploration and production, R&D, equipment purchases,                                                           CAPACITY DEMAND*    CAPACITY DEMAND*     CAPACITY UE-M-AND*
                etc. have been redu@ced by 40-50 percent. By 1990 U.S. reliance on imports
                will be at even higher levels than in 1973 and 1979. But when the U.S.
                reaches such dependence, in&, try will be unable to respond quickly to meet                                   Western Wraps                20.3     14.4       20.2     12.3        16.0     11.3
                national economic and energy security concerns.
                                                                                                                              United States                17.2     18.5       18.5     16.1        15.4     15.7
                7.   Policy Determination                                                                                     other Western Hemisphere     10.7     6.1        10.9     6.2           9.6     5.9
                There is caTpelling evidence that       a continuation of existing trends will
       21       result in an excessive and inprudent    level of inported crude oil and petroleum                             Asia/Pacific                 10.3     9.3        10.6     8.7         10.4      8.4
       -        z)rodwts within the next 2-3 vears.       Our national securitv interests demand
                !hat the U.S. Government prorq3ily adopt policies designed io@ insure that U.S.                               Aftica/Middle East             5.2    2.9          5.4    3.3           6.5     3.7
                crude oil production riot decline below a target minimn level. Such policies
                could include improved financial incentives to the domestic producing industry
                including consideration of an oil import fee or mininum "floor price." The                                         TOTAL                   63.7     51.2       65.6     46.6        57.9     45.0
                appropriate remedy can be determined once the objective as to the desired
                future level of U.S. production is determined.

                                                                                                                               Demands cannot  be compared directly to refinery capacities because there are
                                                                                                                               other couponents to supply such as natural gas liquids supply, processing
                                                                                                                               gain, inventory change, yield differences, crude oil quality, etc.

                                                                                                                              SOUMM:    Capacity: International Petroleum Encyclopedia. Demand: Western
                                                                                                                                        Durope -      I United States    DOE; other     British Petroleum
                                                                                                                                        Statistical Pieview.

                                                         -4-

                                                                    U. S. NET OIL IMPORTS

                                                19                                                                                                           4 STUDY CONSUMPT101
                                                                                                                                                             PROJECTION

                                                17

                                                is

                                                                                                              oe
                                                14-

                                                13-

                                                1M

                                                io-

                                                    9-

                                                    7-            DOMESTIC PRODU TION                                                                        4 STUDY PRODUCTION
                                                    6                                                                                                        PROJECTION
                                                    1985               1986                1987                1988                 1959                1990
                                                                                                    YEAR         Note: The 4 Study Projection is based on a composite from stvdies made by the
                                                                                                                 Coiqresijunil Budget Office, American Petroleum Irstitute, 6ongressicnal
                                                                                                                 Research 1trwice and Data ;es*-.,rces-Inc.

                                                          U.S. OIL IMPORT DEPENDENCE

                                                55-

                                                                                                                                                             4 STUDY PROJECTION

                                                150-

                                        Lj      45-
                                                                                                                                                             43% LEVEL AT
                                                                                                                                                             1979 DISRUPTION
                                        z
                                        LLI     40-

                                        IX
                                        Ld
                                                                                                                                                             35% LEVEL AT
                                                35-                                                                                                                 -74 DISRUPTION
                                                                                                                                                             1973

                                                25-
                                                    1985                1986                19 87               1988                1959                1990
                                                                                                     YEAR         Note: The 4 Study Projeition is based an a composite from studies aide ty the
                                                                                                                  Congressional Sudget Office, American Petrotput Institute, Congressicnal
                                                                                                                  Research Service and Data Resources Int.
                                                                                                                      1-200

    DO YOU WANT TO MAKE PUBLIC COMMENTS?

    If you would like to speak at the hearing today, please fill in the blanks
    below and turn it in to one of the Fish and Wildlife Staff members present.
    You need not complete this sheet to submit written comments.  Thank you.

    Please print

    Name Donald C. hartman

    Mailing Address	Texaco Inc.  550 W. 7th Ave, Suite 1320
    			Anchorage Ak 99501

    Check appropriate box below:

    	I am here to offer my own views.
    			-or-
    	I am speaking for TEXACO INC.
    				(please enter name of organization you represent)

    				TESTIMONY-DRAFT ARCTIC NATIONAL WILDLIFE REFUGE
    				COASTAL PLAIN (ANWR) RESOURCE ASSESSMENT AND
    				LEGISLATIVE ENVIRONMENTAL IMPACT STATEMENT

    My name is Donald C. Hartman.  I am Advanced Exploration Geologist (title)
    for Texaco in Anchorage, Alaska (location).

    ALTERNATIVES

    Texaco strongly recommends that Alternative A (full leasing of
    the 1002 study area) be adopted by Congress as the alternative
    most compatible with national needs.

    Specifically, domestic U.S. oil production by some estimates, is
    expected to decline from aproximately 8.6 million barrels per
    day at present to an estimated 4 to 5 million barrels per day by
    the year 2000.  Assuming a modest increase in national demand,
    imports of oil, largely from politically volatile regions of the
    world, could climb to mroe than 12 million barrels per day by the
    year 2000.  Specifics aside, a strong consensus has emerged on
    the falling U.S. production na dramatically-rising import
    dependence from projections recently completed by the
    Congressional Budget Office, the Congressional Research Service,
    the Department of Energy, the National Petroleum Council, the
    American Petroleum Institute, and Data Resources Inc.

    Such great dependence upon imported oil raises a number of
    important economic, energy, and national security concerns.  API
    President Charles DiBona warned of a severe energy crisis in the
    mid-1990's in releasing the API's report, entitled "Domestic
    Petroleum Production and National Security," on December 30,
    1986.  Similarly, the interim Report of the NPC on the U.S. Oil
    and Gas Outlook noted in October 1986 that the "imminence and
    gravity of the national energy vulnerability" mandate that the
    NPC request the Secretary of Energy to convey the urgency of the
    situation to the Administration, the U.S. Congress, and the
    American people.  And, President Reagan, himself, recognized the
    seriousness of growing import depence in forming a fast-track,
    interagency study of U.S. energy security under DOE Deputy
    Secretary WIlliam Martin.  Their report is expected in February
    on March, 1987.

    Unquestionably, national security would be enhanced by the
    opening of ANWR and the anticipated discovery of substantial new
    reserves.  Without doubt production of those reserves would
    decrease U.S. dependence on foreighn oil and lower the future
    trade deficit.  But, the timing of ANWR's opening is also
    critically important.

    Although there is currently a worldwide surplus of oil, it is
    important to note that, due to the logistics of Arctic
    exploration and development, any oil discovered in ANWR in the

                                            -2-
                                                                                                                                        -3-

           near-term would not be produced until about    the year 2000.                              exploration and development at Prudhoe Bay indicates minimal
           Accordingly, Texaco believes that Alternative A should be adopted                          impact on wildlife resources.     Hence, it is reasonable to assume
           and timely access to ANWR be granted so that this source of                                that development can'proceed on the coastal plain with similar
           supply m:y be available when needed.     This approach would also                          minimal effects.0
           assure o derly. efficient development of resources In a
           non-crisis atmosphere.                                                                     Texaco would also like to take this opportunity to point out that
                                                                                                      all of the predictions of biological disaster before construction
           The economic benefits associated with the exploration and                                  of the trans-Alaska pipeline have proven false.       Animal and plant
           development of ANWR are also substantial.     Oil production    from                       life have flourished and the state and nation have shared an era
           ANWR would provide a significant new source of tax and royalty                             of great economic prosperity due to the pipeline and associated
           revenue to federal, state and local governments.      Moreover '                           oil development.    The extension of such development to the ANWR
           development of the petroleum resources underlying ANWR wouid                               coastal plain is therefore a known and proven process.
           promote economic opportunity not only in Alaska.    but also in the
           Lower 48 states.   Demand for goods and services in connection                             At several points in the report, the suggestion is offered that
           with such.. development would create jpbs and positive impacts                             oil,and gas exploration and development would "eliminate the
           nationwide.                                                                                wilderness character of the area."      Texaco acknowledges that any
                                                                                                      activity within the Refuge wi.11 affect its wilderness character;
          iln view of the national benefits which could be derived from                               however, what seems to be ignored is the fact that oil and gas
           ANWR's development, Texaco believes the remaining alternatives                             development is of limited duration. Industry's use of the area
           are unacceptable.   Alternative B prohibits leasing on part of the                         in the event of a commercial discovery is expected to span 20-50
           'area used by the Porcupine caribou herd for calving, however. the                         years.   Thereafter, the equipment would be removed and a natural
           need for this exclusion is not scientifically documented.                                  regenerative process would begin to return the wilderness quality
           Alternative C would delay leasing and development indefinitely                             to the area.
           and calls for off-structure drilling which would provide
           additional Information but would cause unnecessary delays without                          Texaco agrees that caribou of the Porcupine herd are the most
           establishing the presence or absence of oil reserves.                                      conspicuous biological community on the 1002 coastal-plain, but
           Alternatives D (no a-ction) and E (wilderness designation) are                             we believe that designation of USF&WS Resource Category I for.a
           unacceptable since each would preclude any development                                     portion of their widespread calving area in the Jago River area
           whatsoever.   Texaco believes It.would be folly to leave untested                          is not justified.    The terms "traditional". "core calving area",
           what the report terms. "clearly the most outstanding oil and gas                           "unique" and "irreplaceable" are inappropriate in this case.
           frontier remaini:g In the United States...*.      This is especially                       Concentrated calving has been observed in the Jago highlands
           true 91ven the d clining state of our national oil reserves and                            during only 5 of the past 14 years which -indicates that.the
           the lead times necessary to establish production..                                         calving habitat is not fixed at any one location along the
                                                                                                      calving habitat from Canning River to the Babbage River In
                                                                                                      Canada. - Therefore, all of this area is an acceptable calvAng.
           ENVIRONMENTAL IMPACTS                                                                      habitat.and there is nothing traditional about the Jago
                                                                                                      highlands. It just happens that on the averagei the interaction.
           The resource assessment portion of the report was conducted under                          of migration, forage, predators and weather conditions,have        ,
           a statistically based, most likely case scenario.       In contrast,                       combined to place some of the herd in that area when their cal.ves
           virtually all of the environmental impact discussions are based                            were due to be born in 5 out of 14 years of observation.
           on a worst case scenario.    Texaco is concerned that such an
           unbalanced approach could be misleading.      The major biological                         Texaco supports the USF&WS conclusion that minor to negligible
           concern appears to focus on the Porcupine caribou herd and                                 impacts may be expected to other mammalian species, to fish, to
           insufficient credit seems.to have been given to consolidation of                           fowl and to threatened and endangered species.
           facilities and the imposition of reasonable operating
           stipulations which can frequently.fully mitigate an environmental
           concern.   Furthermore. the discussion of possible effects on -the                         STIPULATIONS
           herd seems to ignore experience gained at Prudhoe Bay. Kuparuk
           River, Milne Point and Endicott.     That, despite the statement in                        Texaco believes the   Department of Interior can    responsibly   manage
           the report that "The evidence generated during the 18 years of                             any oil and gas activities which may be authorized by Congress.

                                          -4-

           In this regard, with the exception of a few provisions, the
           proposed environmental protection stipulations appear to be
           reasonable and in accordance with current oil industry practice
           in the Arctic. Texaco will more fully address this issue in our
           written submission later this month.

           CONCLUSION

           Texaco fully supports the proposed leasing recommendation by the
           Secretary of the Interior on page 169 which states in part
           the production of oil from North America's largest oil field at.
           Prudhoe Bay has taught us much about how to protect environmental
          .values. Even though billions of barrels of oil reserves have
           been brought on line and the infrastructure developed to bring
           that oil to U.S. markets, the fish and wildlife resources'of the
           Prudhoe Bay area remain extremely healthy." It is clear that the
           nation's best interests are served through the.opening of ANWR to
           energy exploration and development. We trust that Congress will
           recognize that need and act to authorize leasing within ANWR as
           presented under Alternative A.

           Thank you.

           LRN:12/31/86
           sjm:j6/C2
          *C3/DW.402
           DW.2

                                                             1-204

                                                                          'Comments from Private IndIviduals (P)

                                                                                                                                                                 Page

                                                         Adams, Made                 ...................................  ................................................................. P- 1
                                                         Anderson, Susan L           . ......................................................................................... .2
                                                         Beattie,   Joan B           ..................................................................................................3
                                                         Bergerud, A. T              . .................................................................................................4
                                                         Briggs,    Phillip. H                             .........................I .................................... 20
                                                         Brown,     Anne L           .................................................................................................. 21
                                                         Brown,     Peter D          . .................................................... ..v .............................  ............ 24
                                                         Carter-BadIlla. Susanne          ...................;.......................I .....................................I... 26
                                                         Cohen, C. AJexand&               ....................................................................................... 27
                                                         Connery, Bruce A            . .....................................I............................................. s.;  ........129

                                                         Fredricks, John P. and Anne Halley                 ............................................................... 31
                                                         GlIbreth, O.K., Jr          . .................................................................a ............................ 33
                                                         Hunter, Celia M             . ................................I ................................................................ 34
                                                         Jacobs, Laurs               .................................................................................................... 37
                                                         Jettmai, Karen              ..............I...................................I.................................................. 39
                                                         Jorgenson, Torre            .........................................................I ...................................... 41
                                                         Kleln, David R              . ........
                                                                                     ........................................................................................... 43
                                                         Martin, Philip              .............................................................................  ........................ 45
                                                         McDermott. Mark             ......................I.......................................................................... so
                                                         Miller, Debbie              .......................... ......................................................................... 62

                                                         Mitchell, Dennis W          ................................................................................  ......... 67
                                                         Mollett, Nina .... ;        .................................................................................................. 69
                                                         Nelson, Pamela S            . ............................................................................................ 71
                                                         O'Reilly, Kathleen M        ................................................................I.......................... 72
                                                         Pfeffer, Jon     ....................;................................................................................. 74
                                                         Reynolds, Martha K          . ......................................................................................... 76
                                                         Rexford, Herman S           ............................................................................................ 77
                                                         Roberts, Malcolm B          . ...................................... ................................................... 78
                                                         Ross, Donald E              . ............................................. ..................I................................ 82
                                                         Shafer, Richard V           . ..........................................I................  ................................... 85

                                                         Sloss..Jeffrey.
                                                                                     .................................................................  .................................. 87
                                                         Sutton, Laurence            ............................................. 1. ................................................. Be
                                                         Thompson. Dorothy H              ....................................................................................... 90
                                                         Tritt. Lincoln    ......................................................................................................... 93
                                                         Weinstock, June             ................................... . .................................................... ...... 94
                                                         WIckstrom, Jerry C....                                                                                        96
                                                         Witherspoon, William. D          . ................................I.................................................. 108
                                                         Wood, Virginia H            . .............................................................................................. 110
                                                         Wright, Cynthia             .................................................................................................. 112
                                                         Zemansky, G. M              . ............................................. ................................................. 115

                                                                     Marie Adams
                                                                     P.O. Box 313
                                                                     Barrow. Alaska 99723

                                                                     January 16, t93-7

                U.S. Fish & Wildlife Service
                2343 Main Interior Bldg.
                18th & C Streets, N.W.
                Washington, D.C. 20240

                ATTNt Division of Refuge Management

                I am writing to let you know what my personal views are regarding the Arctic
                National Wildlife Refuge 1002(h) report. I work for the North Slope Borough
                and have followed this issue as public information officer under the office
                of Mayor George Ahmaogak.    I attended the January 6, 1987 hearing on ANWR
                in Kaktovik.

                After listening to everyone's comments I am    in support of option B to permit
                @limited leasing. I believe that any maternal grounds or calving grounds
                should be protected from disturbance, Also, one of the reasons I support.
                option B is.because of my background as a past Executive Director o     *f the
                Alaska Eskimo Whaling Commission. Many of us involved with whaling have
                always said to explore and develop onshore oil and gas potential areas
                before going to offshore areas. I oppose the current Beaufort Sea Sale 97
                which is along the migratory path of the bowhead whale currently listed as
                an endangered specie. Regarding ANW`R, there is a lot of concern for LbU,UUU
                :
                 trong porcupine caribou heed. I would rather see exploration and development
                 f oil and gas onshore before looking at offshore areas, where technology has
                been improved with the Prudhoe Bay experience@ I do not believe technology
                for offshore arctic waiters has been developed and the price for such activity
                is too great for our people who have to depend on subsistence resources.

                One area which I   strongly believe has been neglected in your 1002(h) report
                .is coverage about what is going to happen to the local residents. The
                social impacts from Prudhoe Bay have been tremendous. We are now dealing
                WiLh Social problems never before experienced in the North because of the
                impact that the cash economy has on local people. We are facing alcohol and drug
                related disieases never before encountered by the Inupiat people in the
                Arctic Slope. We are a small population and studies should be done to enable
                our communities to at least obtain funding to deal with such impacts.

                Thank you for this opportunity to comment.

                                                                     Sincerely,

                                                                     Marie Adams

            Jan 18, 1987
           1724 Aspen
           Ft. Collins, CO 80524

           U.S. Fish and Wildlife Service
           Attn.: Division of Refuge Management
           2343 Main Interior Bldg.
           l8th and C Streets, NW
           Washington OC 20240

           Dear S I rs,

                 I am writing In regards to draft report 1002 for the Artie National
           wildli fe Refuge which was released an Nov. 24, 1986 by the U.S. Fish &
           Wildlife Service.    I am very concerned about the Fish and Wildlife Service
           recommendation of full leasing of the entire costal plain and have the
           following comments:

           1. Accidental oil spills are a known and Inevitable risk of oil exploration.
           Since 1972 there have been 23,000 spills reported to the Alaska Department
           of Energy Conservation. More oil development just means more oil spills and
           we cannot afford.any oil spills In Alaska's fragile environment.

           2. The hazardous wastes produced In all and gas production are another
           concern of mine. Where do you dispose/store such wastes In the North
           Slope? This needs to be addressed before more oil and gas drilling Is
           done in that area.

           3. What sorts of cumulative effects will oil and gas development In the Artie
           Refuge have on adjacent state and federal leases and     offshore an the outer
           continental shelf?

           4. Oil and gas exploration will have obvious negative effects on the more
           than 170,000 caribou that use that area as a calving ground and post-calving
           Insect avoidance area. But what about the lesser known, Irreversible
           effects such development will have on the soil. the Insect lifet the nutrient
           cycles, the plant life? The ecosystem needs to be considered as a whole
           when determining the consequences of oil and gas production. It has not been
           In this report.

           5. Perhaps most Importantly, I believe that the money and energy that would
           be poured Into obtaining Artie Refuge oil and gas could be used 100% more
           effectively in energy conservation and education. Oil and gas supplies
           are a limited resource and will one day be economically outdated as a means of
           keeping our country running. It just doesn't make sense to me to keep
           despoiling America's premier wilderness areas. - areas like the Artie Refuge
           when known but untapped energy conservation methods are available for use
           right now.

                 In short, I believe that full scale oil and gas leasing In the Artie
           Refuge should not be considered as an option and urge you to consider less
           environmentally damaging and longer terni solutions to our country's energy
           needs.

                                                     Sincerely,

                                                               Joan B Beattie
                                                               4380 ika Mve
                                                               Anchorage, Alaska 99508

                                                               February 3, 1987

              U.S. Fish and Wildlife Service
              2343 Main Interior Buildling
              18th and C Streets, N.W.
              'Washington, D.C. 20240

              Dear Sir,:

              The 1002 area of the Arctic National Wildlife Refuge should remain wilderness.
              I support Alternative E, which recommends wilderness designation for the entire
              Arctic Refuge coastal plain.

              I wasdisappointed that the 1002 report failed to address the cumulative effects.
              of oil and gas development@ not only within the.1002 area@ but also between the
              1002 area and adjacent state and federal lease areas on the north slope and outer
              continental shelf. The impacts of oil and gas development on a single site may
              be insignificant, but when viewed in concert with the host of other development
              sites, the impacts add up.
              I am deeply concerned that the 1002 report also  failed to adequately addeas a,.bow
              hazardous wastes will be dealt with and how sufficient water will be obtained
              .and water quality standards not compromised.

              I urge the Secretary to reconsider this unwise decision and to recommend the
              1002 area for designation as wilderness in his final report.

              Sincerely yours,

           //Joan B. Beattie

                                                                   January 28,1987.

              UNIVERSITY OF VICTORIA
              P.O. BOX                                                     Department of Biology
              TELEPtIONE(61H) 721-r21 I. -I ELEX 1)4%-72t'2                           721-7094

              Director
              Fish and Wildlife Service
              Division of Refuges
              U.S. Dept. of Interior                                                                                        AN ASSESSMENT OF PETROLEUM DEVELOPMENT ON THE STATUS OF THE PORCUPINE HERD
              Room 2343
              Main Interior Building
              18th and C Street
              Washington, D.C.
              20240

                                                                                                                                                                by

              Dear Sir,                                                                                                                                   DR. A. T. BERGERUD

                   As an interested caribou biologist, I wish to submit the enclosed
              brief relative to the impacts of full oil leasing of the 1002 lands in
              Alaska on the Porcupine Caribou HOrd.
                                                                                                                            Professor of Biology, University of Victoria, Victoria, B.C. Canada. V8W 2Y2

                                                             Yours trulyp

                                                             Dr. A. T. Bergerud

                                                             Biology Dept.
                                                             University of Victoria*

                                                             Victoria, B.C.
                                                             Canada V8W 2Y2

                                                           2                                                                                                               -3-

                           The U.S. Federal government has proposed that the 1002 lands of the

                    Arctic Coastal Plain and in the Arctic National Wildlife Refuge, Alaska,
                                                                                                                                                                     OTHER ANIMALS
                    be opened for exploration and full leasing for petroleum supplies.
                                                                                                                                                                           @OLVES -
                    Included within the 1002 proposed lease area are 242,000 acres of 311,000                                                                              CAMBOU -
                                                                                                                                                                           INSECTS
                                                                                                                                                       VARIABLE                      ---- CONSISTENT
                    acres (78%) of the.core calving area of the Porcupine Herd.(core defined                                                                                             CONTINGEVCIES
                    as areas used in > 5 of 14 years) and 934,000 acres of 2,117,000 acres                                                                             A PLACE IN
                                                                                                                                                                         WHICH TO
                    (45%) of concentrated calving area of the herd (areas with > 50 animals/                                                                                 LIVE
                      2                                                                                                                                                                     GkC64.10US
                    mi ).  Also Included in the 1002 area Is the habitat where nearly the                                                                                                   BEHAVIOUR
                                                                                                                                                                         01,14 04111TAT
                    entire herd, now estimated at 18,000 animals, masses in early July to        seek
                                                                                                                                                      .@,EVENT              FOOD       Z) STUR@ANCE
                    relief from mosquitoes.    The herd leaves the 1002 area in mid to late     July                                                   --,*V-             ,@ GROWING   B""'OUR
                                                                                                                                                                            PLANTS
                    and does not return until the following May.      I have been asked as a
                    caribou biologist,    by AOCA, to evaluate the impact of full leasing and                                                                            WEATHER
                    development on the viability of the herd and specific     ally to critique the                                                                           SNOW
                                                                                                                                                                              .No

                    environmental impact statement prepared by the Fish and Wildlife Service

                    on,the proposed full leasing and development.

                    Background Theoretical Considerations

                           The environment of the caribou (Rangife      tarandus) can be segregated

                    Into: other animals, a place _Ln which to live, food and weather (Fig. 1,

                    Andrews rtha and Birch 1954). The interactions of caribou with insects,

                    open habitats, food and weather represent variable contingencies that                                            Figure 1.   Diagram of the proposed manner in which the four components
                    result in facultative responses by caribou that can be modified relative                                                     of the environment interact as variable and consistent
                    to disturbance factors (Fig. 1).     The Interactions of caribou with other                                                  contingencies I  n the development of movemento aggregation*
                    caribou and with wolves in.open environments are consistent contingencies                                                    gregarious and disturbance behaviour of caribou (Bergerud 1974b).
                    affecting reproductive fitness - these are obligatory responses that will

                    respond to change very slowly, If at all, when habitats are modified.

                                                        4

                  I feet that the major behavioral responses of caribou in the 1002 area                                       structures.   The nomadic life style of caribou and its propensity for

                  are the Insect x weather facultative responses and the predator x habitat                                    shifting habitats makes it as adaptable to short term habitat alterations
                  obligatory responses.   Unlike many biologists, I do not feel that food is                                   as it is to the slow succession of lichen following natural fires and
                    major factor in the calv ing and massing of caribou in June and July in                                    regeneration cycles.   The unwary nature of caribou means that they can
                   he 1002 area.                                                                                               coinhabit range with man if not overhunted. in fact, reindeer (Rangifer

                                                                                                                               tarandus) are an important domestic animal in Eurasia. Several caribou

                  Are Caribou Wilderness Animals?                                                                              researchers have noted that caribou are both highly adapted and adaptable
                         Much of the concern for the well-being of caribou arises from the                                     (Skoog 1968, Bergerud 1974b, Roby 1978, Skogland, pers. comm.).

                  view that caribou are wilderness animals that cannot adapt to coinhabiting.

                  ranges with man.   This concept has arisen, in part, because caribou are                                     Resource-Limited by Food?
                  found on ranges far removed from major developments.     Also, caribou herds                                        Another basic philosophy that influences how some caribou biologists
                  have declined on the southern edge of their range as settlement proceeded                                    view the impacts of development on caribou Is the closely held belief
                  (Cringan 1956).  Thirdly, caribou are unwary and easily over-exploited.                                      that the carrying capacity of the habitat for caribou is determined by
                  And lastly, caribou utilize stow-growing lichens that are many years in                                      food resources, the slow growing lichens in winter, and green plants in
                  recovering following forest fires.                                                                           the summer.  It follows from this belief that if caribou are displaced
                         However, a closer examination of these facts suggests that they are                                   by development and lose part of their range, then the potential carrying
                  not sufficient to define caribou as wilderness animals nor to imply that                                     capacity is reduced.   Another concern is that, if the animals are at a
                  loss of wilderness per se will bring about the demise of herds.     Obviously,                               carrying capacity limited by food, then additional disturbance may stress
                  mule deer (0docoileus hemionus) and antelope (Antilocapra americans) were                                    the animals, thereby reducing reproductive rates.and increasing mortality
                  once far removed from European man in the 1700's, but they are not called                                    rates.  A further refinement Is that caribou select their calving grounds
                  wilderness animals today; they have adapted.    The decline of caribou along                                 to maximize the quantity and quality of the diet - to optimally forage
                  their southern boundary was due to increased predation from man and                                          (Kuropat and Bryant 1980). Hence displacement from the calving areas
                  natural predators, as well as from disease contracted from white-tailed                                      should adversely affect the herd.
                  deer (0docoileus virginianus) (Bergerud 1974a) and not from outright                                                As an. example of this type of thinking, Whitten and Cameron (Arctic
                  habitat alteration.  There is no evidence that herds abandonned their                                        (1984:293) said, speaking of developmental impacts, "For example, a series
                ,annual ranges because of an intrinsic aversion to man or man-made                                             of mild winters might compensate for the negative effects of harassment or

                                                             6                                                                                                                    7

                     habitat loss.", Bergerud, Jakimchuk and Carruthers replied (Arctic                                                  indicated that the herd would be limited by wolf predation at densities
                     1984:295) "The supposition advanced by Whitten and Cameron... assumes:                                              far below those imposed by food resources (Walters et al. 1979).
                       (1)  that winterconditions limit,caribo.u numbers (this has never been                                                   Both reproductive and natural mortality rates of caribou are
                            substantiated in mainland North America);                                                                    little affected by winter food supplies.       Fecundity is.relatively fixed
                       (2)  that harassment results In caribou mortality        never substantiated                                      at I calf/femate/year for females > 3 years-of-age regardless of densities
                            and the extreme case (Pot Hill    data)   given.in our paper represents                                      (Birgerud 1971, Skogland 1986).      Skogiand provided an equation for
                            the best available contrary evidence     pertaining to this assumption;                                      recruitment for females > I year in Norway, where there are few predators,
                                                                                                                                                                                   2
                       (3)  that, habitat loss (unspecified)   has governed caribou numbers                                              where R - 0.65    0.012 Dw   --0.00013 Dw@ where Dw = caribou/km     2.  Even at
                            (.greater evidence for the opposite case is available in the                                                 a densit y of 10 caribou/km  2 of winter range, recruitment would equal 52
                            literature);                                                                                                 yeartings/100 females.    At a density of 10 animals/km    2  the Porcupine
                       (4)  that ranges are at ca  .rrying capacity    which is not the case for    any                                  Herd would number 1,800,000 animals; and even this density would         not hold
                            of the herds we discussed;                                                                                   since this many caribou would have greatly expanded their range.
        @4             (5)  finally, that the supposition    has some basis   in fact.   However, this                                         'In North America, in herds coexisting with wolves, recruitment is
                            supposition has never been researched."                                                                      commonly less.than 25 yearlings/100 females and yet.densities seldom
                     Sucha  seemingly innocuous statement, as made by     Whitten and   Cameron,                                         exceed 2 caribou/km  2 (Bergerud  1980).   This disparity in densities and
                     reveals a  basic philosopy of food limitation, and Is the cornerstone        of                                     recruitment between Norway and North America is due to predation in
                     many dire  predictions of caribou demise with development.                                                          North America.   Predation limits populations far below that provided by
                            But in fact, the carrying capacity of this herd is not limited by                                            food supplies (Bergerud et al. 19B3).
                     winter food supplies.    The dynamics of the Porcupine Herd were modelled                                                  Carrying capacity has been defined as that point where recruitment
                     in a workshop at the University of British Columbia In 1978.         The herd                                       natural mortality (Caughley-1977).      For caribou on mainland North America
                     then numbered 110,000.    The.simulation model indicated that the herd was                                          the carrying capacity is determined by the abundance of predators
                     not limited by winter food supplies.      Food would not be limiting until the                                      (Bergerud.:nd El Ilot 1986).   Recruitment equalled natural mortality for
                                                                                                                                                                          2
                     herd reached about one million animals.      The simulation even Indicated                                          22 herds    6.5 wolves/1000 km     (Bergerud and Elliot 1986) regardless of
                     that If no animals crossed the Dempster Highway and the entire range east                                           the density of caribou on the wi   nter range.
                     of the road in the Ogilvie Mts was    lost, the herd could    still prosper if

                     food resources were the only consideration. The same simulation, however,

                                                         8

                  Long Term  vs. Short Term, Individual vs. Herd                                                                is, why not?    The Central Arctic Herd spends its entire annual cycle
                          Bergerud_Jakimchuk and Carruthers (1984) reviewed the demography                                      quite close to  Ithe development zone - the Porcupine Herd spends only two
                  of 8 herds relative to disturbance by human activities.      They concluded                                   months.  All the animals now alive in the Central Arctic Herd have been
                  that the major impacts were (1) the building of transportation corridors                                      born since development commenced; they have adapted.     The basic reason
                  that permitted increased human harvests of caribou and (2) the                                                that some biologists cannot accept that caribou can cope with development
                  improvement In calf survival when wolves were reduced.      Caribou herds                                     Is their ingrained views that caribou    are "wilderness animals" and that
                  continued to cross roads, and herds such as those in Newfoundland, still                                      food supplies are limiting.   The new research work planned for the
                  prospered when habitats were altered by logging and flooding. The Central
                                                                                                                                Porcupine by the Alaska Fish and Came Is proceeding on this basis. Now
                  Arctic Herd in Alaska increased from about 5,000 to 13,000 (early 1970's
                                                                                                                                caribou will be radio-tracked by satellites and energy budgets calculated
                  to 1984) despite the Prudhoe Bay all field.                                                                   daily, perhaps hourly. It all flows from the unsupported belief that
                         The conclusions of Bergerud et al. (1984) were debated in letters
                                                                                                                                nutrients and enetgy will ultimately limit total numbers of caribou in
                  to the editor by Whitten and Cameron (Arctic 1984:293)p Klein and White
                                                                                                                                this herd.
                  (Arctic 1984:293-294) and Miller and Gunn (Arctic 1985:154-155).
                  Rebuttals to all letters were provided by Bergerud and Jakimchuk      (Arctic                                 Biology of Calving and Aggregating Behavior
                  1984:294-295, Arctic 1985:155-156). Klein and White agreed that      the
                                                                                                                                      Before we can evaluate the potential    impacts of development on   the
                  herds were increasing but thought that disturbance must be viewed on a
                                                                                                                                Porcupine Herd we must determine why the animals use the Coastal Plain in
                  long term basis.   But this is a nonsequitur - if there are no effects of                                     the 1002 area for calving and grouping afte  Ir calving.  Basically, what are
                  disturbance for a short terniq how are they significant on a long term? The
                                                                                                                                the environmental factors that determine where caribou locate their
                  .long term Is the addition of short term intervals. Miller and Gunn agreed                                    calving grounds?
                  that the herds were increasing but stated that   Idisturbance must be viewed                                        The calving grounds of the migratory herds in the liolarctic are
                  on the basis of the individual, not the herd.     Again, this Is a                                            usually located on the northern distribution of the herd's range in
                  nonsequitur - since individuals comprise herds, if the herds are                                              tundra habitats (Appendix I:FIg. I). The cows leave the bulls and
                  prospering, then the individuals are also faring well.                                                        commence migration towards these areas generally in April before green
                         Now, there are new arguments that the prosperity of the Central
                                                                                                                                plants appear. Some herds migrate northeastv others northwest, and two
                  Arctic Herd in the face of development cannot be used to gauge the success                                    herds south of Hudson Bay even migrate east.   The consistent factor in all
                  of the Porcupine Herd when faced with similar development and the question
                                                                                                                                these migrations is that cows cross the tree-line at right angles

                                                         10

                     (Appendix I:Fig. 1) Wolves in North America generally den near tree line                                   grounds of the Porcupine Herd on 5 May 1974 and 12 May 1975 when snow

                     (Appendix 11).   By migrating at right angles to the tree line the cows                                    cover was light; they arrived ZO May 1976 and 24 Ilay 1973 with medium snow

                     can maximize their distance from wolves, with the least effort.     Caribou                                cover and even later 'on 26 May and 30 May when winter snows had been

                     cows migrate and calve on the bleak inhospitable arctic tundra to reduce                                   heavy (Curatolo and Roseneau 1977).    The calving ground of the Porcupine

                     contact with wolves (Appendix II) and there are very few wolves on the                                     Herd Is on the areas of reduced snow cover generally sandwiched between

                     calving grounds of the Porcupine Herd.                                                                     the foothills and the slightly colder coastal strip (Fig. 2).     In an

                            An alternative hypothesis is that caribou seek their northern                                       early spring, as in 1974, the animals will be farther west and north than

                     tundra calving grounds to optimally forage, primarily on Eriophorum                                        in late years such as 1972 and 1973.    In an early year, more caribou will

                     angustifolium  (Kuropat and Bryant 1980).   1 was able to disprove this                                    calve in the 1002 area than in a late year.    In 198Z, the season was so

                     hypothesis in 1984 by comparing the nitrogen in fecal droppings and plants                                 retarded that the herd calved in the Yukon (ANWR Progress Rept FY 83-6).

                     at the time of calving between cows on calving grounds and bulls still                                     We can think of the annual variations as caused by snow induced

                     south of calvin g grounds. The bulls were feeding in more nutritious plant                                 limitations to the  basic spacing antipredator tactic.    But within this
         (0          communities than the cows (Appendix I:Table 1).    If the calving grounds                                  tactic, to maximize   the distance from tree line, the animals also need

                     were really unique in the quality of forage  then the bulls should have                                    to find brown substrates so that calves can be cryptic, especially to

                     been with the cows.  If the cows were primarily "Interested" in the                                        avoid predation from golden eagles (Aquila chrysaeto ).    Thus snow cover

                     quality of their forage,they should have stayed back with the bulls.                                       affects the distribution within the coastal plain but not the overall

                     The fact that cows commonly calve on Erlophorum tussock associations     may                               regional distribution.

                     be due to the particular microtopography of these habitats which results                                          We know less about the extrinsic and socialization factors in the

                     in little accumulation of snow and early snow melt (Benson 1969). That                                     massing of caribou in late June and July than we know about calving.     In

                     is not to say that caribou do.not optimally forage within the constraints                                  some years, such as 1976 and 1981, no large aggregations formed.     But in

                     of selecting the best overall habitat to avoid predators. However, over                                    all years, the animals concentrate on the 1002 lands. This occurred even

                     all, the diet of the cows in late May and early June is not highly                                         in 1982 when the herd calved In the Yukon (ARWR Progress Rept. FY 83-6).

                   'nutritious (Appendix I:Table 1) and this has resulted because of their own                                  We also know that the Porcupine Herd is unique that in some years the

                   .migratory behaviour.                                                                                        entire herd comes together for a few days in July. This represents the

                           The location of the calving grounds varies between years because.of                                  most spectacular aggregation of ungulates in North America and compares

                     annual variations inanow cover.   The caribou arrived on the calving                                       favorably with the aggregating of the wiidebeeste (Connochaetes taurinus)

                                                        12
                                                                                                                                                                13

                                 RUDHOE                                                                                     on the Serengeti.
                                             BARTER                                                                                                                          r calves group together
                                                                                                                                   Initially, after calving,  cows with thei
                                                  is

                                                                                                                            in the vicinity of where the  calves were born (Lent 1966, Bergerud 1974b).
                                                               HERSCHEL
                                                                   18
                                                                                                                            This aggregating represents another antipredator tactic. A caribou calf

                                                                                                                            will benefit if there is another animal between itself and a predator

                                                                                                                            (the selfish herd concept) (Appendix II). Later, with the onset of the

                                                                                                                            mosquitoes, the caribou in the Porcupine Herd move to the coast where

                                                                                                                            cooler temperatures and fog provide some relief. The animals are usually

                                                                                                                            concentrated in July south of.Barter Island in the 1002 Lands.
                                                                          ----------
                                                                                     NWT                                           Why is this particular strip of coast selected? The animals   . may
                                                                                                                            select the coast adjacent to Barter Island simply because the core
                          ALASKA                                  YUKON                                                     calving area is near the Jago River, hence a direct route to the coast

                                                                                                                            Leads to Barter Island.   In support of this view, in 1974, when the
                        CALVING AREA
                                                                                                                            concentrated calving was along the  I'atakturuk River, the post calving
                           504Y. SNOW COVER
                . ..... LANDSAT BOUNDARY                                                                                    grouping was at nearby Camden Bay. But to the contrary of this sequence,

                     0     so     ISO    240 Iwn                                                                            when the animals calved near Herschel Island in 1982, they still travelled

                                                                                                                            up the coast after calving to the area adjacent to Barter Island (ANWR

                                                                                                                            Progress Rept. FY 83-6). This fidelity to the coast opposite Barter

                                                                                                                            Island could be due primarily to (1) tradition and socialization, or it

                                                                                                                            might result because (2) the animals may, between the end of calving and

                                                                                                                            the emergence of insects, follow the green phenology west, or, (3) the
                  Figure 2. The snow profile of northeastern Alaska in late May 1978 (from
                                                                                                                            concentration at Barter Island may relate to some additional relief factor
                             Lent 1980).
                                                                                                                            from mosquitoes. For example, a small herd of 2000 animals on the Hudson

                                                                                                                            Bay Coast in Ontario aggregates In July on the tidal benches where there

                                                                                                                            are large mud flats. In the absence of vegetation to hold insects, these

                                                                                                                            caribou probably gain added relief from mosquitoes. This same situation

                                                             14                                                                                                                  15

                      may hold for the tidal flats near Barter Island. Thus we don't know if
                                                                                                                                         a 50% avoidance of adjacent habitats at 2 kilometers from the road and no
                      the uniqueness of the gathering near B    Iarter Island is because of its                                          avoidance at 3 kilomete   Ira (p.I100:Fig. 4).   Thus there should be 50%
                      juxtaposition to calving locations or if the area, per se, has its own
                                                                                                                                         avoldancelat 1.2 miles and -no avoidance at 1.9 miles. Actually, Murphy
                      special attraction.                                                                                                and Curatolo (in press) show thatcaribou, including cows and calves,

                                                                                                                                         resume normal foraging and daily activities when 600 meters from active
                      Critique of the Arctic National Vi    ldlife Refuge-Alaska Coastal     Plain                                       roads in the Prudhoe oil field.     Therefore, a max   .imum statement is that
                         Resource Assessment
                                                                                                                                         maternal cows avoid about a I@ mile strip on each side of the read; thus

                              My comments are limited here to the full leasing option and are                                            the displacement statements In the report should be reduced substantially.
                      restricted to caribou. This is the worst case scenario and many of my                                                     If development proceeds in area 3 as shown on page 7 of the

                      comments will reflect my view that caribou can adapt to full leasing and                                           assessment a Itatement, there would be 47 miles of road in the core calving
                      developing if  .the proper mitigating actions are taken.      I will only discuss                                  area.  We could expect maternalcows to be displaced from an area of 141
                      my major criticisms, which does not mean that I necessarily agree with                                             MiZ or about 90,000 acres. However, the area between the two parallel

                      sections not  discussed.                                                                                           roads in the hypothetical development would also probably be lost.

                                                                                                                                         Parallel roads to reach different objectives should be avoided. However,

                      2 mile limit: On several pages it is suggested that maternal cows wi        11                                     parallel roads to reach the same objective might be a way to re-direct
                      avoid a strip 2-miles out from major roads and development.         This implies                                   traffic to minimize disturbanc  Ia, depending upon which route has the most
                      a 4-mile displacement when both sides of the road are considered. The                                              caribou nearby.

                      reference for this avoidance strip is Dau and Cameron (1986). Based an
                      this 2-mile rule, the report calculates the acreage      .lost to caribou from                                     P. 28, Para. 1.   "The bower Levels of earlier estimates may reflect a
                      development.   Firstly, the concern should not be the lost acreage as it                                           truly smaller population, less accurate or less complete survey
                      relates to carrying capacity. The cows have not selected the coastal plain                                         techniques,...".   Because the Porcupine herd gathers in one or a few
                      for it forage resources but to avoid predators.       If wolves travel the                                         major aggregations, the census results of the herd by aerial photography
                      haul road, as they did the TAPS highway (Roby 1978) it will be                                                     Is highly accurate. The herd has definitely been Increasing. This
                      advantageous for caribou to avoid the habitat adjacent to the        ,road.                                        increase has resulted from greater calf.survival (Fig. 3). The increased
                    .Secondly, Dau and Cameron (1986) did not show caribou avoidance of a                                                calf survival occurred because wolves were reduced by rabies in the late
                      2-m.Ile strip on both sides of travel routes. Dau and Cameron documented                                           1970's and early 1980's. Jakimchuk and associates saw considerably more
                                                                                                                                         wolves in 1971 and 1972 than have been seen in recent years.

                                                              16
                                                                                                                                                                                 17

                                                                                                                                          P. 29, Para. 4.    "Access to Insect-relief habitat and forage resources
                                  0 JULY                                                                                                  during th Is period may be   sritical to herd produc   tivity." No one has
                                  A AUTUMN
                                                                                                                                          documented that fecundity or calf survival have been affected by failure
                       z          r=o.658, n@to                                                                                           to reach mosquito relief habitat. There are no other large herds in
                          TO         EXCLUDES 19"
                                                                                                                                          North America that have access to a foggy coastal strip. Even if the

                                                                                                                                          animals could not use the coastal strip this would only put them on par
                       0                                            A                                                                     with other herds. Note that there were an excellent 59 calves/100 cows
                       >. 60-
                       _j                                                                                                                 in July 1976; in that year the animals did not mass on the shores of the

                                                                         0                                                                coast. However, if caribou did seek the       foothills for Insect relief,
                       z
                    C>@-  50                                                                                                              reduced calf survival would    be expected because of increased predat     .ion.
                    C+_                                                                                                                          In this paragraph and throughout the report, the word "productivity"
                       0                                                                                                                  Is used as a synonym for "recruitment". This is an unfortunate usage. To
                       0
                       Cr. 40                                                             ENCL"D                                          many ecologists, productivity brings to mind "to produce", the elements
                       W
                       CL                                                                                                                 of reproduction, and for others it implies biomass as in the terms
                       (a                         A                                                                                       primary and secondary productivity.      The use of the word "productivity"
                       W                          Y       4474. Z5 iL z. z-91 X
                       _j                                                                                                                 comes with the philosophy of a food carrying capacity. For many ungulates
                          30-     A
                                                                                                                                          In the lower 48 states (where there are no wolves) the number of young

                                                                                                                                          born per 100 adult females does vary with nutritional conditions. In

                                                                                                                                          these southern ungulates, the final recruitment may indeed reflect the

                                 1972       1974       1976       1978       1980       1902       1984                                   initial variations in pregnancy percentages. For caribou, we should use
                                                        COHORTS                                                                           the terms "fecundity", "parous percentage", or "pregnancy rate" to

                                                                                                                                          describe the initial number of calves/100 tows at birth, prior to

                                                                                                                                          mortality. The emphasis thereafter should be on documenting the survival
                       Figure 3.  The regression of calf survival (calves/100           on year.                                          or mortality statistics; the final yearlings/100 females parameter at

                                                                                                                                          12 months should be called "recruitment". "Productivity" Is a catch-all

                                                                                                                                          and reveals a basic indoctrination that the resources of the land result
                                                                    A

                                                                              A

                                                                                                                                                                                19

                      in cows being productive or not productive.       Since fecundity is fixed in                                     displacement of caribou farther south towards tree linelt will result in

                      mature caribou the emphasis should always be on survival after the calves                                         Increased predation (Fig. 4) and reduced survival.       "Loss of important

                      are born.                                                                                                         habitat has been shown to directly impact ungulate populations (Wolfe,

                                                                                                                                        1978; SkovIin, 1982)'. This is a general motherhood statement and these

                      P. 29, Para. 10.    "Riparian areas are used for travel corridors...".                                            references are for ungulates living without wolves and are not

                      This does not sound feasible since wolves also use riparian areas for                                             appropriate for the Porcupine Herd.      When caribou herds increase they

                      travel.   Caribou in Spatsizi, B.C. avoid ambush cover in tall willows                                            expan d their range and when they decline the range shrinks (Bergerud

                      (Bergerud, Butler and Miller 1984). Also the streams are in flood in                                              1980). Calf survival drives numbers and hence range occupancy.

                      late May and early June and are not suitable for small calves.        In                                          "...Whitten and Cameron (1985) contend that the CAH has not experienced

                      Svalbard, T. Skogland (pers. comm.) indicated that bull caribou use the                                           a reduction In productivity ... because (1) the CAM has been displace
                      riparian communities and flood plains but cows avoid these dangerous                                              from only a part of its calving grounds;...". The herd could be

                      areas.  Curatolo (1985) also indicated that butts used      the riparian                                          dis placed from all of its calving area and still not decline if predator

         CO           community but cows generally avoid them (seealsoRoby 1978).                                                       numbers were managed. The CAH herd increased 1972 to 1985 because of

                                                                                                                                        high calf survival since wolf numbers had declined with development. As

                      P. 10.8, Para. 1.  "Caribou select calving areas because of favorable.....                                        their second point, Whitten and Cameron argued that the CAH did not

                      .advanced new vegetation. ..proximity to insect relief habitat...".                                               decline with development because "...(2) suitable alternative

                      Caribou only select calving grounds to avoid predators (Appendix I,11).                                           high-quality,habitat appears available...".      The habitat at Prudhoe Bay

                      The report is too general in using the word "insect-relief".         Generally,                                   is,so poor that White et al. (1975) calculated some negative energy

                      Insect relief is meant to include both mosquitoes and oestrid flies,                                              budgets and thought that the herd was energy-limited when it numbered a

                      whereas the coastal habitats that the caribou seek are to escape only                                             few thousand animals in the early 1970's.      Again, the habitat was thought

                      mosquitoes.   Oestrids do not emerge until late in July, when the animals                                         to be so poor from a forage standpoint that Skogland (1980) listed it as

                      have left the 1002 lands.                                                                                         the area with the least plant biomass of 6 herds in the Holarctic.          Yet

                                                                                                                                        today the CAH has grown to >15,000 animals. Point 2 of Whitten and

                      P. 108, Para. 2.   "Displacement of the PCH from a core calving area to a                                         Cameron (1985), referenced in the assessment statement, is an ad hoc

                      -less desirable area would be expected to reduce productivity'.        Again,                                     hypothesis to explain away the herd*t prosperity in the face of

                      the word should not be productivity.     If the development results in a                                          development.  As their last point, Whitten and Cameron felt that the CAH

    					20

    			JULY

    			AUTUMN

    				25		30		35		40		45

    			MEAN MILES FROM TREE-LINE TO SOUTHERN

    				BOUNDARY OF MAJOR AREA OF CALVING

    Figure 4.  The regression of calf survival (calves/100  _ _) on distance of

    		calving ground from tree line.

    							21

    has not declined with development because the "...(3) overall density of

    CAH caribou on ther calving grounds is much lower than that of arctic

    herds in Alaska".  Again, this reflects Whitten and Cmeron's dogmatic

    opinion that forage determines numbers.  The CAH calving ground is about

    125 miles from tree line and the PCH, only 30-40 miles.  Given the much

    larger "safe" space, the cows in the CAH are also able to disperse which

    is another antipredator tactic (Appendix II).  The animals in the PCH

    herd, faced with less space, are not aggregated.  Again this is expected,

    if the animals were dispersed, many would be nearer tree line and at

    greater predation risk.  Since food supplies are not limiting for either

    herd, the greater densities for the PCH are not a problem.  In fact the

    aggregating is a tactic to avoid predators; when animals face food

    problems such as in the high arctic or on Svalbard, the groups disperse

    and densities are low (T. Skogland and F. miller, pers. comm.).

    P. 108, Para. 3.  "Both absolute..."  This paragraph is irrelevant.  One

    cannot use density figures (see above) to argue that the PCH will face

    greater consequences than the CAH from development.  The CAH lives year

    round with development and has prospered;  the PCH will only b enear the

    development for 2-3 months.  Densities are functions of aggregating

    behaviour and the lower densities for the CAH than the PCH mean greater

    forage as well as less space for the PCH, and in no way signify the

    density-dependent problems that Whitten and Cameron imply.

    P. 108, Para. 4.  "With the CAH calving density remaining low compared to

    other herds,...overcrowding and consequent habitat stress that might

                                                                                                                                                                         23
                                                            22

                       result in reduced productivity have not yet occurred,            This                                      and fatten for winter. Remember that the Porcupine herd has a unique fog
                       statement Is not correct;   there is no habitat stress.   The CAH cows                                     belt for insect relief that other herds do not have and even they (PCH)
                       have selected their calving range, with its low plant biomass, to avoid                                    desert the mosquito relief habitat by mid-July.     Murphy and Curatolo
                       predators.  Cows in other herds in North America are also prepared to                                      (in press) showed that caribou at Prudhoe Bay, away from the road, feed
                       sacrifice optimal foraging to avoid predators (Ferguson 1982, Bergerud                                     53% of the day prior to mosquito emergence, 41% with mosquito harassment
                       et at. 1984).                                                                                              and 29% with oestrids on the wing.    Oestrid flies harass caribou more than
                                                                                                                                  do mosquitoes and yet PCH animals contend with oestrid flies well inland

                       P. 108, Para. 5.  "The PCH is much more crowded..." They are not                                           in August.

                       crowded - they aggregate to maintain maximum distance from tree line.
                                                                                                                                  P. 112, Para. 4. (and p. 132 as well) "These changes ... could result in
                       P. 109,.Para. 2.  This paragraph continues to discuss insect disturbance.                                  a major population decline and change in distribution of 20-40 percent..."
                       But what is involved is primarily mosquitoes.    Oestrid flies are not on                                  They have provided no data to show a 20-40% population decline.       Neither
                       the wing until the animals leave the 1002 lands.    Helle in his                                           was a to ncensus reached an the magnitude of any negative effects on the
                       publications was primarily concerned with oestrids and other flies and not                                 PCH population size or distribution by the. 14 specialists at the Caribou
                       mosquitoes.  To quote their work in this context of causing mortality is                                   Impact Analysis Workshop (ANWR) in November, 1985.     1 believe that the
                       stretching the argument.                                                                                   caribou will continue to use the 1002 lands with development, except near
                                                                                                                                  active roads. Even if there was some displacement, there is no need for
                       P. 109, Para. 6.  "Failure to obtain relief from Insect harassment from                                    the herd to decline if wolf populations are managed to provide positive
                       either factor (barrier or displacement) could shorten foraging time,                                       recruitme'nt or calf survival sufficien t to balance natural and hunting

                       leading to poorer physical condition and subsequently to increased                                         mortality.

                       susceptibility to predation and reduced overwinter survival."
                       The 1976 and 1981 cohorts did not apparently use the coast line for insect                                 P. 112, Para. 5.   "The population decline or distribution change would be
                     @relief and these cohorts did quite well. These animals are not on a fine                                    5 - 10 percent for the  CAH throughout its range." There is no evidence
                       edge in physical condition.  No one has documented winter starvation in                                    to support such a decline.    A change in distribution cannot cause a
                       North America as a result of high insect years.   When the insects abate                                   decline unless it changes the reproductive or mortality rates.       Caribou,
                       In late August and September, the animals are able to recoop their losses                                  even In undisturbed populations, frequently exhibit range shifts,

                                                           24                                                                                                         25

                    including areas used for cal4ing. Why can't the authors be objective?
                                                                                                                                   cross a pipeline.-road corridor more readily than the CAN.      Also, the
                    The empirical .evidence is th  .ere for all to see; the CAN incre ased                                         PCH caribou should cross rather than be funneled by the corridor because
                    coincident with development becau  .se predator numbers were reduced.                                          caribou should not be easil  ,y deflected when undertaking di rectional
                    [low can the field findings be twisted to fit preconceived ideas?                                              shifts to antipredator and mosquito-relief habitat.

                                                                                                                                          Certainly, every effort must be made to allow the animals to
                    Impacts and Mitigation                                                                                         continue to use all their potential space to avoid predators.        Initially,
                           The one guarenteed impact of the development of the 1002 lands                                          unItil the impact of the corridor is understood, traffic will have to be
                    will be that cows with young calves will avoid active roads for a dist:ance                                    prohibited in the period May 15-June 10 within several miles of cows
                    of )1.2 miles.   This is based both on theoretical considerations (Bergerud                                    moving west or north towards the road.     Another effort to mitigate the
                                                                                                                                   -effect of the corridor should be to reduce its visual impact as seen by
                    et al. 1984) and empirical observations (Dau and Cameron 1986). The
                    loss of this habitat will not cause additional stress on th    .e animals                                      animals entering the area (moving north and west). Once in the area, the
                    since they are not nutritionally limited. Nor will activity budgets       be                                   animals will find their way out.    If ramps are built they are more
        0)          seriously altered by development activities (Murphy and Curatolo in                                            important on the south side.of the  Iroad than on the north side.     Murphy
                    press).  It might be more serious if the animals'remained near the road                                        and Curatolo (in press) have shown that disturbance is greater when there
                                                                                                                                   Is an active road combined with a pipeline. Theoretically the vehicle
                    where predators may travel.    We do not want these cows to habituate to
                    traffic because this would suggest that they might become less vary to                                         appears as a predator - and the pipeline as the ambush cover.      The
                    their natural predators.                                                                                       pipeline and haul road should be separated by at least 1 km with the
                           An impact that might affect calf survival would     be if the females                                   pipeline north of the road. Pipelines should be cryptic (painted green
                    in May failed to cross the east-west haul road because of the traffic                                          and brown), be motionless and scentless.
                    :nd shifted their, calving distribution closer to the foothl   .Ila where                                             Another potential impact Is that the road facilities will increase
                    here are greater numbers of wolves and bears.      Such a barrier affect                                       predator access.to the herd.   Wolves can be expected to move north down
                    has not resulted from the TAPS corridor and haul road. The CAN animals                                         river valleys and then move laterally* using the road to cross rivers.
                    have crossed the road and shifted their.distributions between years,                                           east and west.  The cows ' by calving between north-south river valleys,
                                                                                                                                   have in the past taken advantage of the rivers as potential barriers to
                    making use of habitats both east and west of the corridor. Presumably,
                    these shifts relate to snow cover (Jakimchuk pers. comm.).      The PC"                                        east-west movements of predators, especially since the rivers are in
                    herd, since it is both more migratory and larger than the CAN, should                                          flood in late May and early June.    We do not want to increase the ease of

                                                          26                                                                                                            27

                     access to calving areas for predators by development (Bergerud 1985).                                        see that this massing does not become a memory as did the thundering
                             Even if the calving animals are displaced southwards by the                                          buffalo herds of the plains.    The animals should continue to mass in the
                     corridor, the PCH can remain a viable herd if predator populations are                                       undisturbed KIC lands, adjacent to the coast, In a wilderness setting.
                     managed.  It is an incredible omission in this impact statement that                                                Because I believe caribou can coexist in close proximity to an
                     predator management was not mentioned.    The reduction of wolves Is our                                     ethical man,, I look forward to the day when I can go on a guided tour

                                                                                                                                  down the'Haul road and view this massing of the mighty legions in July.
                     major tool to improve calf survival. Wolves would not necessarily have
                     to be reduced on the Coastal Plain. Control operations could take place                                      The day will surely come when the old rigs will have been dismantled,
                     on the winter range.  The goal would be to have recruitment equal                                            the pipes disassembled, the scars left to heel, and the wind again
                     natural mortality + hunting mortality, which means, for the Porcupine                                        sweeps unrestricted across the cotton grass plains.     The caribou will
                     herd, that about 12% of the herd should be yearlings in April-May                                            still be there in uncounted numbers, coming,as always down their
                     (Bergerud and Elliot 1986).   This oil development may provide advantages                                    ancestral tracks, and, we too will be there to see and marvel at the
                     for predators.  Once we disturb the status-quo, we must be prepared to                                       majestics of our fellow species.

                     manage the predators. This management is the fail-safe position.
         -4

                             I believe that the PCH will cross the ha ul road in seeking mosquito

                     relief  along the coast.  The cow and calf that Curatolo (1986)

                     radio-tracked in the CAU herd crossed the road 8 times In one mosquito

                     season.  Once a large herd starts across it will continue even if a

                     vehicle approaches. Certainly large herds moving meat and north will

                     have to be monitored hourly as they approach the corridor and all traffic

                     halted or rerouted. However, even if the animals did not cross and gain

                     the coastal strip, I believe that the herd wuould be little affected in

                     its vitality.

                             The one fact that we cannot escape is that the wilderness character

                     of the coas talL plain will be lost for decades. The post calving

                     j4ggregation of the Porcupine Herd is the most spectacular large mammal*

                     display on the North American continent. We must do all that we can to

                                                            28                                                                                                                29

                                                     REFEREHCFS                                                                       BERGERUD9 A. T, E. MERCER, K. CURNEW, and M. NOLAN.         1983. Growth of

                                                                                                                                               the Avalon caribou herd. J. Wildl. Manage. 47:989-998.
                      ANnREWARTHA, H. G. and L. C. BIRCH. 1954. The distribution and                                                  CAUGHLEY   G.  1977. Analysis of vertebrate populations. John Wiley and
                              abundance of animals.    Univ. of Chicago Press. 782 pp.                                                         Sons. N.Y. 234 pp.
                      BENSON, C. S.    1969. The seasonal snow cover of Arctic Alaska. Research                                       CRINGAN, A. T.    1956.  Some aspects of the biology of caribou and a study
                              Paper No. 51.   Arctic Inst. of North America. 86 pp.                                                            of the woodland caribou range of the Slate Islands, Lake Superior,
                      BERGERUT), A. T. 1971. The population dynamics of Newfoundland caribou.                                                  Ontario. N.A. thesis, University of Toronto. 300 pp.
                              Wildl. Monogr. No. 25. 55 pp.                                                                           CURATOLOO J. A.    1985. Sexual segregation and habitat use by the Central
                      BERGERUD, A. T.    1974a. Decline of caribou in North     America following                                              Arctic caribou herd during the summer. 2nd North American Caribou
                              settlement. J. Wildl. Manage. 38: 757-770.                                                                       Workshop, Val Morin, Quebec. pp. 193-198.
                     ,BERGERUD, A. T.    1974b. The role of the environment in the aggregation,                                       CURATOLO, J. A.     1986. Evaluation of satellite telemetry system for
                              movement and disturbance behaviour of cariobu.      I.U.C.N.                                                     monitorinIgmovements of caribou. Rangifer Special Issue No. 1:
                              Publications, New Series No. 24:552-584.                                                                         73-79.
          co
                      BERGERUD, A. T.    1980. A review of the population dynamics of caribou                                         CURATOLO, J. A. and D. G. ROSENEAU.      1977. The distribution and movements
                              and wild reindeer in North America. 2nd Int. Reindeer/Caribou                                                    of the Porcupine Caribou Herd in northeastern Alaska and the
                              Symp. 556-581.                                                                                                   Yukon Territory 1976. Unpubl. Rept., Renewable Resourc      Ies.
                      BERGERUD, A. T.    1985. Antipredator strategies of caribou: dispersion                                                  Consulting Service Ltd.   59 pp.
                              ,along shorelines. Can. J. Zool. 63:1324-1329.                                                          DAU, J. R. and R. D. CAMERON. 1986.       Effects of a road system on caribou
                      BERGERUD, A. T., H. E. BUTLER, and D. R. MILLER.      1984. Antipredator                                                 distribution during calving. Rangifer Special Issue No. 1:95-101.
                              tactics of calving caribou: dispersion In mountains. Can. J. Zool.                                      FERGUSON9 S. H. 1982. Why are caribou on Pic Island? H.Sc. thesis,
                              62:1566-1575.                                                                                                    University of Victoriam Victoria, B.C. 171 pp.
                      BERGERUD, A. T. and J. P. ELLIOT. 1986. Dynamics of caribou-wolf                                                KUROPAT, P. and J. P. BRYANT. 1980.       Foraging behavior of cow caribou on
                              fluctuations in British Columbia. Can. J. Zool. 64:1515-1529.                                                    the Utukok calving ground in northwestern Alaska. 2nd Int.
                      BERGERUD, A. T., R. D. JAKIMCHUK, and D. R. CARRUTHERS.       1984. The                                                  Reindeer/caribou Symp. Roros, Norway. pp. 64-69.
                              buffalo of the north: caribou (Rangifer tarandus) and human                                             LENT, P. C. 1966. Calving and related social behavior in the barren-

                              developments.  Arctic 370-22.
                                                                                                                                               ground caribou. Zeit. Tierpsychol. 23:702-256

                                                          30

                     LENT, P. C. 1980. Synoptic snowmelt patterns in arctic Alaska in

                             relation to caribou habitat use. 2nd Int. Reindeer/caribou

                             Symp.,Roros, Norway. pp. 71-77.

                     MURPHY, S. M. and J. A. CURATOLO. (in press - 1987). Behavior of

                             caribou during summer in the Prudhoe oilfield, Alaska. Can.

                             J. Zool. (in press).

                     ROBY, D. D. 1978. Behavioral patterns of barren-ground caribou of the

                             Central Arctic Herd adjacent to the trans-Alaska oil pipelines.

                             M.Sc. thesis. University of Alaska, Fairbanks. 200 pp.

                     SKOGLAND, T. 1980. Comparative summer feeding strategies of arctic and

                             alpine Rangifer. J. Anim. Ecol. 49:81-98.

                     SKOGLAND, T. 1986. Density dependent food limitation and maximal

                             production in wild reindeer herds. J. Wildl. Manage. 50:314-319.

                     SKOOG, R. 0. 1968. Ecology of the caribou in Alaska. Ph.D. thesis.

                             University of California, Berkeley. 699 pp.

                     WALTERS, C. J., R. HILBURN, R. PETERMAN, M. JONES, and B. EVERITT. 1979.

                             Porcupine caribou workshop draft report on submodels and scenarios.

                             Unpubl. Rept. Institute of Animal Resource Ecology. University

                             of British Columbia, Vancouver. 42 pp.

                     WHITE, R. G., B. R. THOMSON, T. SKOGLAND, S. J. PERSON, D. F. HOLLERAN     and

                             J. P. LUICK.  1975. Ecology of caribou at Prudhoe Bay, Alaska.

                             Biol. Papers, Univ. of Alaska. Fairbanks. Spec. Rept. No. 2:151-187.

    	Please accept the following comments on the proposed leasing
    of the Arctic National Wildlife Refuge 1002 area.

    	First, the enabling legislation which set aside the Arctic NWR
    state four general goals for management. (ANILCA PL96487, sec. 303
    (2) (_) (_ _ _ _), all of which would be negated if leasing is
    allowed.  To destroy the reasons the refuge was set aside, for the
    sake of oil leasing would not be in the national interest.  Amazingly
    Secretary Horn has recommended leasing ot the NWR, even though his
    own Coastal Plain Resource Assessment admits that Major environmental
    damage will occur the Porcupine caribou herd, major damage to the
    muskoxen, moderate (questionable, probably catastrophic) effects
    on polar and grizzly bears, possible elimination of the wolverine.
    When the draft says that wildlife will be displaced, they fail to
    mention where the wildlife will b edisplaced to.   The Coastal Plain
    1002 area is the last hope for wildlife.  The entire National Petro-
    leum Reserve is open to leasing.

    	The report states there is only a 20% chance of finding oil,
    and to beconomical to produce, oil must be several times highter
    than it is at present.  Here in Texas, most people in the oil
    industry are laid off, indefinetly.  Should we destroy the best
    habitat for caribou in the world, on the hope of finding oil, that
    at present cannot even by used?
    	Mitigation is a joke, especially in the Arctic environment.
    Stipulations requiring prohibiting disturbance, implementing time
    and area colsures, and on site monitoring won't help a bit if the
    species is provoked, such as the muskoxen, into leaving an area
    where it was disturbed.  I have worked in Arctic Alaska, and have
    observed muskox one day, went back the nexd day in a helicopter,
    only to find the herd several miles away.  What will happen when
    hundereds of flights occur?  The muskox will leave, if the roustabouts
    don't shoot them first.

    	How can you mitigate an oil spill?  Since 1972, there have been
    23,000 reported oil spills.  I cannot understand anyone wanting

    to destroy the finest piece of real estate in North America.
    We cannot treat the coastal plain as a seperate entity.  The
    integrity of the entire refuge will forever be destroyed if oil
    leasing is allowed.

    	One thing that the study does not cover in enough detail, in
    my opinion, is how to prevent a boom/bus cycle from occuring among
    the North Slope communities such as Kaktovik.  Most employees will
    be out-of-state, but local communities will still b eeconomically
    enhanced.  But after the oil is gone, what then?  A subsistence
    type of lifestyle will be lost forever.  A few oil companies will
    profit, the State of ALaska will reap some taxes, but the natives
    will lose their way of life.

    It is the contention of several groups, including myself, that the
    managing agency is biased towards development.  Throughout the
    decision making process, Department of Interior and USFWS have
    done everything possible to minimize public involvement.  USFWS
    has spent 300,000 dollars appraising land values in order to develop
    exchange agreemnents, which would remove subsurface mineral rights
    from federal ownership.  If it weren't for Trustees of Alaska, no
    public review period would exist at all.

    	Iam disturbed by one thing that I could not find mention of
    anywhere in the Coastal Plain Resource Assessment.  During 1985,
    the leasing program for the NPRA was cancelled for lack of industry
    interest.  I don't have information on 9186 NPRA leasing programs.
    I think this information should be included in the record--should
    we open up the last coastal area, when the developed fields don't
    draw any interest?  Definetely not.

    	I wish to go on record as supporting ALternative _.  Designating
    sec. 1002 of the Arctic NWR is the only alternative which adequately
    protects and enhances the four basic prnciples for which the refuge
    was created.  Under federal wilderness protection, the coastal plain
    would protect the resources for all, not a few.  And if in the future
    the oil resources are needed, they will still be there.  But if
    we develop these resources now, every other value, such as wildlife,
    wilderness, recreation, and subsistence resources will be irretriev-
    ably lost.

    Thank you,

    Phillip H. Briggs
    Rt. 2 Box 198
    Beckville, TX 75631

    PH.#214-678-3673

    cc.	Senator J. Bennet Johnson	Chairman, Senate Energy and Natural
    	Honorable Steve Cowper, Governor State of Alaska
    	Senator Phil Gramm, TX
    	Senator Lloyd Bentsen, TX
    	Representative Jim Chapman, TX
    	Representative Morris Udall

    DO YOU WANT TO MAKE PUBLIC COMMENTS?

    If you would like to speak at the hearing today, please fill in the blanks
    below and turn it in to one of the Fish and Wildlife Staff members present.
    You need not complete this sheet to submit written comments.  Thank you.

    Please print

    Name Anne Brown
    Mailing Address	8731 S_ _tana Drive
    			Anchorage AK 99516

    Check appropriate box below:

    	I am here to offer my own views.
    			-or-
    	Iam speaking for
    				(please eneter name of organization you represent)

    				DRAFT LEGISLATIVE ENVIRONMENTAL IMPACT STATEMENT

    					ARCTIC NATIONAL WILDLIFE REFUGE, ALASKA

    						COASTAL PLAIN RESOURCE ASSESSMENT

    						TESTIMONY OF _ _ _ _ _ _ _ _ _ _ _ _

    					8731 SULTANA DRIVE, ANCHORAGE ALASKA 99516

    							JANUARY 5, 1987

    Mr. Chairman:

    My name is Anne Brown.  I am a fourteen year Alaska resident and an

    representing myself at today's hearing.

    It was a great surprise to receive the 1002(h) report and find it was a

    single volume, concise and well organized.  I appreciate the careful, and

    judicious effort that obviously went into presenting and assessing more than

    six years of work done in the 1002 area.  As a result, I have been able to

    read the report in its entirety.

    The need for future domestic energy reserves and the economic benefits for

    all Alaskans and most U.S. citizens are the most compelling arguments in

    support of oil and gas leasing in the 1002 area.  However, I could not

    support leasing if I were not confident, given the information in this

    document, and knowledge of the Prudhoe Bay experience, that industry can

    explore for and produce oil and gas with minimal changes to the environment

    that have not, and will not, affect the integrity of wildlife populations.

    I strongly support _ _ _'s proposal to congress for full leasing of the

    Coastal Plain.

    							-1-

                 As a professional biologist, I read with particular interest         the section on                            the impacts from large scale natural resource development projects you have
                                                                                                                                to mitigate the habitat losses accruing from such projects.           It set out to
                 environmental consequences. The backbone of this section Is the application
                 of the habitat based impact assessment techniqu        Ia derived from the USVWS                               examine experimentally habitat evaluation procedures for several species
                                                                                                                                including caribou. With the exception of a few species. like beaver. that
                 Mitigation Policy. This is not surprising since WS has pushed fee years to
                 apply their national pol  .icIy to Alaska. While it my be logical to apply the                                 ar e habitat specialists and have very     I--all home ranges, the conclusion Was
                                                                                                                                that the USFWS habitat evaluation type approach was simply not workable,
                 M Mitigation Policy to many regions In the lower forty-eight, there
                 currently is no evidence which even suggests that habitat is a population                                      especially for large herbivorous animals       that are wide-ranging. or for any
                 limAing factor in the arctic.          In fact. evidence shows that wild        .life                          predatory species.

                 populations In the arctic are regulated primarili by non-human and human.
                 predation, weather. disease, parasites, and emigration. Although a habitat                                     in spite of the inappropriate application of,         the FWS Habitat Evaluation
                 based system lends itself readily to precise quantitative analyses, and                                        Procedures, the authors of this report to congress are to be c          IredIted with
                 facilitates the bookkeeping of mitigat     .Iva and compe nsatory requirements. it                             presenting  .a tr.emendous amount of environmental material In a Systematic
                                                                                                                                manner.     biologic,  Information,      for  the   most    part.    was    evaluated
                 Is meaningless from a biologic perspective in the arctic.              At most, it
                 satisfies political pressures.                                                                                 objectively. The only notable exception Is the information on caribou.

                                                                                                                                The biases Inherent In the caribou sections stem from the obvious disregard
                 I support the Fws mitigation      concepts of avoiding impacts where Possible,
                 minimizing impacts through project design when they cannot be avoided. and                                     for much of the published work on caribou In the arctic. and from the loss
                 rehabilitating disturbed areas where surface impacts are extensive or have a                                   than scientific techniques developed to support the controversial notion of
                                                                                                                                a caribou core calving area.        Added to this. to the misuse of habitat
                 significant adverse effect on wildlife populations.              These principles,
                                                                                                                                evaluation procedures, whereby the authors assume complete displacement from
                 however, can be applied much more effectively outside the bounds of the PWS
                 Mitigation    Policy when population and mechanisms whereby development                                        any habitat with reduced value due to either direct or Indirect affects of
                 activities    might     limit   populations    are   the   basis     for mitigation                            oil and gas operations. This has lead to the Irresponsible and unreasonable,
                 recommendations.                                                                                               prediction of major population declines In both the Por         .cupine Iand Central
                                                                                                                                Arctic caribou herds If the entire 1002 area Is leased for oil and gas
                 it is Interesting to note that FWS sponsored a research project published In                                   development.

                 1982 titled 'An Assessment of a Wildlife       Habitat Evaluation    Methodology for

                 Alaska% The study was based an the assumption that to mitigate effectively

                                                           -2-                                                                                                           -3-

                                                                                                                                 stood out was the environment, the incredibly beautiful surroundings. the
                  Species-by-species     discussions    In    the   draft    report    Indicate     that
                  displacement or blockage is the primary mechanism by which wildlife                                            wildflowers, the caribou and the waterbirds.         I have spent a lot of time on
                  populations could be adversely affected. The technology exists to design an                                    the Worth Slope since then and feel lucky for every opportunity personally
                                                                                                                                 and professionally.       Prudhoe say has provided a tremendou             amount of
                  oilfield that assures free passage of migratory birds and animals. We have                                                                                                           1 3
                                                                                                                                 opportunity and funding for      biological research that otherwise would never
                  the laws, and the commitment on the part of government and industry to
                  insure the integrity of the arctic environment and wildlife populations.             I                         have occurred.       The    leasing of the 1002 area will             bring similar
                  am conv .inced that the   I caribou and other biological Issues raised by                                      opportunities for Individuals in my profession as well as engineers,
                                                                                                                                 drillers. accountants, lawyers, regulators, bankers and the general public;
                  opponents . to full leasing of the ooastal. Plain are red herrings.               what
                  conflicting views really boll down to are disagreements regarding aesthetics.                                  and It Is necessary to meet the economic needs of this State and the energy
                                                                                                                                 needs of our nation.

                  Anc It-5    important to separate aesthetic feelings from biological issues
                  and   conclusions.     Aesthetic    arguments    are    frustrating    because.     by                         Thank you.

                  definition, they are based on very personal feelings.               So many people

                  involved in the    discussion of the aesthetics of the 1002 area have never

                  been to the North Slope.or    to Prudhoe Day or AWdR In particular. They speak
                  from a mental Image that      probably does the beauty and uniqueness of the

                  region justice, but cannot    possibly comprehend Its vastness. Its resilience

                  and the Insignificance of      the presence of the largest ollfield in North

                  Americam on the surface of     the arctic. For most of those people who speak

                  from experience, that experience was possible and memorable because of

                  Prudhoe Say. not diminished because of Prudhoe Say.

                  I will never forget the first time I flow into Prudhoe Day In 1916. The

                  excitement of Its remoteness wW the awesome expanse of-both, the coastal

                  plain spotted by polygonal lakes and the Ice pack extending beyond the

                  horizon are unforgettable. ilost striking however was how small the Industry

                  facilities seemed amidst the expanse of the wilderness. Here was Alaska's

                  economic life's blood and 20% of the nation's energy production and yet what

                                                           -4-

    DO YOU WANT TO MAKE PUBLIC COMMENTS?

    If you would like to speak at the hearing today, please fill in the blanks
    below and turn it in to one of the Fish and Wildlife Staff members present.
    You need not complete this sheet to submit written comments.  Thank you.

    Please print

    Name  Peter D. Brown

    Mailing Address	8731 Sultana Dr.
    			Anchorage, Ak 99516

    Check appropriate box below:

    	I am here to offer my own views.
    			-or-
    	I am speaking for
    				(please enter name of organization you represent

    I support Interior's                     recommendation t fully explore and
    lease ANWR.  Direct experience in the Arctic has repeately shown
    that oil development can occur without major damage to the
    environment while providing major benefits to the United States and
    the State of Alaska.

    I do feel that the 1002 report grossly exagerates the extent of
    environmental costs and that the public has been very ill-served by
    the Fish and Wildlife authors' of existing data
    with respect to caribou impact.

    Implicit in their assessment but never openly stated are a number of
    subtle but critical assumptions which need to be explicitly stated
    and scruntinized.  Examination of these unstated assumptions iwll
    reveal them to be seriously flawed.  Furthermore, these assumptions
    are not supported by the very data  F & W uses, namely the Alaska
    Fish and Game study of Caribou in the Milne point area.

    Specifically, the critically flawed assumptions are:

    1.  	the repeated misapplication of the "Sphere of Influence"
    	concept and

    2.	the idea that significant habitat area will be lost

    3.	the available habitat is the major limiting factor in arctic
    	wildlife populations.

    First of all,
    The F&G study does show that caribou avoid calving within   2 miles
    of an active roadway       that the effect on non calving activity 15
    minimal.  From that F&W erroneously infers that all habitat within
    that "sphere of influence" is lost and that this loss of habitat
    will result in a loss of population.  This is bad science at its
    worst and reduces wildlife study to the intellectual level of
    phrenology.

    The preponderance of evidence suggest that calving
    activity will simply be displaced beyond the 2 mile range, relocated
    bu not disrupted entirely.  Furthermore, the disruption which does
    result from road traffic can be limited by industry at the
    critical times to further reduce the effect to levels that may be
    insignificant even with the 2 mile range.

    Secondly, the Sphere of influence concept as applied by F&W
    automatically assumes that all habitat value within the zone is
    eliminated when in fact the effect on non calving activity has been
    shown to be minimal.

    Finally, a principal theme in F&W remarks and policy is that habitat
    loss is a predominant factor in arctic wildlife population change.
    Although biologically unsound, this emphasis on habitat does allow
    F&W to avoid a politically sensitive but biologically significant

       issue    predation,    especially controllable human        predation by
       subsistan.ce and sport hunters.

       I am appalled by the quality of thought in F&WIs method and
       conclusions. F&W,should focus on the real issue, game populations,
       rather than the red herring of habitat loss and the misapplication
       of the sphere of      influence concept.    -This seriously erodes the
       scientific   integrity    of public discussion of        a complex and
      .emotionally si6roificant issue.      This is particularly unfortunate
       when Fish and Wildlife's conclusions are not supported by data and
       create the appearance of a conflict between wildlife and development
       where none in fact exists.

                                                            Peter     Brown
                                                            1/5/67

                   United States Fish and Wildlife Service                                  1/25/87
                   Attn: Division of Refuge Management Resources
                   2343 Vain Interior Building
                   l8th and C Streets, N.W.
                   Washington, D.C.      20240

                   To Whom It May Concern,

                   I am writing concerning the oil exploration  and leasing proposed on the
                  Arctic National Wildlife  Refuge. I would like my opinion to go on
                   record as opposing opening up this area for oil exploration and leasing.

                   As an Alaskan and a United States citizen, I realize there are some
                   benefits of oil development in this area but I have come to the conclusion
                   that the costs, in terms of the ecology, wildlife, wilderness ard future
    	        subsistenc _ues, are far too high for the oil potential _ _ _ _ _.

                  Impacts on the ANWR have been  underestimated by the draft 1002 report.
                   It Prudhoe Bay type facilites are required to explore and develop
               th_ oil rescourses, th_ web of pads, roads and pipleines _ _ _uld signifi-
               cantly alter the area.  Table V-1 does not include major types of
                 facilities that would be required such as exploratory pads, secondar_
                   roads, pipeline construction roads, base camps, construction  corps,
                   support facilities, minor stream crossings, reserve pits,  pipe _ne
     		maintenace centers, pump stations, airstrips, etc. Also, the impact
                   of rpa is between Prudhoe Bay and AMWR are not discussed in the report.
                    These  roads and pipeline extensions will have impacts both on and
                   off the refuge.

                   Since there were few baseline studies done before Prudhoe Bay was
                   developed the idea that the oil companies have developed the area without
                   impacts cannot be substainated. Serious impacts that have occured
                   at Prudhoe Bay are not addressed in the report, including water quality
                   impacts described by Zemansky (1983).

                   The draft 1002 report should have been written on the highe             reserve
                   potential and not the wean since it is the higher potential that is
                   being used to justify compormising the ecosystem this refuge was intended
                   to protect. In any case, the reserve potential is not high enough
                   to merit destroying this essential habitat for the caribou  herd.

                   As managers of the United States fish and wildlife resources I urge
                   you to support Alternative E in the draft 1002 report, which recommends
                   wilderness designation for the entire Arctic Refuge coastal plain.

                                                        Thank you for your consideration,
                                                        Susanne Carter-Badilla
                                                        Box 182
                                                        Douglas, Alaska 99824
                   Zemansky, G.M. 1983. Water Quality Regulation during Construction
                     of  Trans-Alaska Oil Pipeline System. PhD di_sertation.  University
                     of Washington. 957 pp.

                                                               13 Grafton Street                                              cussed. What we nre looking at is a vital (in every sense of the word) habitat
                                                               on Gallows 14111                                               that the administration, in its arrogance and greed, wishes to turn into part
                                                               Salem. Massachusetts 01970                                     of the oil patch.   You, yourselves. admit that there is no way to avoid adverse
                                                               19 January 1987                                                effects on this part of the environment -- it may only be possible to mitigate
                                                                                                                              these effects. In fact, If development were to occur, not only would there be
                                                                                                                              immediate adverse effects on the caribou and other species that use this area.
                                                                                                                              but eventually the entire area,will become industrialized. to the permanent
                                                                                                                              loss of this wilderness. Further, a statistically probable accident prior to
             U.S. Fish and Wildlife Service                                                                                   full industrialization would also render portions nf the 1002 area
                                                                                                                              on inha bttable. Your solution to such damage appears to be that the offending
             Division of Refuge   Management
             2343 Main Interior   Building                                                                                    party should pay a fine. Looked At another way, while the wilderness dies,
             18th and C Streets    IN                                                                                         little green pieces of paper move from one pocket to another. This is         not a
             Washington, D.Ci  . 20240                                                                                        solution, butIonly the way men in cities. who see everything as coming        down to
                                                                                                                              money, think the situation would be alleviated. The wilderness would        still be
             re: leasing of  the Alaskan 1002 area                                                                            just as damaged, for we are not Godlike in our power to revivify.what       we des-
                                                                                                                              troy. On another, but related tack, you may look upon the changes In        the lives
                                                                                                                              of the indigenous  people as positive. Objectively speaking, this is debatable.
             To Whom It May  Concern:
                                                                                                                              .."..Y, Y-              SLVLJ[g YUUI@el_VeN Lull oversipht management.     Inis
                 1 have just finished reading the executive summary of the draft       Arctic Nfl-                            strikes me as letting the fox guard the henhnuse.
             tional Wildlife.Refuge,. Alaska. Coastal Plain Resource Assessment, And the ac-
                                                                                                                                 On the economic.front, it seems ludicrous to be sinking new wells        In on-
             companying press release; and I must say I am APPALLED.
                 Appalled for several reasons, not the least of which is the blatant poli-                                    spoiled and neccessary (at least. to the animal inhab   'itants) wilderness, when
             tical and rhetorical manipulation exhibited In this project. Though I know                                       existing wells are lying dormant fr   .om the oil glut. Let us   use what we have.
                                                                                                                              The situation must, in my book, reach crisis proportions before we start to
             there is no reason why I should be among the first to      read this report, it is
             unconscionable for yo  ,u to be sending it out so that I   receive it on the 17th                                destroy our nation's heritage to salve it. And I'm talking       about real crisis
             when written comment must be made by the 23rd. You are managing the debate in                                      not like those trumped to influence the uninformed with needless fright.
             a shamelessly underhanded fashion t   Io get what you want. Other examples of this                               Careful, minimal  exploration EI&Lt he in order to prepare for this.
             are quoting a $33 and $40 price for oil, when the current price is less that
             $20 - a price quote that is, forward or back, out of date.         Then you turn
             aroun.d anti use current.drilling rates. This is called lying with statistics.
             Is thiR what we should expect? Perhaps you should risk to have your Services
             renamed in accordance with what they actually (in: The Fish Anti Wildlife ;Isbitat
             Destructinn Service, partnered with the Hureau of Land Exploitation.
                 Shameful As this Is, itis-not the substantive issue that needs to I)e dis-

    _ _nally, let not the arrogrance of Mankind - and the heightened form found

    vernment officialdom - lead us to think that our short tem needs are the

    important thing there is.  That kind of logic is worthy only of a child.

    ise, statesmanlike, forbearing and truly conservative - conserve what

    _ot be he replaced, lest our children suffer without.

    Thanks for your time and attention, but thank you the more for taking this

    heart.

    							Sincerely,

    							C. Alexander Cohen

    cc:  members of the House and Senate

                         A Y-)

                                  IM, 7-
                                                                    lY                            s.
                                                       61
                       X@%W,6w-                                f-
                                                                                                                e^yl
                                                                                                                           -AO
                                                                                m4dh@),                   14;koe V24"w AW 44ag-aw- h24
              AWII;o@mm4W.

                     4V                                                                                              /Oll,  oraq W&e
            /!00*.4- a                                                                                             =j=
                                                    Oil- 0&961111L

                          life-
                                                         124--y"   Z *14        eJ5-;- P
                                                           Aillylw@@ Af?4   ahetAwalr, A
                                      O*Ay
                                                                                          he, a &OA,

                                                                                              4w
                     le

                                                                                                        de 24vw pity F-dal-A

                 less qeu xrr.                                       fe'rw h/e-r/f-
                                               d5k                    A(4@     ff t44 t cc-il- -AOxld

                       ex4v
                  17

                              )Wl,           7/Z:x-                      11o5ol e@h e,-I- AV
                                                          Aud litee%f6               44L
                          rAc- /or Z 1,fvfw2

           XAW
           .t/

            It A- 41,,,- t L

                                                                                 I'll fl 14-1

                                       14331 Osborne Street
                                 Panorama City, California    91402                                       wouldonly supply 4.17% of projected U.S demand by the year 2005 and
                                                                                                          2.57% by the year 2010.
            January 11,  1987
                                                                                                          C. To be economically recoverable, any oil that.may exist would
                                                                                                          require the same artificially high prices of oil $32-$40 per barrel
            U.S. Fish and Wildlife Service                                                                that many shortsighted individuals and agencies have relied on in the
            Division of Refuge Management Resources                                                       past.
            2343 Main Interior Building
            18th and C Streets, N.W.                                                                      d. Not adequately considered in draft 1002 is the probability that
            Washington, D.C. 20240                                                                        alternative sources of every and future technology may substantially
                                                                                                          reduce our dependence on this resource.
                                       Re: Arctic Coastal Plain   Draft 1002 Report
                                                                                                          e. Nowhere is any consideration given to the unsought geological
            Dear Sirs:                                                                                    consequences of continuously removing oil and the.probability of
                                                                                                          magnifying geoglogical shifts in substrata.
            We feel that the Interior Department's    proposal  to allow oil and gas
            leas[ng along the Coastal Plain of the    Arctic National Wildlife Refuge                     Environmental dama .ges associated with this proposed leasing of 1002
                 :L
            is unwise and inconsistent with sound resource management,. In our                            are many and cumulative, e.g.:
            opinion it is vital to long-run interests of theUnited States that
            this area be designated wilderness.                                                           a. To quote 1002 "Accidental spills of crude oil and refined petroleum
                                                                                                          products are an inevitable consequence of oilfield development."
            To allow oil and gas leases in this area     is unsound resource                              suffice it to.say that sinicC 1972, 2LAM spills were reported in
            management because it jeopardizes one of     thdgreatest and diverse                          IAlaska magnifying the possibility of this type of accident.
            wilderness areas left in North America, an area recogniz      .ed worldwide
            as one of the last, biologically intact ecosystems. To adopt any plan                         b. There is no safe economically acceptable way to dispose       of the
            which would permit oiland gas exploration along any portion 'of the,                          toxic discharges (zinc, arsenic, and aluminum) which result from
            Coastal Plain directly subverts the original reasons for the                                  drilling into the earth. one needs only examine the negative impacts
            establishment of the refuge, i.e.:                                                            on water quality at Prudhoe Say where drilling (reducing water quality
                                                                                                          and thus negatively impacting the food chain, just now becoming
            (1)  conserve in@tfieir natural diversity, fish and    wildlife                               apparent), are the detrimental effects on bird and fish populations.
                 populations.
            (2), MeetLinternational treaty obligations regarding fish, wildlife       and.                c. Any developmentLof 1002 will be disastrous to the Porcupine Caribou
                 their habitats.                                                                          herds as such development will interrupt or prevent critical calving
            (3)  PIrotect the quality and quantity of water in the refuge.                                and post-calving periods.    To quote draft Report 1002 "...a. population
            (4)  Provide,for subsistence use by local residents.                                          decline or distribution change for 20-40 percent of the Porcupine
            Any  decision that would allow any leasing fo    .r the purpose of energy                     Caribou Herd." - "Increased noise and disturbance level displacing
                                                                                                          wildlife throughout the.1002 area..." - "Depending upon design,
            development needs to be made in light of the consequences of both now                         pipelines may create a barrier. Those adjacent to or close to active
            and the future. Draft 1002 Report states, and we quote "...long-term                          roadways would probably most impede free movement ... this is of
            losses in fish and wilderness resources, subsistence uses, and                                particular concern in the 1002   Larea because the probable pipeline haul
            wilderness values would be the inevitable consequences of a-long7terM                         road route would bisect the area,".
            commitment to oil and gas development, production, and .                                                                 v: with     e surviyal of the caribou who are
                                                                                                                         ally     Hir
            transportation."                                                                              "o?!d b     tfv                         y
                                                                                                          no e :nmft e anglcr!q          the win'd cool sea coast to av d
                                                                                                          mosquitoes and store energyLduring the calving/post-calving period.
            We have. compiled a list of the facts and the impacts associated with                         Report 1002 states that, under full leasing, 72,000 acres of habitat
            .leasing any portion of the 1.5 million acre Coastal Plain.                                   would be lost to the caribou herds and other species.
            The rationale p  Irovided in draft 1002 Report used to justify the full                       d. Any development of 1002 will also result in habitat loss for
            leasing is based on weak and questionable.data because:                                       wolves, arctic foxes, wolverines, brown bears and polar bears and over
                                                                                                          100. species of birds which either nest, feed, molt and prepare for
            a. The report states that there is only a 19% chance that economically                        fall migration.    it should be noted that over 300,000 snow geese,
            recoverable oil deposits exist beneath the Coastal Plain.                                     approximately 1/2 of the Pacific Flyway population, stage on the
                                                                                                          Coastal Plain in preparation for the long migration south.
            b. If the Department of interior's estimated mean of 3.2       billion
            barrels with a 40% probability of success are considered       valid it                       e. Last, but not least, are the muskoxen and fish species in the
                                                                                                          rivers, streams and coastal waters offshore. Muskoxen, successfully

    reintroduced in the late 1960s after being nearly hunted to
    extinction, depend on the Coastal Plain.  Draft 1002 states "...major
    negative effects upon the muskoxen population from oil and gas
    development could occur, considering the present management objectives
    for continued population growth of the herd under natural regulation
    and the displacement from habitat likely to occur."

    f.  The need for water, to quote draft 1002 "...as much as 15 million
    gallons of water may be needed to drill one exploratory well."
    presents a serious problem as sufficient water supplies are not
    available in 1002.  This means that the proposed development
    jeopardizes fish, wildlife and subsistence users by competing for
    limited water supplies and by reducing the quality of thos limited
    supplies by contaminating them with heavy metals such as zinc, arsenic
    and aluminum.

    g.  The need for large quantities of gravel to build roads and drill
    pads on the permafrost is not available.  To quote draft 1002 "Each
    mile of road occupies about 5 acres and requires approximately 40,000
    cubic yards of gravel."  "Gravel might have to be mined from upland
    sites, river terraces, streambeds, lagoons or other potential sites."
    In the past, mining gravel and transporting it has always resulted in
    habitat destruction and dnegatively impacted streambeds and thus fish
    and wildlife populations.  In all it is estimated that 40 to 50
    million cubic yards of gravel will be required to construct and
    maintain the proposed development.

    Other distrubing facts regarding this proposed development revolve
    around the Department of the Interior and the U.S. Fish and Wildlife
    Service as follows:

    a.  Why has the Department of the Interior only allowed public review
    of draft 1002 as a result of a successful lawsuit by a coalition of
    local and antional conservation groups?

    b.  Why has the Department of the Interior spent public funds to
    appraise lands in order to develop land exchange agreements with
    private native corporation that would remove subsurface mineral
    rights from the public domain in the 1002 area?  Why ere these
    negotiations (kept secret) known within the department as "Project M
    or Megatrade?"

    c.  Why did draft 1002 fail to consider the cumulative effects of oil
    and gas development?  In essence the above actions smack of wrong
    doing, and the subvert the original intent of the congress in establishing
    the Arctic Refuge.

    d.  This nation's lack of a national energy policy which considers
    conservation of resources and development of more efficient
    alternatives sources of energy is disturbing.  Since the memories of
    the disastrous oil embargo have faded we have resorted to old habits
    and methods of depending mainly on oil as a source of energy and have
    never made any serious long-term commitment to other energy forms such
    as solar power.

    							3.

    e.  Why, when there are alread 23.6 million acres of Alaska's North
    Slope included in the National Petroleum Reserve (a figure which
    excludes the vast oilfields of Prudhoe Bay or state and federal Outer
    Continental Shelf oil leases), is the Department of the Interior
    seeking to increase even more the lands committed to oil exploration?

    To destroy the ecological integrity of the Arctic National Wildlife
    Refuge by allowing oil and gas leasing of the vital Coastal Plain when
    only a one-five-chance of economically recoverable oil is possible
    and then only if artificially inflated oil prices of $35 to $40 per
    barrel can be maintained is unwise because:

    	a.  	Present projections show it will not significantly reduce our
    		dependence on foreign oil by more than 4.17% by the year 2010 if
    		prices are at $40 per barrel.
    	b.	It ignores the disposal of hazardous wastes.
    	c.	It fails to consider the cumulative effects.
    	d.	Destroys habitat vital to fish, plant and animal speices.
    	e.	Ignores the need of subsistence users in Alaska and Canda by
    		destroying vital Caribou habitat and thus the Caribou.
    	f.	Worst of all it shows a reliance on conventional energy sources and
    		a lack of commitment to more efficient nonpolluting energy sources,
    		a quest which has all but been totally abandoned by the present
    		administration who seem to rely on short-run solutions while
    		ignoring the future needs of America to develop safe, more
    		efficient nonpolluting energy supplies if we are to maintain a
    		healthy environment in which to survive.
    	g. 	Appears to be consistent with the administration's willingness
    		to sell off public resources in a desperate attempt to provide
    		deficit financing, again a poor short run solution to a government
    		which cannot control expenditures, but whose elected members have
    		developed for themselves a foolproff method of providing automatic
    		raises, i.e., contrary to the spirit of the Gramm-Rudman Act.

    In conclusion we would like to recommend that the Department reverse
    its stand of leasing 1002 in favor of alternative "E" which recommends
    wilderness designation for the entire Arctic Refuge Coastal Plain

    Sincerely,

    John P. Fredricks				Anne _alley

    							4.

    								FEBRUARY 3, 1987

    DIRECTOR
    U.S. FISH AND WILDLIFE SERVICE
    DIVISION OF REFUGES
    2343 MAIN INTERIOR BUILDING
    18TH & C STREETS, N.W.
    WASHINGTON, D.C. 20240

    								RE:  COMMENTS 1002 REPORT

    GENTELEMEN:

    THE FOLLOWING OCMMENTS ARE BEING SUBMITTED ON THE 1002 REPORT
    RECOMMENDATIONS COVERING THE ARCTIC NATIONAL WILDLIFE REFUGE
    (ANWR).  I FULLY AGREE WITH THE RECOMMENDATION TO OPEN THE
    COASTAL PLAIN OF ANWR TO OIL AND GAS EXPLORATION, DEVELOPMENT
    AND PRODUCTION.  I HAVE THE FOLLOWING CONCERS THAT I FEEL
    HAVE NOT BEEN FULLY ADDRESSED IN THE 1002 REPORT.

    1.	EXTREME CONCERN IS EXPRESS ABOUT THE CARRIBOU IN THIS
    	AREA AND WHAT HAS BEEN REFERRED TO AS A "CORE" CALVING
    	AREA.  THE MAPS APPEAR TO HAVE BBEN INTENTIONALLY CUT OFF
    	AT THE CANADIAN BORDER AS THOUGH ALL OF THE CALVING WAS
    	IN THE U.S. AND THERE WAS NO "CORE" CLAVING AREA IN
    	CANADA.  AS A MATTER OF FACT A COMPLETE SET OF CARRIBOU
    	MAPS MAY SHOW A DIFFERENT PATTERN FOR THE SO CALLED EXTENDING
    	CALVING AREAS WITH A VERY LARGE CALVING AREA EXTENDING
    	INTO CANADA IN MANY OF THE YEARS.  THIS SHOULD BE
    	ADDRESSED.  WHNE ONE LOOKS AT THE COMPLETE CALVING
    	AREA.  THE VALIDTY OF THE SO CALLED "CORE" AREA IS
    	OPEN TO QUESTION.

    2.	THE AMOUNT OF PRESENT NORTH SLOPE PRODUCTION THAT IS
    	COMMITTED IN EMERGENCIES BY INTERNATIONAL AGREEMENTS
    	SHOULD BE ADDRESSED.  IT IS UNDERSTOOD THAT THE
    	JIMMY CARTER ADMINISTRATION COMMITTED A PORTION
    	OF NORTH SLOPE PRODUCTION TO OUR ALLIES IN AN EMERGENCY
    	AND THIS AMOUNT OF PRODUCTION WOULD BE LOST TO THE
    	REST OF OUR COUNTRY.  IF THIS IS THE CASE IT IS EVEN
    	MORE CRITICAL AND IMPERATIVE THAT THE COASTAL PLAIN
    	BE DEVELOPED AS SOON AS POSSIBLE IN THE NATIONAL
    	INTEREST.  IF SUCH AN AGREEMENT EXISTS THIS MATTER
    	SHOULD BE ADDRESSED IN DETAIL.

    3.	MANY STUDIES ARE CITED TO ADD VALIDITY TO THE ANALYSES.

    	BUT THERE IS NO EXPLANATION AS TO WHY MOS CONCLUSIONS ARE
    	DRAWN ON A WORST CASE BASIS AND A VERY LARGE PART OF
    	THE DATA FAVORABL TO DEVELOPEMNT HAVE BEEN IGNORED.
    	MANY OF THE STUDIES CITED SHOW CONCLUSIONS MUCH
    	DIFFERENT TO THOSE IN THE REPORT AND NO REASON IS
    	GIVEN AS TO WHY THE RESULTS WERE IGNORED.  IF THE
    	USFWS FEELS THAT THAT DATA ARE NO GOOD.  THE REASONS FOR
    	THAT CONCLUSION SHOULD BE GIVEN AS WELL AS TO WHY THEY
    	FEEL THE STUDIES WHICH IT RELIED ON WERE MORE RELIABLE
    	AND INDICATIVE OF WHAT CAN "REASONABLY BE EXPECTED"
    	AS REQUIRED BY THE STATUTE.

    4.  	AFTER FIFTEEN OR MORE YEARS OF STUDY AND REARCH AND
    	THE EXPENDITURE OF MANY MILLIONS OF DOLLARS BY
    	BOTH PRIVATE AND GOVERNMENT BIOLOGISTS.  THE SIMPLE
    	TRUTH IS THAT NO ONE INCLUDING ALL OF THESE
    	BIOLOGISTS KNOW WHY A CARRIBOU DOES WHAT IT DOES
    	FOR THIS REASON.  WE SEE ALL KINDS OF PROPHESIES, BUT
    	STILL NO ONE CAN PREDICT WHAT THE CARRIBOU WILL DO
    	WITH ANY DEGREE OF ACCURACY.  CERTAINLY THE BIOLOGISTS
    	WONT PUT THAT IN THE REPORT BUT IT NEEDS TO BE SAID!

    SINCERELY,

    O.K. "EASY" GILBRETH, JR.
    206 DAVIS STREET
    ANCHORAGE, ALASKA 99508

    									February 1, 1987

    									1819 Muskox Trail
    									Fairbanks, AK 99709
    									(907) 479-2754

    TO:  	U.S. Fish and Wildlife Service
    	Attn: Division of Refuge Management
    	2343 Main Interior Bldg.
    	18th and C Sts., N.W.
    	Washington, D.C. 20240

    	Attached to this letter of transmission are my comments on the 1002
    Report prepared by personnel of the US_ _WS, and the Executive Summsary which
    was written by the Department of Interior.  I want to be sure that this
    material will become a part of the written record of public comments on the
    1002.

    	Thank you for the opportunity to present these comments, because
    the _ate of the arctic coastal plain of the Arctic National Wildlife Refuge
    is of vital concern to people throughout the United State - and not merely
    those U.S. citizens living in Alaska.

    								Yours very truly,

    								Celia M. Hunter

    February 1, 1987  Comments prepared by Celia M. Hutner

    	I would like to presen the follwing point as my
    comments on the "1002 Report" prepared by the USF&WS.

    1.	I wish to state my preference for either a "do nothing"
    option, or for wilderness for the entire coastal plain.

    2.	I have chosen these options because I feel that the
    1002 reprot does not address the following points:

    		It fails to give a full and complete assessment of
    the nature and the values of the plain's current wilderness
    status.

    		It does nto address cumulative impacts upon the
    coastal plain as off-shore oil development is added to
    on-shore efforts.

    		It does not acknowledge that the Prudhoe Bay oil
    development has ahd serious problems with taccidental spills
    of crude oil and petroleum products:   23,000 spills have
    been reported to DEC ranging from a few gallons to more than
    658,000 gallons.

    		Furthermore, it fails to not that DEC has
    extremely limited jurisdiction over the oil industry in the
    matter of disposal of drilling muds, hazardous waste, and
    cleanup of spills, because of special exemptions accorded
    the oil industry under RCRA.

    		There is a greater liklihood that oil development
    on the arctic coastal plainof the ANWR under Federal
    auspices will result in a build-up of communities for worker's
    fmilies and the facilities to service them.  The State of Alaska
    was able to influence the oil industry to oeprate Prudhoe
    bay as a work camp, with the wives and families of workers
    living in ther established Alaskan communities or in the lower 48.
    This policy has minimized some impacts on the North Slope
    environment, but it is doubtful if the Federal government
    were the landowner, fi this policy would be followed, and
    doubly uncertain if the Native Regional Corp. became owners
    of the land, and were in  charge of oil development.

    		It does not properly address the concerns of the
    Canadian people of Yukon Territory who share a dependency on
    the Porcupine caribou herd with villagers of northeastern
    Alaska.  No treaty exists at present between the U.S. and
    consistently storng habitat protection on both sides of the
    border, as well as foolproof stipulations guaranteeing
    maintenance of the herd at its present strength.
    	The Canadian Government has not been consulted by the
    USF&WS in any meaningful way as set forth by Congress when
    mandating the prepartation of the 1002 report, so that Canadian
    concerns for the wellbeing of the Porcupine caribou herd have not
    been considered.

    	The report fails to acknowlege the actual

    							1

                                                                                                            sufficient water and gravel in the coastal area for the
                number of wells already plotted by the industry on the                                      proliferation of drill rigs, gravel pads, and roads. The
                coastal plain, which would indicate a far more serious                                      negative effect upon all beholders, and particularly those visitors
                impact than originally thought in drawing conclusions from                                  to the Arctic National Wildlife Refuge seeking the power of
                the 1002 report. This oversight appears to be a deliberate                                  solitude, the spiritual re-charge possible from being in a huge
                attempt to minimize the proliferation of roads, pipelines,                                  expanse of natural landscape with no visible sign of the presence of
                drilling pads, and all the other infrastructure associated                                  other humans will be immeasurable.
                with an active oil field, and the extent of the impacts it
                would have an the surrounding landscape.                                                          Furthermore, when the Executive Summary glibly talks of
                                                                                                            'mitigation' they are whistling in the dark. What will
                           The Executive Summary which sets forth the policy                                occur will be a direct loss of 20% to 40% of the vast
                on maximum oil exploration and full leasing of the coastal                                  Porcupine caribou herd (from a herd of 185,000, that would
                plain does not take into account the findings of the                                        mean a loss of 74,000 animals) according to predictions
                biologists of the USFWS and State ADF&S i clogists, in                                      contained in the biological research findings of the 1002
                concert with biologists representing indt     -y, which                                     report.   In addition, biologists predict large losses of all
                advocated absolutely no leasing or develop*@.t ofany kind                                   other wildlife and birdlife within the coastal plain area.
                within the care calving area of the Porcupine caribou herd.                                 These can't be 'mitigated' because to do so would require a
                                                                                                            refugiem area of similar carrying capacity to the arctic
                           The economics of oil development on the coastal,                                 coastal plain, and this does not exist.
                plain at this time is predicated an oil prices of $33 to $40
                per barrel, totally unrealistic price assumptions according                                       In addition, public access to the arctic coastal plain,
                to the experts. These prices probably won't occur until we                                  and to all those other areas of the ANWR which depend upon
                get into the 21st century. Therefore the demonstrations of                                  transit across the coastal plain will be severely curtailed.
                economic feasibility for this speculative pil reservoir need                                The oil company restrictions-on the movement of the public
                to be re-worked using realistic data.                                                       within the Prudhoe Bay complex virtually exclude all
                                                                                                            movements not work-related, even for individuals employed
                           National Security and national oil independence                                  within the site. Even private citizens flying in and out          of
                are often given as reasons for pushing development of this                                  Deadhorse Airstrip are subjected to stringent regulations         of
                field despite the high risk of irreversible environmental                                   their movements anywhere outside of'the terminal buildings.
                effects on wildlife, its habitat, and the wilderness                                              There could not be a more complete lock-up of that 1.5
                character of the area. However, national security is not                                    million acres of the aFLtIC coastal plain, or a more
                served by maximum development of any US oil reserves during                                 comprehensive Iock-out of the public from that area, unless
                this period of low priced oil. We are shutting down                                         the area were to be turned over to the military.
                production in major producing oil fields of the continental                                       Those who currently hunt in ANWR, those who float its
                U.S. in order to help raise prices by creating sr,rcity, as                                 rivers and backpack and hike the plainsi river valleys and
                is OPEC. Wouldn't it be more sensible to declare the entire                                 mountains, will be unable to carry on their traditional
                coastal plain off limits to oil exploration and development                                 pursuits.   This will mean a genuine hardship for a growing
                until much later, when that oil will be a precious reserve,                                 cadre of professional wilderness guiding operators, who have
                rathe,r than adding to an oil glut?                                                         developed their businesses by providing guide service within
                                                                                                            tnenarthern half of the Refuge.
                           At the same time the State of Alaska is pushing
                for opening up the ANWR coastal plain, it is pressuring                                           This relatively small portion of the arctic north slope
                Congress to permit export of both oil and natural gas                                       under the U.S. flag is the only part of that unique
                products from Alaskan soil. The effects of this strategy                                    ecosystem we have been able to preserve. From the Canning
                might bring down the present trade deficit by a minimal                                     River to the west as far as the Chukchi Sea, all of Alaska's
                amount, but it isnwt enough to warrant loss of all the other                                northern coastal plain is open to oil and gas development,
                values of the coastal plain area.                                                           much of it within National Petroleum Reserve-Alaska.
                                                                                                                  Why sacrifice this small area of pristine wilderness on
                     In conclusion, I want to affirm my support for the         continued                   the gamble that the geologic structures (there is no single
                existence of the wilderness nature of the coastal plain         of                          strucLure comparable to that underlying Prudhoe Say,
                the Arctic National Wildlife Refuge.     I believe that the cumulative                      according to the geological section of the 2002 report)
                impacts of oil field development upon    the present wilderness                             might produce a few million barrels of oil? At current and
                existing there has not been addressed    anywhere in the 1002                               anticipated rates of oil use in the U.S., the maximum oil
                report.                                                                                     potential predicted would fill that demand for less than 2/3
                     These impacts will be visualv noisinessg air and water                                 of one year.
                pollution, plus the irreparable damage potential of trying to find

                                                                                                                                            3

                  I would hope that Congress would note the sizable
             discrepancies evident between the incomplete data assembled
             in the USF&WS 1002 report, and the glowing optimism of the
             report's Executive Summary. The potential oil production is
             grossly over-estimated in that Summary, while the potential
             losses of public values is minimized.
                  Congress should demand congruency between the report
             and the Executive Summary as a minimum requirement before
             any serious discussion of this vital issue is attempted.

                  I request that the above material shall be entered into
             the public record of responses to the USF&WS 1002 Report to
             the Congress of the U.S.

                                                  Celia M. Hunter
                                                  1819 Muskox Trail
                                                  Fairbanks, AK 99709
                                                  (907) 479-2754

                                          4

                                                                                                                                                                                         i.s dur, to a) the Central Arctic he:-d (Giifl are moving ouL uj
                                                                                                       2608 kingonberry !..ine                                                           their traditional calving
                                                                                                                                                                                                                                      . grounds onto others.                      The same qtra-
                                                                                                       Fairban%.;, Alaska                     7 0 Y                                      tegy would be great for the Porcupine caribou herd (P(If) except
                                                                                                                                                                                         for the fnct th9t they can not do the same - they car not
                                                                                                                                                                                         because of the cua@.tal plain's difference in topography.
                                                                                                       January 22, 1987                                                                  close proximity of mountains which narrows the coastal plain
                                                                                                                                                                                         area as you move eastward,,reduces their choices for alterna-
                                                                                                                                                                                         tive and very important calving and post-calving insect-relief
                                                                                                                                                                                         areas. b) their (PCH) numbers are also greater than the CAH
                                                                                                                                                                                         and will therefore tend toward having less area per animal to
                                                                                                                                                                                         av?id stressful situations.                           c) that a portion of the CAH co-
                  @Ittn;                                                                                                                                                                         ts now with the PCH in the 1002 coastal plain area durin-
                                                                                                                                                                                         exi
                            ;",!I              o!-        P, I I                                                                                                                         the calving and post-cal@rihg seasons.                                  d) unlike the CAH, th@
                  1  t ,
                            a:,,                                                                                                                                                         PCH travels a much farther distance each year, arriving at
                                                     v,
                                                                                                                                                                                         calving areas much more exhausted and therefore more suscepti-
                                                                                                                                                                                         ble to stresses. e) and finally, (page 28) "The post calving
                                                                                                                                                                                         season is the low point of the annual physiological cycle when
                                                                                                                                                                                         ene@gy reserves of parturient cows are especially low. Access
                  Dear                                                                                                                                                                   to insect-relief habitat and forage resources during this
                                                                                                                                                                                         period may be critical to herd productivity." When one con-
                                                                                                                                                                                         siders that 78@. of the PCH core calving area is within the
                            This letter is to air my opinions and comments on the draft                                                                                                  1002 area than how can we think that there will b6 minimal
                  copy of the Arctic National Wild
                                                                           t1if
                                                                                .:.U1:d1u9e, Alaska, Coastal Plain                                                                       impact?
                  Resource Assessment (1002 Repor                                            by    the U.S. Department
                  of the Interior, in hopes that you will give the 1002 Report and                                                                                                       3) On page 99, "On the 1002 area. obtaining water for drilling
                  my comments both thoughtful consideration. Based on the information                                                                                                    and ancillary needs such as                         ,ice roads and airstrip construc-
                  .gathered by researchers, professionals in their respective fields,                                                                                                    tion could.be a serious problem and the greatest potential for
                  the body of the 1002 Report is informative and substantial in most                                                                                                     effects on the physical environment                              . " This issue is glossed
                  areas.        But in other areas, particularly some very important aspects                                                                                             over in the Executive Summary and is not sufficiently discus-
                    f this r nnrt. Arp lacking,                        wo-fully,you as well as all members                                                                               sed in the body of the report.                             The mining and retrieval of
           .4     of Congress will not just read the Executive Summary and call it good.                                                                                                 these two resources could mean a considerable amount of im-
                  It is very clear that. for some reason. the Executive Summary is quite                                                                                                 pact when realizing the quantitie@@ recerrary for drilling
                  different from the actual'body of the report, which                                            supposedly, the
                  Executive Summary is from.                                                                                                                                             "nd considering the paucity of both immediatel.-y                                              t:_ I
                                                                                                                                                                                         coastal plain area.
                            I oppose opening the 1002 area or any area of the Arctic Na-
                  tional Wildlife Refuge to oil and gas leasing. My reasons are as                                                                                                       4) Because the hazardous waste problem of reserve pit fluid
                  follo     .ws:                                                                                                                                                         discharges has not b?en solved to anyone's satisfaction (ex-
                                                                                                                                                                                         cept of course the oil company's ). Even though preliminary
                                1) Because on page 2 of the 1002 report (Executive Summary).                                                                                             results from U.S. Fish & Wildlife investigations have shown
                            Bill Horn states that "The evidence generated during the 18                                                                                                  an increase in heavy metals and hydrocarbons and a considerable
                            years of exploration and development at Prudhoe Bay indicates                                                                                                decrease in freshwater macro-invertebrate total numbers of
                            .minimal impact on wildlife resources." Ar4f yet on page 29,                                                                                                 species, diversity and abundance, North Slope oil companies
                            U.S. Fish and Wildlife biologists state                                  "Little or no calving                                                               continue to promote this method of waste disposal.                                              How can
                            has been observed in the TAPS - Prudhoe                                 Bay oil field area                                                                   this problem be mitigative in ANd.R when it is already ignored
                            since about 1,973 (U.S. Fish and Wildlife Service, 1982; Whitten                                                                                             as a serious problem in Prudhoe Bay oil. fields?
                            and Cameron, 1985)." This does not mean minimal impact tr. mc.
                            There are more discrepancies to follow.                                                                                                                      5) Misconstrued benefits to the state of Alaska and North
                                                                                                                                                                                         Slope Inupiats are constantly stated in the Executive Summary
                                2) Proponents of oil and gas leasing are using the increas-ed                                                                                            but are not supportable in the report's body of information.
                            population of the Central Arctic caribou herd as a point to                                                                                                       a) local hire for construction and maintenance of the oil
                            support their statements that oil development and caribou are                                                                                                fields is an empty promise considering how hiring and employ-
                            compatible.            Yet they fail to include the fact that the increase                                                                                   ment has been orchestrated in Prudhoe Bay -                                    ,  little state bene-
                                                                                                                                                                                         fit. b) revenues from taxes and lea@es are to be on a dif-

                 ferent scale for Mi"A;J as compared to 1@rudhoe   little bene-
                 fit to the ctate.   c) why do we need more oil fields establiphed
                 when there are oil fieldF in Louisiana that Pre being capped
                 and closed down prematurely? 4hy do            :n--   'i fields.
                 established when leases are being returned by oil companies
                 on the North Slope? d) the agency has failed to justify their
                 recommendation of full leasing in today's flooded lease market,
                 while the world is experiencing an oversupply of oil, and ex-
                 ploratory drilling indicates that prospects for discovering
                 even one major econumically reco,;c.-a@ if:  I field on the coas-
                 tal plain is only t9%. I don't concider it beneficial to
                 lose forever this last stretch of important coastal habitat
                 to oil companies who have based their glossy picture on un-
                 realistic predictions (50% chance of finding 3.2 billion bar-
                 rels of oil at the inflated price of $33 per barrel = overly
                 optimistic amount of revenues to the federal economy) and who have
                 failed to conduct an economic analysis to prove how opening
                 the 1002 coastal plain area to oil and gas leasing tcan pro@
                 vide maximum benefits to the Alaskan and national economies,
                 and contribute to national strategic interests over the long
                 ,term.

                 6) Despite our international agreements for protection of
                 the Porcupine caribou herd, the Department of the Interior has
                 proceeded with secretive land trade proposals. and plans to
                 substantially decrease an international resource used by sub-
                 sistence users of both the U.S. and Canada -the Porcupine
                 caribou.herd, and other migrating birds, mammals and fish -
                 while failing to notify or even include the Canadian people
                 in this period of public.testimony and comment.

                 7) 1 find the practice of secretive land          by our Govern@
                 ment underhanded. Proposed land trades with certain Alaska
                 native corporations and the State of Alaska are practically
                 sealed into agreement by the time the public - who own the
                 resources being traded away - are made aware of such dealings.
                 B)Considering that not all in-place resources are recoverable.
                 that statistically there is'a much greater chance of not being
                 able to recover enough oil to make oil development in7'-ANWR
                 economically feasible, that inflationary oil prices were used
                 to generate cost benefit estimates, and that "Alaskan crude
                 oil in excess of West Coast demand is transported to the Panama
                 Canal for shipment to other markets." (page 165), 1 don't
                 agree with the Interior Department's recommendation to open
                 the Arctic "..'ational Wildlife Refuge to full oil and gas leaFing.

                 So. in conclusion, I don't feel that the-findings of the draft
           '1002 report' support the Interior Department's recommendation.
           I hope you will consider all aspects of this issue and make a well-
           informed decision when the time comes. Thank you for your time.

                                              Sincerely
                                           /
                                                ur
                                              ,@@@ac    obs

              P. 0. Box 317
              iakutat, AK 99689                                                                               TAPS has created a false sense of security.for
              February  1, 1987                                                                         Alaskans. Once again, the bust cycle is upon Lis and we
                                                                                                        are left holding the bag. Alaska has been like a spoiled
              William P. Horn                                                                           child the last 11 years, on a rampage of construction and
              Division of Refuge Management                                                             spending as if there were no,tomorrow. With development
              U.S. Fish and Wildlife Service                                                            on the coastal plain, we would have yet another
              2343 Main Interior Bldg.                                                                  schizophrenic cycle to loot, forward to.
              16th and C Sts, N.W.
              Washington, D.C. 20240                                                                          Likewise, the United States appears intent upon
                                                                                                        viewing energy consumption as if there were no tomorrow.
                                                                                                        The issue with the coastal plain is not whether or not we
              bear Mr. Horn and Committeet
                                                                                                        should develop it, but rather, is that development going
                   I am opposed to.the recommendation by    the Dept. of                                to provide anything for ourlong-term future as a nation?
              Interior.for full oil and gas leasing for the 1002 area
              of Arctic National Wildlife refuge.    I recommend the 1002                                     1 would urge you, Mr. Horn, and the Division of
              area be given federal wilderness designation.                                             Refuge Management, as well as Interior Secretary Hodel
                                                                                                        and President Reagan, to reexamine our energy policies.
                   The 1002 report fails to address some important                                      By developing the 1002 area we are looking at a short-
              issues concerning oil production an the North Slope.                                      term solution to a global problem -- the depletion of a
              Oil developers like to point to the engineering success                                   finite energy source.    By.concentrating our efforts on
              of the trans-Alaska pipeline (TAPS) as proof,of our                                       extracting all our-oil reserves, we will ultimately find
              ability to extract oil on the Arctic coastal plain                                        ourselves in a-precaripus situation regarding national
              without environmental and/or other negative effects.      I                               security and foreign dependence on oil. We should
              would, however, like to point out some of the negative                                    concentrate our efforts on demeloping environmentally
              effects which may have been overlooked.                                                   safe alternative sources of energy and on improv3    .Lng the
                                                                                                       ..efficiency of our present.oil-dependent technology.
                   Historians tend to characterize Alaska as a place of                                 Finally, our government should set an example by
              boom and bust. Certain developments, such as TAPS.i have                                  practicing conservation of our natural resources.
              helped to create and proliferate this type of cycle in
              Alaska. TAPS and ANILCA changed Alaska profoundly. The                                          Intensive petroleum--related development on the
              construction and production phases brought unprecedented                                  Arctic Coastal Plain is not compatible with the habitat
              amounts of money and human resources to the state.     And                                requirements of the Porcupine Caribou herd, nor is it
              while, monetarily, many Alaskans have reaped the benefits                                 compatible with traditional Native habitat requirements.
              of that wealth, TAPS has also left behind scars. The                                      A pipeline traversing the coastal plain will severely
              once tight-knit Alaska Native family has been severed, as                                 interrupt the migration patterns of the herd and will
              male family members marched off to work on the pipeline,                                  interrupt critical calving activity.     The very nature of
              leaving behind their traditional culture and value                                        caribou migration activity precludes the establishment of
              systems. Most of the highly technical jobs were awarded                                   exact calving areas.    Therefore, it would be difficult to
              to out-of-state petroleum workers, so few Natives.learned                                 construct manmade facilities which would not adversely
              skills that were useful in the long run. Quick money                                      affect animal populations.    The displacement of caribou
              brought drugs, and an increase in alcoholism and                                          by roads and pipelines has already been documented by
              prostitution to Alaska, both which remain serious                                         activities of the Central Caribou herd near TAPS.
              problems today. Disposal of toxic wastes is yet an                                        Breeding bird populations, fish and other wildlife
              unsolved problem at Prudhoe Bay.     The current suggestion                               populations will also be severely impacted. A pipeline.
              by ARCO to inject toxic wastes into deep Wells in the                                     and road network across the coastal plain will alter a
              arctic is unacceptable to my way of thinking.                                             pristine wilderness forever.    Certainlys one would not
              Accidental oil spills.continue to plague oil development                                  gouge a scratch across a Rembrandt painting, then say
              and production on TAPS.   In the last 14 years, there have                                it*s ekay because it didn't spoil the entire painting.
              been 23,000 reported spills, the largest at 658,000                                       The point is, this type of development will spoil the
              gallons.  How many more spills have gone unreported?                                      entire wilderness.    A fragile ecosystem, once disturbed,
              Regardless of the existence of more spills, the reported                                  takes several lifetimes to recover.     There is more to be
              number shows a poor industry track record for production                                  gained by establishing wilderness than by developing the
              an fragile arctic tundra.                                                                 coastal plain.

            Canadian government in protecting the Porcupine Caribou
            herd.

                 ANWR was established in 1960 to protect its unique
            wilderness. While many would argue that we need the oil,
            I would argue that we need wilderness. I know, for I
            have felt what the Arctic does for me and I have seen the
            transformation in those people who have accompanied me
            into the Arctic. The experience of seeing tens of
            thousands of caribou, bounding across a peneplain free of
            human intervention is one which will remain in my memory
            forever.

                 In a world which becomes increasingly complex,
            technological, noisy and polluted, we need wilderness for
            our psychological and emotional benefit, as well as for
            the protection of unique fish and wildlife habitats. I
            recommend full protection and wilderness designation for
            the Arctic Coastal Plain and urge you to to do the same.

                 Thank you very much for the opportunity to comment
            on the draft ANWR Coastal Plain Resource Assessment.

            Sin rely yours,

            Karen    ttmar
             n 4re,     our!
                     y Y

             .r  en  ttmar

    Bill Horn										Jan. 31, 1987
    Asst. Sect. for Fish and
    Wildlife and Parks
    Div. of Refuge Mangement
    U.S. Fish and Wildlife Service
    2343 Main Interior Bldg.
    Washington, D.C.  20240

    Dear Sir,

    	I would like to express my opposition to the Department of
    Interior's recommendations for oil and gas exploration and
    development and outline some of my concerns over deficiencies in
    your draft environmental impact statement.
    	The coastal plain of the Arctic Refuge has outstanding
    natural resorces that are of preeminent national significance.
    The 1002 area ought to be designated a wilderness as in
    alternative E to establish an international preserve folling
    the Canadian initiative.  It should provid a safe haven for
    important wildlife species such as caribou, muskox, polar bear,
    and snow geese and provide a spectrum of pristine Arctic
    ecosystems contained in the area.
    	The draft EIS does not present a sufficient national need
    for the oil resource to justify the detrimental consequences that
    development would entail.  The Department of Interior shoudl
    present alternative national actions that could achieve
    compensating reductions and therefore negate the need to impair
    this important national treasure.  The Epa should not be relaxing
    fuel efficiency standards for automobiles while the DOI uses a
    national security rationale to promote development.  Conservation
    should be the first priority - it has had remarkable success at
    reducing our national dpendence on foreign supplies and
    contribured to the present oil glut on the international markets.

    The Department of Interior must explain why it has abandoned
    conservation as a priority and instead promotes profligate
    development.
    	The EIS is also deficient in a number of aspects concerning
    the impacts to the land.  The EIS seriously underestimates the
    amount of infrastructure that would likely be reequired fo full
    development and therefore understates the amount of gravel
    required.  The Kuparuk Oilfield alone has 39 drilling pads and
    another 10 are on the drawing boards.  Then there are the flare
    pits, equipment storage pads, construction camps, and contractor
    facilities.  There is alos a large gravel requirement for the
    solid core causeways for ports that the EIS did not include.  Then
    there is the possibility of future development such as offshore
    oilfields requiring gravel islands and causeways at millions of
    cubic yards per shot.  This is not an unreasonable scenario - its
    happening at Prduhoe Bay and must be taken into consideration.  In
    addition to the increased gravel requirements form the facilities
    overlooked, there is the potential problem resulting from the
    projected climatic warming trend that would alter the thermal

    										1

    balance of the gravel pads and require increased insulation.  This
    would require thicker gravel cover if foam insulation is not
    required.
    	The EIS has avoided the delicate issue of where the gravel
    might come from as the sources are likely to be concentrated is
    areas with important habitat values.  For example, consider the
    first development area around Marsh Creek.  In this area,
    development would require a large dock with tremendous gravel
    requirements, then roads, drill pads, processing facilities,
    and possible offshore development requiring tens of millions of
    cubic yards of gravel.  The gravel could come from the Sadlerochit
    River, which is of primary importance to muskox and is the most
    productive drainage on the coastal plain, or maybe the
    Kaktakturuk, which is also important habitat, or maybe the upland
    outcroppings of Tertiary gravels.  The gravel requirement is huge
    and the supply is limited requiring concentracted devestation in
    important areas.  Even mining in the lagoons would create
    temperature and salinity problems detrimental to fish
    popultions.  The consequences of the gravel demand appear much
    more drastic when the sources must be idetnified beyond bland
    generalizations that perhaps 500-750 acres might be affected.
    	Air pollution must be identified as a problem.  It has
    received very little attention at Prudhoe Bay, only because it is
    in a remote area.  Prudhoe bay oeprators are permitted by the
    Alaska Dept. of Environmental Conservation to discharge 90,000
    tons of NOx per year.  Other souces of pollutants, including
    heavy metals and other toxic elements are the Borrough
    incinerators.  The distribution, fate, and impacts of this air
    pollution need to be studied.  Further development in ANWR would
    contribute to pollution of the Arctic basin, an international
    problem for which we must also be responsible.  the arctic
    pollution may be of significance to solar energy absoroption at
    the poles and consequently to global climate.  Such enormous
    emissions are incompatible with a wildlife refuge.
    	The EIS needs more effort in identifying the occurrence and
    fate of liquid and solid wastes generated during oilfield
    development.  There are many toxic compounds used in drilling and
    processing and these need to be accounted for.  One of the largest
    concerns is the reserve pit fluids.  Experience in NPRA has shown
    that with time the reserve pits are breached, usually from
    melting and subsidence underneath the containing berms, and their
    contents leached or _roded onto the adjacent trundra.  The main
    toxic elements are salts but may also include some heavy metals.
    Allowing toxic wastes in the rufuge is incompatible with wildlife
    protection.
    	Finally, the DOI must take steps to identify areas with
    critically high ice contents.  During the seismic exploration
    program, drillers encountered massive ice beds, up to 60 to 80
    feet thick with only a few feet of pretective soil matnel, in
    some locations.  These are extremely sensitive areas to
    disturbance and must be identified and avoided.  Once thermal
    erosion starts in such massive ice beds, stability would be very
    difficult to achieve and in the worst case whole hillsides
    might erode before equilibrium is achieved.  This is all the more

    									2

            critical given a projected climatic warming trend.
                 These concerns, along with the important wildlife
            consequences described by others, should be given further
            consideration by the Department ot Interior.

                                           Sincerelv,

                                           2332 Cordes Way
                                           Fairbanks, Alaska 9970?

                                                                                                                              from experience gained with Prudhoe Bay and related oil field development and
                                                                                                                              the Central Arctic Caribou Hord Is of limited applicability to the 1002 area
                                                                                                                              because of the lower density and resident nature of that herd In contrast to the
                                                                                                                              Porcupine Herd. Nevertheless, Central Arctic Herd caribou have largely
                                                                                                                              discontinued calving in the Prudhoe Bay oil field since Its development, and
                                                                             January 31D, ISBI                                access to coastal Insect relief habitat Is greatly hindered by pipelines, roads
                                                                                                                              and other off field facilities. Of pertinent Interest here Is experience from
                                                                                                                              the very large Taimyr Peninsula Caribou Herd In the Soviet Union that, when
                                                                                                                              confronted by a large diameter gas pipeline In the 1960's that had been built
               U.S. Fish and Wildlife Service                                                                                 across It's migratory path, did considerable damage to range vegetation over a
               Attn: Division of Refuge Management Resources                                                                  large area adjacent to the pipeline through trampling and overgrazing, while
               2343 Mein Interior Building                                                                                    being delayed In crossing the pipeline.
               Ilith and C Streets, N.W.
               Washington, D.C. 20240                                                                                         An ethical question Is raised with regard to the threat posed to the Porcupine
                                                                                                                              Caribou Herd through petroleum development when this herd Is an Important
               Greetings:                                                                                                     subsistence base for Athabascan Indlans In Arctic Village and several other
                                                                                                                              villages In Alaska and to a lesser extent for the Inuplat people of Kaktoylk.
               I wish to comment on the proposed options regarding oil and gas exploration                                    The value of the subsistence lifestyle to these people cannot readily be
               and development on the coastal plain of the Arctic National Wildlife Refuge                                    converted to monetary values for comparison to the short term dollar value of
               (ANWR). My comments are made as a private cItIzen, however, I have worked                                      postulated petroleum reserves.     Similarly, because the Porcupine Herd Is an
               professionally as a wildlife blologist In Alaska for the Alaska Department of                                  International resource that provides a subsistence base for the Athabaskan
               Fish and Game, the U.S. Fish and Wild] Ife Service and the University of Alaska                                people of Old Crow In the Yukon Territory, as well as other native villages In
               for a total of 34 years. Major focus of my professional work has been                                          the Northwest Territories on the lower MacKenzie River, the United States has a
               research on ungulate species, primarily caribou, muskoxen, doer and moose; and                                 responsibility to maintain the productivity of this herd that transcends our own
                                                                                                                              national borders. The United States has played a leadership role In encouraging
               Investigation of the effects of northern development on fish and wildlife and
               their habitats. This has Included work In northern Canada, Greenland,                                          other nations to respect the International nature of fish and wildlife
               Scandinavia and the Soviet Union.                                                                              populations that migrate across International borders, and to assure that         the
                                                                                                                              actions of one country do not jeopardize the resources upon which other
               The primary purpose of National Wildlife Refuges Is the protection and                                         countries may be dependent. This principle applies equally to migratory
               management of fish and wildlife habitats to assure the continued well-being of                                 waterfowl, salmon migrating up the Yukon River through Alaska Into Canada         and to
               fish and wildlife populations and their sustained productivity. Additionally.                                  caribou of the Porcupine Herd.
               the unique wilderness values of the Arctic National Wildlife Refuge were a
               major consideration In the original establishment of Its precursor, the                                        Experience with the Forty-mile and Western Arctic Herds In Alaska, as well as
               Arctic National Wildlife Range.     Secondary, and very Important purposes of                                  with other herds In Alaska and other cIrcumpolar areas, Indicates that when herd
               the ANWR are to provide for the subsistence and recreational use of Its        fish                            size declines range use patterns change. with a reduction In total area used and
               and wildlife resources. Uses of the ANWR for other purposes, such as oil                                       discontinued use of some migration routes. Thus, a substantial reduction In the
               exploration and development. are clearly of lower priority than the primary                                    size of the Porcupine Herd resulting from the Impacts of petroleum development
               fish and wildlife-related goals and uses.      It Is Important that this ranking                               on the coastal plain would be expected to bring about corresponding changes In
               of prloritles of ANWR be held In perspective when considering proposed oil                                     range use patterns. The consequences of such changes would very likely be
               and gas leasing.                                                                                               reduced availability of the caribou to subsistence hunters in both Alaska and
                                                                                                                              Canada even though herd size might be adequate to sustain traditional
               Of major concern  are the likely effects of oil    and gas leasing and subsequent                              subsistence harvest levels.
               possible development or the fish and wildlife     populations and their habitats
               In the 1002 area. The effects are dealt with       In the draft 1002 report (Arctic                            Predicting the consequences of development activities on caribou Is much more
               National Wildlife Refuge, Alaska, Coastal Plein Resource Assessment, November                                  difficult than for other ungulates, such as deer and moose. largely because of
               1986).   It Is obvious that oil and/or gas development and production will                                     their migratory nature that extends their ecological relationships over several
               detrimentally Impact directly on fish and wildlife resource values of the area                                 ecosystems. Additionally, their well developed sociality, vulnerability to
               even with the constraints of strict environmental regulations.                                                 Insects and dependence on winter forage that must be excavated from beneath the
                                                                                                                              snow cover are also unique to this species. Inspite of the generally well
               Carlbcu, because of the Importance of the calving grounds and       use of, and acccss                         designed studies carried out on caribou In the 1002 area during the five years
               to, Insect relief habitat, would be particularly vulnerable to detrimental                                     of biological baseline Investigations, several aspects of the biology and
               effects of petroleum development. The very high density of caribou of the                                      ecology of caribou are not 5ufflclently understood to enable an in-depth
               Porcupine Herd In the area and the Important role that calving and Insec'! relief                              assessment of the possible Impacts of petroleum development. The calving
               habitat play In facilitating recruitment to the population and In allowing for                                 grounds, although delineated, have not been adequately Investigated In
               optimization of growth and body condition of the caribou make It very unlikely                                 relationship io their use by caribou to provide answers to questions of their
               that mitigation of the effects of oil development is possible. EyArapoleilon                                   specific characteristics thai have made them so attractive to cow caribou over

            the centuries of their use. Quantitative data Is also lacking on the energetic
            and nutritional costs of Insect avoidance, as well as to how access to Insect                                I have I Im.1ted my comments to potential conflicts between petroleum
            relief habitat may Influence levels of parasitism In caribcu. The complex                                    development In the 1002 area and caribou and muskoxen because of my close
            Interrelationships between caribou, weather, harassing Insects. vegetation type                              familiarity with these two species In the area. There are obviously many
            and terrain, although known to exist, cannot, with our present     level of                                  other fish and wildlife species there that may be adversely affected by
            knowledge, be Integrated Into a reliable predictive Interactive model.                                       development activities-and these conflicts I am sure will be addressed by
                                                                                                                         others who have knowledge of them.
            It Is particularly frustrating to both the engineers who design      development
            projects and the ecologists who attempt to minimize or mitigate     the effects     of                       In conclusion, It seems obvious that the risks of damage to fish and wildlife
            these projects on wildl Ife, that the complexity of I IvIng systems Is                                       habitats and of losses of fish and wildlife resource values that would be
            magnitudes greater than the seemingly complex development projects that may                                  associated with petroleum exploration and development In the 1002 area are too
            affect them.                                                                                                 great to justify opening the area to leasing at this time. With Increased
                                                                                                                         knowledge of the ecology of fish and wildlife In the area In the future, with
            It Is quite  evident that there Is Insufficient knowledge of the ecological                                  reduced Impacts of now technologies for petroleum extraction In the Arctic that
            relationships of caribou In the 1002 area at the present time to enable an                                   will undoubtedly be developed over time and with the greatly Increased value of
            adequate assessment of the consequences of the likely development scenarios.                                 petroleum products that will occur In the future, It Is most prudent to delay
            Biologists familiar with caribou have only been able to make "educated guesses"                              leasing In the 1002 area until some time In the future when It can be fully
            about the consequences of the proposed petroleum developments on caribou.           In                       justified.
            view of this, the only responsible recommendation with respect to leasing for
            oil and gas exploration and development In the 1002 area Is to exclude those                                                                                              Sincerely,
            areas of known Importance to caribou for calving, post-calvIng and Insect                                                                                              I
            avoidance use. At some future time, It the necessary research has been done,
            the knowledge may be available to plan for development In these critical habitat                                                                                             a
            areas In such a way as to avoid or greatly minimize the Impacts upon caribou.                                                                                             David R. Klein
                                                                                                                                                                                      2039 Weston Drive
            Another ungulate species resident in the 1002 area that would be affected by oil                                                                                          Fairbanks, Alaska
            and gas development Is the muskox. The muskox was reestablished In the coastal                                                                                            99709
            plain of the ANWR through Introductions made In the late 1960's. The muskox was
            extirpated from northern Alaska In the late Igth century and old skulls have                                 cc:  Senator Bennett J. Johnson,
            been found on the tundra In the 1002 area from these previous populations,                                          Senate Energy and Natural Resources Committee
            testifying to their earlier presence there. Their reestablishment in historical                                   Henry Cole, Science Advisor to the Governor of Alaska
            habitat In the ANWR through the joint efforts of the U.S. Fish and Wildlife
            Service and the Alaska Department of Fish and Game Is an outstanding success
            story In the history of wildlife conservation.

            Research we have completed on the patterns of habitat se    Iection and use of
            these newly established and expanding muskox populations Indicate that the
            riparian habitats along many of the major stream drainages of the coastal
            plain are preferred by the muskoxen during much of the year. The vegetated
            gravel bars and stream banks of these habitats have high plant diversity and
            productivity as a consequence of their annual flooding, which thaws and heats
            the soils and adds nutrients to them annually. The quality of plants In
            riparian habitats as forage Is understandably high and the quantity Is also
            hIGh In contrast to the adjacent tundra.

            The potential conflict between muskoxen and oil and gas development In the
            1002 area focuses on the Importance of stream or riparian areas to the
            muskoxen as a foraging habitat, while at the same time being of Importance to
            the oil Industry as sources of gravel and for transportation corridors.
            Because muskoxen are resident In the riparian areas or Immediately adjacent to
            them for much of the year It may not be possible to plan disturbing human
            activities that might take place In these areas, such as gravel extraction or
            exploratory drilling, so as to occur when the muskoxen are not present.
            Additionally, gravel extraction In those stream drainages with high production
            of forage used by muskoxen will result In loss of high quality riparian
            habitat.

                                                                                                            pertinent impact-related research conducted at Prudhoe Bay and on the
                                                                                                            Arctic Refuge that is not even cited in the 1002 report. A partial list
                                                              Institute of Arctic Biology                   of relevant references ignored by the 1002 report is attached. The
                                                              University of Alaska                          review of aquatic/fisheries studies was particularly disappoining,
                                                              Fairbanks, Ak 99747                           considering the effort and funds expended at Prudhoe Bay in this area.
                                                                                                            Impacts are not even considered for such important species of concern as
                                                                                                            arctic cisco.   Many of the studies listed were conducted on ANWR, some
              U.S. Fish and Wildlife Service                                                                by USFWS, and all are undoubtedly familiar to the field staff of USFWS
              Attnz Division of Refuge Management                                                           in Alaska. It is difficult to understand why the report's authors
              2343 Main Interior Building                                                                   proceeded with such disregard for pertinent information and apparently
              18 and C Streets NW                                                                           without the benefit of the expertise among USFWS staff most familiar
              Washington, D.C. 20240                                                                        with the area and issues.
                                                                                                                 The attached list of references represents only the tip of the
              To whom it may concernt                                                                       iceberg -- there are undoubtedly many other studies with which I am not
                                                                                                            familiar, and there are studies currently in progress (related to the
                   I would like to take this opportunity to comment on the draft                            development of the Lisburne and Endicott fields at Prudhoe Say) for
              Coastal Plain Resource Assessment Report to Congress (1002 report)                            which I have no references.    There are also numerous proprietary studies
              concerning oil and gas leasing in the Arctic National Wildlife Refuge                         conducted by industryp which are not generally available to the public.
              (ANWR).  I have spent at least part of four summers in the Arctic                             Industry might reasonably be expected to share the results of these
              Refuge, including two summers of research on bird populations at the                          studies if they would provide Congress with additional insights'into
              Canning River delta and my report to USFWS is cited in the 1002 report.                       ecological processes and environmental problems associated with arctic
              In addition, I have spent two summers involved in research at Prudhoe                         oil development.
              Bay concerning development impacts on the terrestrial environment.
              Thus, I have some familiarity with the area and the issues as well as        a                    Many of the studies that are cited in the report are inadequately
              citizen's concern for the future of our public lands.                                         summarized in the literature review.      I have neither the time nor
                                                                                                            expertise to review this in detail but can provide examples of omissions
                  The report's recommendation to allow full leasing o      .f the 1002 area                 which I suspect are rampant.     For example, Troy (1984) is cited briefly
              i:pclearly not supported by the evidence presented in the body of the                         on p. 132, but none of the analysis ofthe effects of drainage
              r ort.   The petroleum potential of the area is stated to be highly                           alterations and impoundments conducted by the Water-flood Monitoring
              uncertain.  In reference to the EI)esmerian rock sequence, the report                         Project is mentioned.    On the same.page,.riurphy rt a!.           are cited
              states (p. 54) "The presence or absence of these rocks in that area                           in reference to Glaucous Gull populations, but the main focus of their
              greatly affects the petroleum potential because very large structures                         study (impact-related studies on waterfowl) is never.mentioned.
              occur in that &real these rocks include the main oil-producing
              reservoirs  in the Prudhoe Bay area.     If most of the Ellesmerian rocks                         The report is Inadequate in its review of what we have learned from
              are missing in most of the 1002 area, the assessment number would be                          the Prudhoe Say experience.     It is equally important for a report of
              reduced considerably.   Drilling one or two wells in critical areas would                     this nature to realistically assess what we clon@t know about the impacts
              resolve this question.'    Here is a clear statement that the data are                        of oil development on the Alaskan arctic.      The report utterly fails to
              inadequate to provide a prediction of petroleum potential of any                              give any indication of the data gaps and the many uncertainties
              precision.                                                                                    remaining in predicting impacts. Instead, the Secretary would have us.
                                                                                                            believe that we are fully capable of predicting and mitigating the
                  One of the most glaring deficiencies of the 1002 report is         its                    entire array of potential environmental problems.       Furthermore, the
              failure to review available data on ecological impacts of arctic oil                          report fails to review the efficacy of the various mitigation procedures
              development.  With the possible exception of caribou research,                                that have been tested at Prudhoe Bay.      Finally, no effort was made to
              apparently only a token effort was made to review the numerous impact                         realistically assess the enforcement problems and compliance with
              studies conducted in Alaska over the last decade.      In spite of this                       existing regulations at Prudhoe Bay.      In summary, the report obscures
              omission, the Secretary's Recommendation claims that 'most adverse                            the difficulties inherent in predicting environmental impacts, devising
              environmental effects would be minimized or eliminated through                                appropriate mitigation procedures, and the practical difficulties of
              mitigation based on the vast amount of information and technology                             insuring compliance with environmental regulations.        Without a realistic
              acquired during the development of the Prudhoe Say area               This                    assessment of these issues the discussion in Chapter       VI cannot be
              claim is completely unsubstantiated by data presented in the report       and                 considered seriously as a guide to decision-making.        The cursory
              can only be interpreted as wishful thinking on the part of an                                 attention given to existing relevant information and       expertise on
              administration favorably disposed toward development regardless of                            development impacts is mystifying.     Against these deficiencies, the
              available information on impacts.     In fact, there is a large body of                       Secretary@s claims that "most adverse effects would be minimized or

    eliminated through mitigation..." and that "unnecessary adverse
    effects would not be allowed to occur" ar einexcusably misleading.

    	In summary, the wildlife impacts of full leasing are to a great
    extent unpredicatable.  In contrast, the impascts to the wilderness
    summarized on p.131, "The wilderness value of the coastal plain of the
    Arctic Refuge would be destoryed...".  The issure of wilderness value
    is consistently underplayed in the report as a whole, and virtually
    ignored in the Secretary's Recommendation.  This is particularly
    inappropriate given the stated purpose of the establishment of the
    refuge to presever "unique wildlife, wilderness and recreational
    values".
    	Given the certain destruction f wilderness values and the
    unpredictable effects on wildlife populations, the uncertainties in the
    geologic data are a serious hindrance in making a national decision on
    ANWR.  The results contained in the report might justify limited and
    carefully controlled further exploration as a national alternative
    (Alternative C) that woudl provide the Congress with the facts needed to
    make an informed decision on ANWR.  There is certainly no justification
    for leasing contained or implied in the data presented.  Had a
    wilderness review been conducted for the 1002 area, ample support for
    Alternative E (wilderness designation) would have been found.  I believe
    this is the most appropriate designation for the 1002 area, given its
    unique and irreplaceable wilderness values.  It is conceivable that in
    the face of overwhelming national need, high and relatively certain oil
    potential, and thorough and conscientious commitment to preserving
    biological resources, a deciion for development would be jutified.
    None of these conditions are demonstrated by teh 1002 report.  The
    report is flawed in it sprepartation and its unsubstantiated conclusions
    betray a bias for development contrary to the intent of Congress in
    requesting the study.

    							Sincerely,

    							Philip Martin

    				Terrestrial Studies, Birds

    Conners, P.G., C. S. Connors and K.G. Smith.  1982.  Shorebird
    littoral zone ecology of the Alaskan Beaufort Coast.  In:
    Environmental Assessment of the Alaskan Continental SHelf, Final
    Reprots of Principal Investigators, National Ocenaic and Atmos-
    pehric Administration/Outer Continental Shelf Environmental
    Assessment Program, Juneau, Alaska.

    Hansen, H.A. and L.E. Eberhardt.  1981.  Ecological
    investigations of Alaskan resource developemnt.  In:  Pacific
    Northwest Laboratory annual report for 1980 to the C.O.E.
    Assistant Secretary for the Environment, Part 2. Ecological
    Sciences.

    Troy, D.M. and S.R. Johnson.  1982.  Bird monitoring program.
    Annual Report of the Prudhoe Bay Monitoring Program, U.S. Army
    Corps of Engineers, Alaska District, Anchorage, Alaska.  62 pp.

    Truett, J.C., R. Howard, and S.R. Johnson.  1982.  The Kuparuk
    Oilfield Ecosystem - - A literature summary and synthesis and an
    analysis of impact research.  L.G.L. Ecological Research
    Associates, Inc.  Prepared for:  ARCO Alaska, Inc.,  Anchorage,
    Alaska.  168 pp.

    Woodward-Clyde Consultants.  1982.  Oliktok Point and Vicinity:
    1981 Environmental Studies.  Prepared for:  ARCO Alaska, Inc.,
    Anchorage, Alaska.

    Woodward-Clyde Consultants.  1982b.  Kuparuk Waterflood Project
    - Final Report, Chapter 6 - Avifauna.  Prepared for:  ARCO
    Alaska, Inc., Anchorage, Alaska.

    Woodward-Clyde Consultants.  1983.  Lisburne Development Area:
    1983 Environmental Studies.  Prepared for: ARCO Alaska, Inc.,
    Anchorage, Alaska.

    					Terrestrial Studies - - Vegetation

    Ebersole, J.J. and P. J. Webber.  1983.  Biological decomposition
    and plant succession following dusturbance on the Arctic Coastal
    Plain, Alaska.  Proceedings of the Fourth International
    Conference on Permafrost, University of Alaska, Fairbanks,
    Alaska; 18-22 July 1983.  Washington, D.C.:  National Academy
    Press.  pp. 266-271.

    Howe, K.  1982.  Observations of impoundments and culvert
    performance along the West Dock to Pad E Road, Prudhoe Bay,
    Alaska.  Draft interim report to Alaska Department of Transpor-
    tation and Public Facilities.  44pp.

    Klinger, L.F., D.A. Walker, M.D. Walker and P.J. Webber.   1983.
    The effects of a gravel road on adjacent tundra vegetation.

    Prudhoe Bay Waterflood Project Environmental Monitoring Program.
    Prepared for the Alaska District, Corps of Engineers, Anchorage,
    Alaska, 99510.

    Webber, P.J. and J.D. Ives.  1978. Recommendations concerning
    the damage and recovery of tundra vegetation.  Environmental
    Conservation 3(5):171-182.

    				Aquatic Studies -- Fisheries

    Biosonics, Inc. 1984.  Prudhoe Bay Waterflood Project Fish
    	Monitoring Program.  1983.  Prepared for Department of
    	the Army Alaska District, Corps of Engineer, Anchorage,
    	161 p.

    Bryan, J.E.  1973.  The influence of pipeline development on
    	freshwater fisheries resoruces of northern Yukon
    	Territory:  aspects of research conducted in 1971 and
    	1972.  Environ.-Soc.  Comm., North.  Pipelines, Task Force
    	North. Oil Dev.,  Rep 73-6.  Ottawa. 63 p.

    Chihuly, M., D. Ward, P. Craig, R. McMillan and R. Morrison.
    	1979b.  Spring fisheries survey and provisional lsit of
    	waterbodies along the Alaskan gas pipelines route (Prudhoe
    	Bay to the Yukon Territory) proposed by Northwest
    	Pipeline Company.  Rep. by LGL ecol. Res. Assoc., Inc.
    	for Northwest Alaskan Pipeline Company. 210 p.

    Chihuly, M., D. Ward, P. Craig, R. McMillan and R. Morrison.
    	1980.  Spring fisheries survey and provisional list of
    	waterbodies along the Alaskan gas pipleine route (Prudhoe
    	Bay to the Yukon Territory) proposed by Northwest Alaskan
    	Pipeline Co.  Rep. by LGL Ecol. Res. Assoc. for Northwest
    	Alaskan Pipeline Co. 211 p.

    Craig, P.C.  1976.   PReliminary fisheries survey along the
    	coastal alternative corridor (Arctic National Wildlife
    	Range).  Unpub. Rep. by Aquat. Environ. Ltd. for Alaskan
    	Arctic Gas Study CO., Anchorage, Alaska, with revised
    	figures (30 Dec. 76). 5 p.

    Craig, P.C. 1977a.  Ecological studies of anadromous and
    	resident populations of Arctic char in the Canning River
    	drainage and adjacent coastal waters of the Beaufort Sea,
    	Alaska.  Arctic Gas Biol. Rep. Ser. 41(1).  116 p.

    Craig, P.C. 1977b.  arctic char in Salerochit Springs,
    	Arctic National wildlife Range.  Arctic Gas Biol. Rep.
    	Ser. 41(2).  29 p.

    Craig, P.C. 1977c.  Fisheries research in the Shaviovik
    	Drainage, Alaska, emphasis on Arctic char in the
    	Kavik River.  Arctic Gas Biol. Rep Ser. 41(3). 28.p.

    Craig, P.C. 1978. Movements of stream-resident anadromous
    	Arctic char (salvelinus alpinus) in a perennial spring on
    	the Canning River, Alaska.  J. Fish. Res. Board Can.
    	35:48-52.

    Craig, P.C. 1984.  Fish resources.  Chapt. 6.  P. 240-266.
    	In:  J. Truett (ed.), Proceedings of a synthesis meeting:
    	the Barow Arch environment and possible consequences of
    	planned offshore oil and gas development.  MMS/Noaa,
    	Outer Contineltal Shelf Environ. Assess. Prog.,
    	Anchorage, AK.

                                                                                                                                                                                                  Aquatic ~e~n~            Aq~~l~.

                                                                                                                                                                                                    McCort~2p" Craig and                                     p~pv~J~~                         Craig, ~p1~~~1pC~~g                                                                                                       ~~~t~0~~~e~4 ~~~                     ~t~9~d 1~      Rep. by ~1~ ~1po~                                                                                  ~~~to ~~eline                            Co.,
                                                    ~   ~~f~~                                                                                                                 ~~ ~ ~                          ~             It-& ~~f~ ~ fish                                                                                                     Moles, ~, It~n~              ~     ~~
                                               a ~O~~~p3~a ~~                                                                                                   ~~a~~"~~is~~~                                                                                                                                                                                             ~                                                   ~.
                                                                                                                                                                                                           crude ~zene' Trans. Aver. ~                                                                                                                                                                                            ~po~     ~1~~t grovel removal                                It'
                                                 ~1p. ~~~ ~story ~                                                                                            blot&,     ~2p2~~Gravel ~~pu~
                                       ~~~~ Olsen ~~ A~~~                                                                                                                                                           on ~~                                                                                                                                                                                                          ~                                                                                                                                                                                                         ~y ~a~y~                             ~8"~                        1~~k~                                                                                          report,                                       ~pf~~Z~I
                                                                                                                                                                                                                                                                 pep.  ~                             ~~ ~c Gas ~. Up. ~p(~7                                                                                                                      arctic  ~ic ~~~~ ~~~                                                                                                                                                                                           and ~~v- Anchorage, ~~                    C~ ~pd ~                 ~l ~~n~                                       areas of ~ulations &I** routes or                                                                                                 ~~       ~~p,~ ~~h survey.
                                       ~~ pipeline between Prudhoe Bay, ~~h~                     ~~ Delta ~7~-Arctic Cgs ~~                                             ~                                                                                                                                       ~~~ ~~~C~p&~                          ~    I~1pP~~ Classification ~r~                                                                                                 Anchorage~p2~                              ~ ~m~ ~e$ between Prudhoe say,                                                                                                                    ~0.~1p.~L~h                                               ~                       ~~p'~a~l~~tic ~;"                                                                                                           ~~l~A~t~po~       ~ ~ ~-
                                       Research ~~
                                                                                                                                                                                                           ~~p, ~~~  ~.                  t~~r
                                                                                                                                                                                                                                ~~ar~c~               ~, ~~                  ~                                                                                                                 Moulton~pr~pl~.                  ~     ~~I~l~                                                                    ~~ ~"

                                                                                                                                                                                                                                                             ~i~~                                                                                                         t
                                                  ~pg mites ~pN~~                                                                                                                                                                   ~~~                                       ~t Loy     , A~~pj~ ~,~                                                                                                 ~l~1, ~~1p.          ~~pt9~                             ~r ~L~6~) ~K~ ~ ~~                                  ~~-~4~                                                                                                                                                                                                  1984 Central ~~h study, ~pl~          ~pl~t. ~_ ~                                                                                                                                                monitoring ~~po~     ~E~p.~,
                                       Project ~~~s~r       ~V~pl~                                                                                              ~s. ~_ and ~~l~ants I-
                                                         ~~~J ~pa~t~2pp~                                                                                  ~s~pC~ Anchorage~4 ~                         District, C~Engine~ept. ~ Alaska
                                       chap. ~1pP,                      r~2ph~, At. Val,                                                                                                                       ~~d ~~ ~ort $*a
                                                                                                                                                                                                                      ~#~~~                                                                                                                                                                                                                ~1pS~2pb~d~~
                          ~ ~         ~   Prudhoe a                                                                                                                                      ~~                            ~pI~     ~~                             marine Litt return system ~~pa~o~                                                                                                                                                                Ora&*, ~p.
                                                                            ~~g~o~r~                                                                                          ~ta~dhoe ~pit~b
                                       Rep~1pK~U~Anchorage~                                                                                                                                                                                         Neill~pF~~alloway, ~j~d ~pe~                    Daum, ~. Post, ~it~pk~~~~                                                                                                    ~deling ~~#~s~t~~tic
                                       North ~ Of ~t~al Wildlife Refuge, ~                                                                                                           ~ ~~A ~~~ temperature~                     ~F~v~ Sam~1pp~, ~                                                                                                         ~~1pi~~o~a near the ~r~                                 ~1~6~*~   ~                                                                                                                            Causeway, ~o~~1p1~@ of the
                            ~3t~1pP~*~esults Or 3t~~~                                                                                                  Of Alaska ~~                                 ~t~.$ ~1pT~pl~ ~~S~po~                     fish a" ~~b~2p. by A~1pE~~p.                                                                                                    Poulin, V.A.        ~     ?Art   ~pt~I~1pE~~~                             tar ~~p,~~ Co., Anchorage~                                                                                                    ~~ ~~o~n support
                                                                                                                                                                                                           activities related t~1pP~*~~~p%
                                                                                                                                                                                                           ~~pX~~~ I Of ~                                                                                                                                                                                                             ~          ~   ~~2p, and ~o~h, IA., ~~                                                                                                   by F~a~. Ltd. for ~i~a~~                     ~-~
                                       ~~~            ~a~n~U               ~
                                                                     a ~pC~p$~f~g~

    Aquatic Studies, cont.

    S_ith, M. and R. Glesna.  1982.  Aquatic studies on the North
    	Slope of the Arctic National Wildlife Refuge, 1981 and
    	1982.  U.S. Fish and Wildl. Serv., Fairbanks, Ak. Fish,
    	Resour. Prog. Rep. _ _ 83-1.  71 p.

    Tarbox, K. and L. Moulton.  1980.  Larval fish abundance in
    	the Beaufort Sea near Prudhoe Bay, Alaska.  Rep. by
    	Woodward-Clyde Consultants for Prudhoe Bay Unit
    	Waterflood Project, Anchorage, Alaska.  47 p.

    Tarbox, K. and _ Spight.  1979.  Beaufort Sea fishery
    	investigations.  In:  Biological effects of i_pingement
    	and entrainment fro_ operation of the proposed intake,
    	summer 1978.  Rep. by Woodward-Clyde Consultants for

    Tarbox, K. and R. Thorne.   1979.  Measurements of fish
    	densities under the ice in the Beaufort Sea near Prudhoe
    	Bay, Alaska, Rep. by Woodward-Clyde for ARCO Oil and Gas
    	Company, Anchorage, Alaska.  111 p.

    USACE (U.S. Army Corpos of Engineers).  1980.  Final
    	environmental impact statement.  Prudhoe Bay oil field,
    	Waterflood Project, Vol. 1-3.  U.S. Army Corps of
    	engineers, Anchorage, AK.

    WCC (Woodward-Clyde Consultants).  1982_  Oliktok Point and
    	Vicinity:  1981 environmental studies.  Prepared for ARCO
    	Alaska, Inc., Anchorage, Alaska.

    WCC (Woodward-Clyde COnsultants).  1983.  Lisburne development
    	area:  1983 environmental studies--final report.  Rep. by
    	Woodward-Clyde Consultants for ABCO-Alaska Inc.,
    	Anchorage, Alaska. 722 p.

    										FEB 6, 1987

    TO THE U.S. FISH/WILDLIFE

    DEAR SIRS

    	ENCLSOED PLEASE FIND MY COMMENT SON
    THE DRAFT REPORT, "ARCTIC NATIONAL WILDLIFE
    REFUGE, ALASKA, COASTAL PLAIN RESOURCE
    ASSESSMENT.
    	I WOULD LIKE TO STRONGLY SUPPORT
    ALTERNATIVE B IN THE REPORT.  I BELEIVE
    DEVELOPMENT OF ANWR'S POTENTIAL OIL & GAS
    RESOURCES IS IN THE BEST INTERES OF
    THE U.S. AND ALASKA.  I BELIEVE THE
    ENVIRONMENTAL EFFECTS HAVE BEEN
    GROSSLY OVERSTATED & A MROE BALANCED
    VIEWPOINT IS REQUIRED.
    	AS A SENIOR ENVIRONMENTAL COORDINATOR
    WITH ARCO ALASKA INC.  I BELIEVE I HAVE
    A KNOWLEDGEABLE POSITION FROM WHICH TO
    OFFER SUGGESTIONS & CHANGES TO THE DRAFT
    REPROT.  THESE COMMENTS ARE MY OWN &
    ARCO HAS SUBMITTED IT S OWN COMMENTS
    SEPARATELY.

    		MARK MCDERMOTT

    			GENERAL COMMENTS ON ENVIRONMENTAL EFFECTS

    					CHAPTER VI
    					1002_ Report

    Comment #1 - The "core calving area" is assumed to be critical to Porcupine Caribou
    	Herd (PCH) herd demographics and therefore any displacement from this area
    	would necessarily impact productivity.

    The "core calving area" for the PCH has been arbitrarily defined as an area where high
    density (50 caribou/km2) calving has occured for at least 5 of the last 14 years.  For
    much of this area high density clving has occurred in 9 of the 14 years which still
    leads to the obvious conclusion that calving occurred outside the "core calving area"
    anywhere from 5 to 9 years.  An important aspect of the "core calving area" is what
    percentage of all calving areas it represents.  From Tabel VI-5, the total "core calving
    area" is 311,000 acres, while total concentrated calving occurs over 2, 117,000 acres.
    Thus core calving represents 15% of all concentrated calving areas, and would
    represent an even lower percentage if peripheral calving areas were considered.  the
    conclusion is the PCH has successfully calved over a very larg eare in the past
    and while the core area is obviously important to the the herd.  It is not necessarily
    critical.

    The assumption is made that areas outside the "core calving area" have reduced
    habitat valves or higher exposure to predators.  FI this were so then reduced
    productivity shoudl be apparent from years that the herd used these alternate areas.
    This has never been demonstrated and it is known is that the herd has grown steadily
    since the early 70's.

    In considering the effects of displacement from traditional calving grounds, examples
    can be drawn from the literature.  Davis et al., (1983) reprot that "in 1982, the Delta
    Caribou Herd was apparently precluded from calving in its traditional core areas
    because fo persistent snow cover and instead used an alternate calving area roughly
    within the area burned in 1979, even thou snow conditions were as favorable in
    unburned areas northeast, northwest, and west of the 1979 burn, where some calving
    occurs in most years.  Calving in 1982 was quite successful, which suggest that
    caribou may have considerable flexibility in their habitat requirements."  The Central
    Arctic Herd and Talmyr Herd in Russia also provide examples where Industrial activity
    has had no measureable effect on herd productivity.  Milelr and Gunn (1986) review
    other case histories of natural displacement in Alaskan cribou herds.

    Skoog (1968) and Bergerud et al. (1984) believe that caribou are not habitat limited.
    Shank (1979) states that.

    	"Stating that animals have no adequate habitat into which they can dispers is
    	tantamount to say that the population is being density controlled.  In fact,
    	northern large mammals (excepting sheep) are most likely nto often resource
    	limited suggesting that at least some degree of distributional alteration could be
    	accommodated without drastic demographic consequences."

    Comment #2 - Behavioral responses are consistently equated with demographic
    	responses.  That is, if a negative response is observed in an individual or group,
    	then the species productivity has also been negatively impacted.

    								-1-

                                                                                                                                                     These definitions also lead to the questionable practice of combining population
                      Shank (1979) discusses this confusion directly. He defines a behavioral disturbance "as                                        declines and redl3trlbutilons. The effects on many species are summarized as "a
                      any behavioral response to human-caused stimulus which results In actually or                                                  moderate change In population or d1stributloti". These two extremes need to be
                      potentially reduced reproductive fitness. If human action results In an animal acting                                          d13tingulshed, not lumped together.
                      In a manner in which It would not otherwise have acted and It d113 alteration 13 thought
                      to cause a reduction In that Individual's capacity to produce a viable offsprings then                                         Another drawback to the current definitions is that'there is no quantification of
                      behavioral disturbance has occurred.        The Issue Is confused by the occasional                                            the population effects. In the cases where populations are high (arctic ground
                      unavoidable use of the term 'disturbance' to describe the human-Caused stimulus                                                squirrels) or habitat is not limiting (rikuskoxen), & mmoderate" change in habitat
                      Itself-"                                                                                                                       could yield no population effect yet the overall effect on the species 13
                                                                                                                                                     concluded to be "moderate". As an example, one ground squirrel colony could be
                      "Another aspect of behavioral disturbance Is that the response must cause the                                                  covered by a gravel pads yielding a local chan@e, one that Is long term, and one
                      reduction In fitness rather than the stimulus Itself."                                                                         that results In a redistribution of squirrels. By definition this would be a
                                                                                                                                                     "moderate" Impact on ground squirrels in the 1002 area. Clearly something is
                      "Behavioral disturbance becomes manifested In animals In three distinct analyzable                                             wrong with a definition that leads one to a "moderate" Impact on a common
                      modest overt behavioral response, physiological response, and demographic responses."                                          species such as squirrels by ellminatIng one colony..
                      There 13 a consistently blurred distinction In the report regarding what Is a behavioral                                3.     Many of.the above cited problems with the blo;logical effects could be remedied
                      response and what is a demographic response. The discussion of effects on caribou and                                          by separating habitat effects from population effects and having a category for
                      muskox are excellent examples of this confusion. In both cases observed behavioral                                             each. Thus under biological resources there would be 4 levels of effects for
                      responses (flight reactions or 'Misplacement") are used to estimate areas of affected                                          Population In one subsection, and 4 levels of effects on habitat In a separate
                      habitat. Although habitat 13 not a IImItIng factor for either species these avoidance                                          subsection.    This would greatly Increase the flexibility and accuracy of
                      behaviors are then equated to demographic responses. As Shank (19A statest                                                     describing effects on the wide variety of species considered in the report.
                           "What is commonly forgotten or Ignored ... Is that disruption of normal behavior Is                                Comment 04 - Declines In all major predators are assumed to              occur due to the
                           is not necessarily bad In Itself.. for behavioral disturbance to be of practical                                          hypothesized decline In caribou population.
                           concern, It must be demonstrated that it does, or does not, u,--VC- -J-
                                                                                                      .... a.
         01                consequences. Failure to provide this link Is, without. question, the major failing                                The discussions of wolves, brown bears, wolverines and golden eagles all predict a
                           of current research."                                                                                              "moderate" Impacts largely due to a hypothesized 20 - 40% decline In the PCH. This
                                                                                                                                              reasoning Is flawed for several reason=
                      Comment #3 - The definition of environmental effects on biological resources Is
                           Inadequate.                                                                                                               I .  No alternative prey species are considered.
                      Several problems exist with the definitions of environmental effects on biological                                             2.   The 6 - 8 weeks of PCH availability to predators on the coastal plain would
                      resources In Table VI-1.                                                                                                            have to be a critical period for all species where the predator relied almost
                                                                                                                                                          entirely on caribou.
                      1. . There Is a fundamental difference between the definitions for "negligible" and
                           "minor" and those for "moderate" and "major". For negligible and minor the                                                3.   No consideration Is given to the fact that the high numbers of the PCH
                           effect measured Is a change In population or distribution or habitat quality or                                                relative to the low numbers of predators Indicates that the predator - prey
                           habitat availability. For moderate and major the deflnitia@`calls for changesS                                                 system Is not In a stage of dynamic equilibrium where a small change in
                           habitat availability or quality              ead to a change In abundance or                                                   one population leads Immediately to a change In the other.
                           distribution. Habitat Is linked to           ce, which Is not the case for many of
                           the species discussed In the report. The 4 levels of effects should occupy a                                       As an example of the problems with the assumption that PCH numbers are now
                           smooth continuum, not alter In the middle,                                                                         limiting. the 4 predators discussed, wolves will be examined because wolf-caribou
                                                                                                                                              systems have been Studied more extensively. The logic behind the argument applies to
                      2.   As mentioned previously, the definitions      for moderate and major effects tie                                   the other predators as well.
                           together habitat and population effects.      The Implicit assumption Is that any
                           alteration of habitat will result In a population effect. While this may be true                                   Population estimates for the PCH ranged from 100 - 1069000 for most of the 7013,
                           for sorm species, It varies widely for those considered by the repo". As an                                        which represents a decline slightly greater than the maximum 40% predicted by the
                           example, polar bears are thought to be maintaining a stable population and the                                     1002 report. Yet wolf numbers In the 1002 area are not estimated to have been
                           removal of a few donning sites could adversely effect the population. Muskoxen                                     significantly lower than the report`3 estimate of 3 - 10 wolves, and In fact may have
                           are Increasing their populatlon at very high rates, such that major changes would                                  been higher. "Wolf predation an caribou In the ANWR study area during calving and
                           have to be made In their habitat to produce a populatlan effect. These two cases                                   post-calving is probably low." (U5FW 1982) It Is fairly safe to assume that wolf
                           cannot be distinguished given the current definitions.                                                             populations on.the 1002 area have been held artificially low through rable3 and legal
                                                                                                                                              and Illegal hunting and that PCH population size is not a dominant factor.

                                                                 -2-

                       Keith (1991) shows a direct relation between wolf population density and ungulate                                                                SPECIFIC COMMENTS ON ENVIRONMENTAL EFFECTS
                       population biomass. However, the theory behind this relation cannot be applied to the                                                                                    CHAPTER VI
                       1002 area becauset                                                                                                                                                       1002(h) Report
                             1.     Wolf densities are quite low relative to the available biomass of the PCH,
                                    such that Keith's relation does not hold. This suggests other factors                                               Pg. 93, Pam 11. "in Alternative A, three portions of the 1002 area         ..... are all predicted
                                    control wolf populations In the 1002 area.                                                                                as being developed, and the assessment considers all three areas as developed
                                                                                                                                                              concurrently... Therefore, the analysts and consequences may represent a higher
                             2.     The PCH are only seasonally available to resident wolves, and then at a                                                   level of development than may actually occur at any specific time if the area
                                    time when wolves are tied to dennIng sites to the south of the 1002 area.                                                 were opened to leasin&"
                             3.     The availability of the PCH occurs In summer, not during the more critical                                                We would agree that the analysis represents a worst case scenario and therefore
                                    winter period, when resources are more scarce and wolves have fewer prey                                                  most subsequent environmental effects outlined in Chapter VI are overstated
                                    alternatives.                                                                                                             from what Is likely to occur.
                       For the reasons discussed above It 13 not reasonable to assume th3t declines of 20 -40%                                         Fg. 98, section an Effect on Physical Geography and Processes.
                       of the PCH population will have any effect on wolf numbers. Negligible to minor                                                        There are no mitigation sections In the subheadings:
                       Impact on other predator species would also be expected from the hypothetical worse
                       case of a 20 - 40% decline.                                                                                                            '@ConseqUences of Geological and Geophysical Exploration"
                                                                                                                                                              @ConsequenCeS of Exploratory Drilling"
                       Comment #5 - The standard for judging environmental effects is not discussed. Based                                                    '@Consequences of Development Drilling"
                             on numerous examples documented In the specific comments section, the                                                            "Consequences Resulting from Construction of Roads, Pipelines, and Marine and
                             standard used In the 1002 report 13 "worst case". NEPA as now amended                                                            Production Facilities"
        _0                   currently requires that effects be nreasonably foreseeable.                                                                      Mitigation sections are found in the remaining two main subheadings in                . this
                       It appears that the standard frequently used In the report for judging environmental                                                   chapter: "Effects on Biological Environment" and "Effects on Socieconomic
                       effects In the face of Incomplete or unavailable Information IS Worst case analysis. In                                                Environment", thus it would seem appropriate to include mitigation sections In
                       rnany of these instances the use of worst case analysis Is Inappropriate, particularly                                                 the "Effects on Physical Geography and Processes." This is particularly true In
                       without further justification and clear evaluation of other reasonable approaches and                                                  light of the very large body of knowledge that has been developed over the past
                       more probable outcomes.                                                                                                                two decades on this subject. There are literally hundreds of proven mitigative
                                                                                                                                                              techniques commonly applied on North Slope olifields by virtue of the fact that
                       In a recent rulemakIng      (51 CFR 13613 et 3eq. April 26, 1986)t CEQ amended Its                                                     arctic environmental engineering 13 In a mature stage of development.
                       regulations (40 CFR 41302) governing the preparation of environmental Impact
                       statements where Information 13 Incomplete or unavailable. In that rulemaklng CEQ                                                      One small example Is contained In the comments regarding Pg 1009 paragraph 4.
                       greatly restricted the use of worst case analysis to those situations where such
                       analysis Is supported by credible scientific evidence, is not based on pure conjecture,                                         Fg. 99v para. 3, "Effects of seismic exploration generally result from overland travel
                       and is within the rule of reason. Moreover, where worst case analysis 13 used, all                                                     of seismic trains. The effect 13 to the tundra whichg If broken or scarredo can
                       relevant credible scientific evidence must be evaluated using alternative theoretical                                                  cause thawing of the upper Ice-rich permafrost during the succeeding summers.
                       approaches or methods generally accepted In the scientific community. (40 CFR                                                          Such thawing In flat areas will cause ponding at the junction of the Ice-wedge
                       1502.22(bXl)-(3).     The report often Ignored this reasoned approach to evaluating                                                    Polygons, altering the appearance of the tundra landscape. However, If thawing
                       Impacts.                                                                                                                               occurs on sloping groundo erosion can occur. If that erosion and Its products
                       While the NEPA regulations are not specifically made applicable *to this legislatively                                                 terminate at a stream, local sitting may result."
                       mandate EISO we believe that the approach set forth In CEQ regulations should be                                                       Although In the previous paragraph it Is stated that "effects of additional seismic
                       followed.                                                                                                                              exploration would be similar to the effects of the seismic surveys during the
                                                                                                                                                              winters of 1983-84 and 1984-85", It Is not stated what those effects were.
                                                                                                                                                              Paragraph three then lists all the potential III effects without the balance of
                                                                                                                                                              stating what actually occurred during the previous two winters. A summary of
                                                                                                                                                              the actual results, taken from Felix and Jorgenson, 1985 and Felix and others,
                                                                                                                                                              1986a and b, should be Included In this section.

                                                                     -4-                                                                                                                            -5-

                           Pg. 99, last para. "...traces of oils                used during drilling to Islicken! up the drill biti..." Is                                                                      Recent experience from ARCOPs Brontosaurus well site (NPRA) and other recent
                                    not In keeping with current drilling technology utilized on the North Slope.                                                                                                exploration wells on the North Slope (Larry Dietrick, AK Department of
                                    Fresh water based mud systems are currently used to drill wells on the North                                                                                                Environmental Conservation (ADEC) personal communication) do not support this
                                    Slope.                                                                                                                                                                      statement. The Brontosaurus well was drilled approximately 50 miles S-SW of
                                                                                                                                                                                                                Barrow during early 1985 from an Ice pad. The reserve pit was excavated below
                           Pg. 100, para I & 2. "Preliminary results of those Investigations show gradients of                                                                                                  the level of permafrost and the tundra mat was scraped off and stockpiled
                                    Increase In pH, salinity, alkalinity, turbidity, and sediment loads from control                                                                                            separately from the mineral soil. After operations concluded the reserve pit
                                    ponds to ponds adjacent to reserve pits (R.L. West and E. Snyder-Conn,                                                                                                      contents were melted, pumped dry and Injected down the well. The mineral soil
                                    unpublished data). Trends of Increase In the vicinity of reserve pits were also                                                                                             was replaced and then covered with the organic rich tundra mat. This resulted In
                                    shown for heavy metals such as aluminum, barium, chromium, zinc and arsenic,                                                                                                a crown over the reserve pit of 2-3 feet above ground level. An August 1986
                                    as well as for certain hydrocarbons...."                                                                                                                                    Inspection by ARCOO ADEC and the North Slope Borough measured successful
                                                                                                                                                                                                                freezeback of the pit contents with virtually no slumping or ponding problems.
                                    We believe it is Inappropriate for the USFW to cite an unpublished draft report:                                                                                            Natural revegetatlon was already occurring 18 months after closeout. This
                                    that was the subject of widespread criticism based on Its lack of technical merits                                                                                          technique Is considered to be "state-of-the-art" by ADEC. Similar experiences
                                                          Presumedly one of the reasons this report has never been finalized                                                                                    from other recent wells would Indicate that a) this method Is a very effective
                                    nearly two years after Its draft release Is that the deficiencies were recognized                                                                                           mitigation technique, b) remobilizing equipment is not necessary, c) opening
                                    by USFW Management.                                                                                 the West and
                                                                                                                                                                                                                other gravel borrow pits Is not necessary, and d) the material will revegetate
                                    Snyder-Conn reports basic conclusions, cited In the draft IUU2H report, that                                                                                                naturally and rapidly.
                                    were derived from the misapplication Of Statistical analyses. Based on the
                                    ANOVA analysis performed in West and Snyder-Conn's draft report, they could                                                                                         Pg. 100, para 6. "1. Denuding of a 10-acre area of tundra for                                   10 years or more, and
                                    not have concluded that Ronds adlacent to                                              Its were sIgnificanly                                                                the long term (many tens of years) creation of a 2 to 3 acre rectangular
                                    different that control ponds because they did n= Ute statistics to answer                                                                                                   appearing pond."
                                    that questIon.7---*&t--Te-y did conclude by their analyses, based on the
                                    comparison they carried out, was that reserve pLts differed from control Ponds.                                                                                             Recent experience from the Brontosaurus well and other North Slope exploration
                                    The USFW found 78% of their compariso-nsto be-statistically sigiTi-ficant (2T-o-f                                                                                           wells drilled from Ice pads do not support the conclusion that this result Is an
                                    27 comparisons). In a re-analysis of the same data, ARCO Alaska Inc. found 16%                                                                                              "unavoidable consequence". The Brontosaurus site after 18 months has an
                                    of their     .comparisons to be slanificant (3 of 19 comr-a-risons)a                                                                                                        affected area of only 1.5 acres, which represents the reserve pit cap. The four
           CA)                                                         ' 1 1.       -      . The difference was that USFW compared                                                                              acre Ice pad has had virtually no effect on the tundra vegetation and the areal
                                    reserve pits to control ponds, and ARCO compared ponds near reserve pits to                                                                                                 extent of the pad Is not recognizable from the air or ground. A pond Is a result
                                    control      ponds. There is no question that reserve pit water quality differs from                                                                                        only If the reserve pit 13 not capped.
                                    natural      ponds. The appropriate question 13 how natural ponds near reserve pits
                                    differe      from control ponds. USFW has riot adequately analyzed the data to                                                                                      Pg.    100, para S. "The almost unavoidable minor oil leaks and spill                                    ..... which would
                                    answer this question.                                                                                                                                                       contaminate the tundra and, possibly, the aquatic environment....
                                    There are numerous              other major deficiencies In West and Snyder-@Conres draft                                                                                   "Minor" needs to be quantified. The statement could be generally correct for
                                    report that have never been corrected,                                                                 Because of                                                           spills less than 10 gallons. Some of these spills might go undetected and reach
                                    these problems, we recommend deleting any references to WeSL and Snyder-                                                                                                    the tundra or aquatic environment during spring break-up. However, spills of oil
                                    Conn's report or their conclusions.                                                                                                                                         are easily noticed on Ice and snow and rarely escape detectiono even In quantities
                           Pg. 100, para. 3. 'There are two approaches to abandoning an exploratory well reserve                                                                                                of less than a gallon. Furtherp these spills are easily and routinely cleaned up
                                    pit- 1. Leave It as Is        .......                                                                                                                                       and disposed of properly. All that Is required Is that the snow/oll mixture be
                                                                                                                                                                                                                scooped up by shovel or front end loader. Thus the actual amount of spilled oil
                                    Recent studies In the Canadian Arctic (French, 1983) and In the NPRA, Alaska                                                                                                that lasts until spring Is exceedingly minor.
                                    (Nuera Reclamation, 1986) document the minor environmental effects of                                                                                               Pg. 100. para. 9. "Gaseous and particulate emissions which temporarily reduce air
                                    abandoning a drilling reserve pit without closure. Howeverp It Is current Industry
                                    practice to "button up" the reserve pit adjacent to exploratory wells. All recent                                                                                           quality In the locale".
                                    state and federal lease sale stipulations require complete closure and                                                                                                      "Locale" needs to be quantified, since the affected area from a single drilling rlg
                                    containment of reserve pits. Therefore, for the purposes of discussing future                                                                                               is minimal and the effects negligible.
                                    options for reserve pit closeout on the Coastal Plain, option #1 Is not relevant
                                    and should be deleted.                                                                                                                                              Pg. 101, para. 1. "The most disruptive and th                       Ie most visually displeasing (for thousands
                           Pg. 100, para. 4           . .....   'Therefore, this method requires remobilizing construction                                                                                      of years) places from which to obtain gravel are the upland areas."
                                    equipmentt opening a gravel pit elsewhere, and hauling In material to fill In and                                                                                           Abandoned upland gravel borrow pits would either flood naturallyp or could be
                                    "mound up" over the reserve pit area                  ......                                                                                                                purposely flooded, to create an artificial lake.
                                                                                        -6-                                                                                                                                                                          -7-

                                                                                                                                             Pg. 103, para. 4.       Impoundment concerns can be mitigated by adding culverts
                    Pg. 101, para. I "Today, the untrained observer can scarcely find those (NPRA)                                                  periodically after construction, as found to be necessary.
                          borrow sites."                                                                                                     Pg. 103, para 5. Reference to Meehan 1986 and calculation of 7000 acre's of secondary
                          We would support the evidence that carefully engineered and environmentally                                               effects.
                          sensitive gravel borrowing -can   minimize Impacts and create only temporary
                             10 year) disturbance.                                                                                                  We find It Inappropirate to reference a preliminary draft report that has been
                                                                                                                                                    widely criticized for Its lack of technical credibility                      It would
                    Pg. 101, para 2. "The large quantities of water required for development drilling on                                            be more appropriate to reference Walker et al., 1984, Meehan's main source.
                          the 1002 area are not available."                                                                                         Secondary effects based on measurements actually taken at Prudhoe Bay could
                                                                                                                                                    be derived.
                          Although the proposed solution of flooding streambed gravel borrow pits Is a well
                          reasoned and feasible alternative, It Is by no means the only one. Water Is                                               Walker et al. (1995). calculated the areal extent of secondary effects In a 20 km2
                          potentially available from large underground aquifers (likely In a geological                                             area of the most heavily developed region of Prudhoe Bay.                The authors
                          environment containing oil fields) or seawater could be pumped via pipeline from                                          themselves refer to their analysis as a worst case scenario for the olifield       and
                          the coast, similar to the way waterflood operations are carried out at Kuparuk                                            their analysis "must not be used to make Interpretations for the field           as a
                          and Prudhoe Bay.                                                                                                          whole". The main data for this area, referred to as Map 22, Is contained in Table
                                                                                                                                                    12.
                    P. 10 1, para 3. "The Infrastructure required to develop the economic prospects of the
                          1002 area Is described In Chapter IV."                                                                                    Walker et al. measured 222.93 hectares of gravel pads and roads in this area as
                                                                                                                                                    of 1983. Vehicle tracks, gravel and debris, and heavy dust or dust killed tundra
                          on page 75 of the Draft 1002 Report Is Is stated that nthe explorationt                                                   comprised 48.79 hectaresp or a factor of 0.22 for every unit area of road or pad.
                          development# and construction scenarios presented herein are general concepts                                             Thermokar3t totaled 59.29 hectares, or a factor of 0.27. (Flooding data is
                          and must not be considered to be final engineering solutions....", thus the word                                          ignored because the Prudhoe area Is dominantly wet, flat lowlands and not
                          infrastructure on Pg. 101, para 3 should be modified by "proposed" or                                                     comparable to the ANWR region. It Is fairly safe to assume that dust and gravel
                          "hypothetical", such as "the hypothetical Infrastructure required to develop...."                                         spray are more Independent of terrain and habitat type). Combining both
                                                                                                                                                    thermokarst and gravel spray, dust and vehicle tracks yields a total secondary
                    Pg. 101, para 3. "Construction of as many as four or five year-round five-foot thick                                            effect (excluding Impoundments) of approximately 0.5 for every unit of gravel.
                          gravel C-130 airstrips on the 1002 area".                                                                                 For a development scenario of 5000 acres, then, actual data has measured that
                                                                                                                                                    secondary Impacts are on the order of 2500 acres. This Is also noted to be a
                          The hypothetical development in Figure V-1, pg. 90 shows only two airstrips.                                              worst case scenario. In light of this data, the proposed 7000 acre estimate for
                          The current airstrips In use for the five existing North Slope fields, a size similar                                     secondary Impacts Is an overexaggeration and not defensible.
                          to the proposed 1002 developmento number three. Thus "four or five" appears to
                          be an overstatement.                                                                                                      Choosing a 1001 corridor for secondary effects led to an overestimate due to the
                                                                                                                                                    fact that dust and gravel spray may reach the distance specified by the
                    Pg. 101 #6. Same comment as for Pg. 100, para 8.                                                                                references locally These effects are not continually present along roads out to
                                                                                                                                                    1001.
                    Pg 101, para 17. "Construction of a solid-core causeway .... would require breaching to                                  Pg. 103, para 7. "Since 1972 some 23,000, Mostly small, spills have been reported to
                          permit fish passage...."                                                                                                  the Alaska Department of Environmental Conservation. The largest spill of
                          The breaching of gravel causeways for fish passage Is not a necessary                                                     658,000 gallons was the result of sabotage In 1978. A spill of over 200,000
                          requirement.      Although fish do pass through large breaches (Endicott                                                  gallons near Atlgun Pass In 1979...."
                          Environmental Studies 1995) they also go around causeways with and without
                          large breaches (Endicott Studies 1985; Prudhoe Bay Waterflood Studies 1991#                                               It should be pointed out that neither of these Incidents occurred on the North
                          1982, 1983 and 1984). The Waterflood studies demonstrated that the West Dock                                              Slope, although they are an Indirect outgrowth of North Slope developm     .ent.
                          Causeway was not an Impediment to the migration of large fish. The 1985
                          Endicott and Colville River Fish Studies showed that even the smallest migratory                                   Pg. 104, para 1. "To dateg the cumulative effect of spills has not been significanV.
                          anadramous fish, young-of-the-year Arctic Cisco, were able to get by both the
                          West Dock and Endicott causeways to reach the Colville River.                                                             We would concur with this assessment. However, the main reason for the lack of
                                                                                                                                                    significant Impact Is completely absent from the discussion. Of the $2,216
                    Pg. 103, para. 4. "Also thermokarstv which commonly occurs on the edges of roads and                                            gallons spilled in_1985, very little actually remained in the environment because
                          pads..."                                                                                                                  it was prwerly cleaned M. The discussion leaves the reader to conclude that all
                                                                                                                                                           gaijons went into the tundra or wetlands. Spill prevention and cleanup Is
                          References are required for this conclusion.

                                                                                                                                                                    5)     Aggressive fluid management of reserve pits to prevent overtopping
                           aggressively pursued on the North Slope and to date has been effective. Most                                                                    and leaking.
                           spills occur on gravel production pads while snow Is on the ground and are
                           therefore easy to spot and cleanup. Those that do escape detection or occur In                                                           6)     Chemical screening of all reserve pit fluids prior to surface disposal
                           the summer off gravel pads are treated with sorbent pads and rehabilitation and                                                                 to Insure water quality standards are met.
                           revegetatlon procedures.
                                                                                                                                                                    7)     Comprehensive oil spill contingency planning.
                           To gain the perspective of what percent of the 82,216 gallons reported In 1995
                           escaped cleanup and proper disposal, oil spill records for the Prudhoe Bay                                                               9)     Spill clean up procedures, Including proper disposal of snow/oll winter
                           (FAstem half) and Lisburne oil fields were reviewed. In 1985 ARCO experienced                                                                   In and sorbent pads In summer.
                           29 oil SPI113 that were reported to ADEC for the two olifields. These 29 spills
                           represent approximately 19,000 gallons of crude, diesel and other fluids. Twenty                                                         9)     Rehabilitation and revegetation of disturbed sites, Including gravel
                           five of the 29 were spilled on gravel production pads, largely In the winter, and                                                               spray removalt reseeding, replacing damaged vegetation mat.
                           were cleaned tip nearly 100% by removing the contaminated gravel or gravelv
                           snow and Ice mixture. The 4 spills off of gravel pads represent approximately
                           I 150 gallons of crude, diesel and natural gas liquids. Cleanup activities were not                                                      10)    Road watering to minimize dust generation.
                           able to recover all the spilled liquids and It Is estimated that 300 - 400 gallons                                                       11)    Improved culvert design and placement to avoid Impoundments.
                           were not recovered. This represents approximately 2% of the total volume of oil
                           spills that escaped into the environment.                                                                                          The point Is the mitigation section Is inadequate. only five sentences attempt to
                     Pg. 104, Para 4-6v Mitigation Section.                                                                                                   cover the large body of commonly used mitigative technology that applies to the
                                                                                                                                                              preceding 16 paragraphs. Further, numerous sentences have nothing to do with
                           The preceding discussion of Impacts to vegetation, wetlands, and terrain types                                                     mitigation and should be placed in the preceding consequences section: "An
                           covers in detail the possible Impacts from:                                                                                        overall loss of approximately 3,650 acres (0.4 percent of the 1002 area) of
                                                                                                                                                              existing vegetation could result, based on the estimated facility needs for
                                  1)    seismic surveys                                                                                                       developing the entire 1002 area. Habitat values would be lost when these
                                  2)    ice pads and roads                                                                                                    habitats are covered by pads, airstrips, roads, and other support facilities.
                                  1%    grave, pads and toads                                                                                                 Additilon-allyt at lleast 7000 acres could be modified by the secondary effects of
        V1                        X                                                                                                                           gravel spray and dust deposition, altered snowmelt, and. erosion patterns,
        al                        4)    reserve pits                                                                                                          thermokar3t, Impoundments, and pollution Incidents.              Habitat values would
                                  5)    all and fuel spills                                                                                                   decrease."
                                  6)    gravel mining
                                  7)    secondary effects of roads, such as dust, thermokarsts gravel spray                                            Pg.    104, para 7. "The expected modification of approximately 12,630 acres (0.9
                                        and Impoundments                                                                                                      percent of the 1002 area) would be a moderate effect (Table VI-1) on area
                                  9)    seawater spills                                                                                                       vegetation and wetlands."
                           The following Mitigation Section for these Impacts discusses only a portion of                                                     The estimate of 5,650 acres for direct Impacts of gravel appears to be
                           these Impacts and does so In the briefest possible manner. It Is not for lack of                                                   reasonable based an the proposed scenarlo.             Further, the classification of
                           subject matter or data, however, since 19 years of Arctic experience and                                                           moderate Impact for this area 13 appropriate. However, dasWylng 7000 acres of
                           millions of dollars have been spent an effective mitigation techniques. The                                                        secondary Impacts as moderate Is either a) to large an area to be placed in the
                           following commonly employed mitigation techniques should be discussed to.                                                          moderate category, as defined, or b) too severe a category for that broad an
                           properly balance the discussion:                                                                                                   area.
                                  1)    Snow depth, routing and USF&W oversight procedures followed during                                                    The moderate category requires either a "local modification of considerable
                                        seismic surveys                                                                                                       severity" or a "widespread modification of lesser severity'!. Since 12,650 acres is
                                  2)    Current accepted design parameters for Ice pads and roads, (ie.                                                       0.8 percent of the Coastal Plain, It does not fit the category of "widespread".
                                        Brontosaurus well, NPRA# ARCO) that requires sufficient thickness,                                                    Therefore the 7000 acres of secondary effects are defined as local modification
                                        siting considerations.                                                                                                having "considerable severity". It Is difficult to defend the hypothesis that 7000
                                                                                                                                                              acres of road dustp gravel spray and thermokarst would reach this degree of
                                  3)    Site selection criteria for roads and pads that avoid critical habitats.                                              Impact. Based on Walker et al. 1994p and the analysis contained In the comment
                                                                                                                                                              for Pg. 103, Para 3, we would recommend that this figure be changed to 2500
                                                                                                                                                              acres for secondary Impactsv or $130 acres total.
                                  4)    The trend   towards smaller gravel pads and reserve pits, decreasing
                                        the wetIsIte "footprint".
                                                                  -10-                                                                                                                               -11-

                     Pg. 106, para. 2. "Later Studies (Cameron and Whitten, 1979, 1980; Cameron and                                               Based on the earlier, discussion that 2500 acr
                            others, 1981 Whitten and Cameron, 1985) indicate an absence of calving near                                          case" based on actual data, then the above underlined changes should be made.                        the Coast at Prudhoe Bay during 1976-85, possibly due to avoidance of           the                            Pg. 107, para 5. "Whitten and Cameron (1985) 1
                            activity area by calving caribou".                                                                                    caribou and generally low percentages of cal
                                                                                                                                                  their annual surveys of the CAH calving grounds,
                            This Is a widely quoted, though erroneous, conclusion of the low numbers of cows                                      displaced to adjacent areas already used for calving."
                            with calves found In the Prudhoe Bay area. ADF&G reports for the period 1979-                                         Based on Gavin (1980) which demonstrated
                            85 report average caribou densities of 0.06 caribou/km2 while Gavin (1979)
                            reports densities of 0.01-0.05/km2 for the period 1970-79, or predevelopment.                                         and low percentages of calves throughout the
                            Thus the conclusion Is that total caribou densities have always been low. In                                          reached that numbers have always been low in
                            regards to calving Inspection of Table I shows the same consistent low historical                                    the conclusion of the Alyeska Caribou Worksh
                            numbers with little change through development.                                                                       for Pg. 106, para 2). White et al. (1975) sugge
                                                                                                                                                  and moist areas near Prudhoe Bay makes this
                            At a recent caribou workshop at Alyeska (Demography and Behavior of the                                        Pg. 107, para. 5. "Dau and Cameron (1985). In wha
                            Central Arctic and Porcupine Caribou Herds in Relation to Oil Field
                            Development Oct 1986) all ADF&G and USFW participants reached -the                                                   of caribou displacement by oil development
                            consensus that "the Central Arctic Herd (CAH) has never calved In the Prudhoe                                         groups showed measurable declines In habitat
                            Bay area In large numbers."                                                                                           on either side of the Milne Point Road In the
                                TABLE I - TOTAL NUMBERS OF COWS AND CALVES WITHIN THE                                                             The "two mile reference Is a typographical
                                            PRUDHOE BAY AREA (1165 km2),1970-1979.                                                                km".
                                                         From Gavin, 1990.                                                                 Pg. 108, para. 2. "Displacement of the Porcupine
                                                                                                                                                  calving area to a less desirable area woul
                                                    Calves per                                      Density                                       productivity."
                     Year       Cows    Calves      100 Cows      YearlIngs Bulls       Total      Caribou/km                                     This statement Is true, as It stands. However, in the ensuing discussion it is

                    1970       24          17         71             a                  49         0.04                                          implied that any displacement of the PCH would necessarily be into a less
                                                                                                                                                  desirable area. As the report points out, there is over two million acres of
                     1971       16          7          44             7                  30         0.03                                          known concentrated calving area, not counting peripheral areas. Sinch the PCH

                     1972       8           5          63             4                  17         0.01                                          has calved throughout this area successfully in the past, and there is no known
                                                                                                                                                  effect of decreased productivity In the years that the herd used those areas

                     1973       24          9          38             9                  42         0.04                                          exclusively, there is no reason to conclude that the areas outside the core

                     1974       34          9          27             a                  51         0.04                                          calving area area less desirable. Therefore, the expectation that the herd's

                     1975       27          13         48             4                  44         0.04                                          productivity will suffer Is not supportable.
                     1976       19          4          21             5                  28         0.03                                   Pg. 108, para 2. "Although the CAH and PCH calving grounds are roughly equal in

                                                                                                                                                  size..."
                     1977       14          11         79             3                  28         0.03
                     1978       29          15         50             7          6       57         0.05                                          The total survey area covered by Whitten and Cameron (1985) of the CAH
                                                                                                                                                  calving grounds 13 approximately 1.4 million acres. This figure is equal or higher
                     1979       13          7          50             8          4       32         0.03                                          than the CAH calving area by whatever definition. The concentrated calving
                                                                                                                                                  area for the PCH Is given as 2.1 million acres, and if peripheral areas are
                                                                                                                                                  considered this figure would probably Increase to three million acres or more.
                     Pg. 107, para 2. "These changes In vegetation and thus food availability, could occur                                       Thus, at a maximum, the CAH calving ground is 2/3 of the PCH, and probably
                            on approximately 7000 (2500) acres, of which nearly 1800 (650) acres Is In                                            closer to 1/2. (See Figure 1).
                            Resource Category I (1 (0.3 percent). Total modification of caribou habitat
                            attributable to direct and secondary changes would occur on about 12,650                                   Pg. 108, para. 2. "Based on 1982 population estimates."
                            acres, or 0.8 (0.5) percent of the 1002 area, and 1.3 (0.8) percent of the core
                            calving area (Resource Category I habitat)".                                                                          More recent population estimates since they

                                                                -12-                                                                                                                  -13-

                    Pg- 109, Para. 3. "As described by Whitten and Cameron (1995), absolute density for                                               The assumption that all caribou (100%) would be displaced up to 2km (or 2 miles)
                                                                                                                                                      s totally unsupporteJTy Dau and Cameron's data. Total caribou decrease from
                          the PCH Is nearly 14 times, and for the Western Arctic Herd (WAH) nearly 15                                                 an average of I caribou/km2 predevelopment to 0.4 caribou/km2 post-
                          times greater than for the CAH. The difference In effective densities Is even
                          greater, particularly for the PCH, which are found at approximately 24 FarISR                                               development up to Ikm from the road, a decrease of approximately 60%. From I
                          per square kilometer as compared with approximately 3 caribou per square                                                    to 2 km the decrease Is 1.7 cArlbou/km2 to 1.0 carlboU/km2, or a 40% decrease.
                          kilometer for the CAH. Effective density of the Western Arctic Herd Is 13                                                   Beyond 2km caribou were more numerous after development than before
                                                                                                                                                      (presumedly the displaced caribou plus Increased caribou due to a steadily
                          caribou per square kilometer."                                                                                              Increasing growth rate). For calves there was nearly a 90% decrease for the
                                                                                                                                                      first km and approximately a 50% decrease from I to 2km. Beyond 2 km calves
                          The difference In effective densities Is not greater, It Is less than absolute                                              Increased above pre-development densities.
                          densities. For the PCH, absolute density Is 14 times the CAH, while effective
                          density Is 24 carlbou/km2 vs. 3 caribou/km2 or 3 times. For the Western Arctic                                              This would Indicate a weighted average of an approximate 70% decline In calves,
                          Herd, absolute density Is 15 times the CAH, while effective density Is 15                                                   or maternal cows, up to 2km with the displaced cows and calves moving to an
                          caribou/km2 vs. 5 caribou/km2 or 3 times. Thus the difference In effective                                                  area beyond 2km from roads. This Is equivalent to a 100% displacement up to
                          density Is less than absolute density.                                                                                      0.7 X 2km = 1.4 km or .9 mi for the purposes of calculating affected habitat.
                   Pg. 103, para. 3. "The lack of observable adverse effects from displacement exhibited                                              Thus a one mile displacement Is consistent with Dau and Cameron (1985) and
                          by the CAH would be unlikely for the PCH. The PCH Is much more crowded In                                                   should be used rather than the current two mile limit. This would, or course,
                          Its calving habitats, and a substantially greater proportion of Important calving                                           decrease all estimates of the affected area by 50%.
                          habitats would be Involved with development that Included their core calving
                          area."                                                                                                              Pg. 109-109. In general, clarification Is needed with regard to references by S. Murphy
                                                                                                                                                      and/or J. Curatolo on ramp and crossing studies. As this Information Is
                          The fact that   the PCH has higher calving densities than the CAH Is not                                                    presented, It Is Incorrect, misleading and confusing-
                          sufficient to argue that displacement would be likely to cause adverse effects.
                          Two other conditions would have to be met: 1) alternative high quality calving                                      Pg.     109, para. 6. "if caribou refuse to cross through any development areas# then
                          habitat Is not available In sufficient quantities. The large area used by the PCH                                           294,000 acres would be unavailable as habitat. That area encompasses 52
                          for calving, and their historical use and success In that habitat, would Indicate
                          that this is not the case. 2) The densities achieved by the PCH during calving                                              percent of total it-asect-reslef habitat and over 80 percent Of Coastal insect-reliei
       -4                 are near some threshold limit above which range destruction or negative                                                     habitats. This would mean that all coastal Insect-relief habitats within the 1002
                          Intraspecific Interactions would occur. This has not been demonstrated.                                                     area, except for a small area In the eastern portion, would become unavailable
                                                                                                                                                      under full development."
                  Pg.     108, para. 7. "Based upon the work of Dau and Cameron (1985), caribou are                                                   The hypothesis that the PCH would be eliminated from virtually all It's coastal
                          displaced approximately two miles out from development."                                                                    insect-rellef Is predicated by the supposition that the PCH would "refuse to cross
                          Dau and Cameron (1985) show a partial displacement out to two kilometers, not                                               through any development areas'% There are no studies In the literature to
                          two miles.                                                                                                                  support the hypothesis that a properly designed pipeline and road would present a
                                                                                                                                                      total physical barrier to caribou movements. Yet there are abundant examples
                  Pg.     109, para. 7. "Within this approximately two mile area of Influence are about                                               of herds throughout the world regularly crossing roads, roads with pipelines,
                          357,000 acres (38 percent) of the total concentrated calving grounds in the 1002                                            hunter's firing lines, and even Improperly designed pipelines such as the Norilsk
                          area."                                                                                                                      gasline in Russia (Shidefer, 1986). The supposition Is unsupportable.
                                                                                                                                             Pg. 109, para. 6. "The second factor Is to assume the approximately 2-mile sphere of
                          Given that Dau and Cameron (1985) shows a partial displacement out to 2km, or                                               Influence for oil development used previously. Under that assumption, caribou
                          1.2 miles, then the effected area would be reduced to 60%, or 214,200 acres (23                                             crossing through the development area would avoid using approximately 72pOOO
                          percent) of the total concentrated calving grounds.                                                                         acres or 29 percent of Identified coastal Insect-relief habitat within the 1002
                 Pg.      108, para. 8. "An approximately two mile displacement of caribou out from                                                   area....
                          petroleum facilities would Include loss of 32 percent of the most critical PCH
                          core calving areas (Table VI-5)." "The projected displacement from preferred                                                The 2-mile sphere of Influence Is based on the Dau and Cameron (1985) study
                                                                                                                                                      that was conducted during the calving seasont not mosquito harra3ment season.
                          calving habitat would represent a complete loss of habitat values."                                                         Conclusions regarding movement of mosquito harrased groups seek        .Ing coastal
                          Given that Dau and Cameron (1983) show a partial displacement out to 2km, or                                                areas cannot be drawn from studies of the distribution of caribou during calving.
                          1.2 milest then the 32 percent should be reduced to 19 percent.                                                             Dau and Cameron (1986) found that 'Vurlng 3une, the relative number of caribou
                                                                                                                                                      within Ikm of the (Milne Point) road was positively corelated with distance from

                          the road; there was no relationship between number of caribou and distance from                                             caLvh
                                                                                                                                                           2& habitat throughout their range, The high productivity reported for the
                          the road for either May or 1!ggAug.", It Is wen recognized that measurable                                                  ANWR muskox PoPula-tion fiaS_Te;;_n attributed to the availability of preferred
                                                                                                                                                      forage during summer (Robus 1991) and to the tendency for herds to remain In
                          behaviors that can occur during-calving, such as avoidance, are often absent at                                             relatively restricted home ranges, thereby capitalizIng on the abundant forage
                          other times of the year, such as during Insect harassment.                                                                  Olngfors 1980). As the 1002 report points out, "carrying capacity has apparently
                                                                                                                                                      not been reached." Thus due to the fact that the herd 13 still expanding its
                    Pg- 110, para. 2. "Effects of disturbance might also Include .... energy stress, possible                                         range, and that high productivity rates have been tied to abundant forage, It does
                          critical during times of low energy reserves rich as winter-.."                                                             not follow that displacement would have a negative effect on productivity.
                          The vast majority of the PCH would not be In contact with the development                                            Pg. 113, para. 4. "From the reports of Russel (1977) and Reynolds and La Plant (1983),
                          scenario during the winter.                                                                                                 a 2 mile sphere of Influence was assumed In calculating the range which could be
                    Pg- I I I. para. 3. "Mitigation of the loss of caribou habitat In Resource Category I                                             affected by full leasing."
                          (242,000 acres of core calving area) is not possibler                                                                       The term "affected" 13 defined In the next sentence as "lost or greatly reduced."
                                                                                                                                                      Thus the 2-mile area Is being defined as an area where muskoxen are removed by
                          This statement requires explanation.                                                                                        100% (lost) or decreased by an amount In the range of 60-90% (greatly reduced).
                                                                                                                                                      The data of Reynolds and LaPlant (1983) show that a flight response occured In
                    Pg- 112, para 3 & 4. Based on the preceding comments, this entire summary of effects                                              only 7 of 31 groups (23%) encountered In the Tamayarlak area (Table 1) or the
                          on the Porcupine caribou Herd should be modified. Although a conclusion of                                                  Okerokovik area (Table 3). This flight response occurred at distances from 200
                          moderate Impact may still be possible, the affected areas, particularly the 80%                                             m to 3.2 km, or an average of 1.3 km. Based on these data, one would have to
                          of coastal Insect-relief habitats should be modified.                                                                       significantly Increase the stimulus, or shorten the 2-mile sphere of Influence, or

                    P
                        112, para. 3. "For the CAH, a moderate change In distribution or decline In that                                              both, to reasonably expect a 60 to 100% displacement In muskoxen. Four of the
                     g-                                                                                                                               9 groups (44%) displayed no response at distances less than a km. It Is not sound
                          portion of the CAH using the 1002 area could occur. The effect on the entire                                                scientific judgment to pick the farthest distance reported for a flight reaction
                          CAH population throu     hout its range may also be moderate. Those effects on                                              (3.2 km) and then conclude that most or all of the animals will behave In a
                          the segment of the CRH within the 1002 area would be similar to those on the                                                similar manner, when the Reynolds and LaPlant data show that only 23% actually
                          PCH that occur from disturbance, displacement and barriers to free movement.                                                did. This is particularly true since habituation Is known to occur In muskoxen,
                          The population decline or distribution change would be 3-10 percent for the CAH
                          throughout Its range."                                                                                                      as the report states.
                                                                                                                                                      Thus the assumption that a 2-mile sphere of Influence Is appropriate for a
                          The basis for concluding that a moderate dwle In            the CAH distribution or                                         complete displacement of muskoxen Is not supportable by the data.
                          numbers has not been presented. in fact, all the data presented would lead one
                                           W.Ju,
                          to the opposite      .   ion. There Is abundant discussion In the report regarding                                   Pg. 113, para. 3. "The magnitude of that effect Is difficult to accurately predictt
                          why the CAH Is different and can be expected to respond differently to                                                      particularly in view of the expanding nature of the population and refuge
                          development than the PCH. The facts of lower overall densities, lower calving                                               management objectives to allow continued population expansion."
                          densities, more distributed rather than concentrated calving, incomplete range
                          utilization, greater habituation and the overwhelming fact that the CAH has                                                 Management objectives are Irrelevant to the topic of discussion. Whether
                          already demonstrated It's accommodation to development are all discussed In the                                             management objectives are to Increase or decrease the herd has no bearing on
                          report. Ali of these argue towards a minimal impact of the proposed scenario on                                             whether displacement will have a large or small effect on muskox production.
                          the CAH. Further, the proposed development scenario borders the extreme
                          eastern extension of the CAWS calving areas, while It overlaps substantially with                                    Pg.  113, para. 4. "Table VI-6 shows that habitat values could be lost or greatly
                          the PCH. Given all these differences discussed In detail In the report, It appears                                          reduced throughout about one-third (236,000 acres) of the muskox: range within
                          to be Inconsistent with the conclusion that the "effects .... would be similar." The                                        the 1002 area."
                          qualification of "an the segment of the CAH within the 1002 aree Is specious
                          because there Is no distinct subpopulation Of the CAH that uses the 1002 area.                                              These figures should be decreased by at least hall based an the previous
                          That a "population decline or distribution change would be 3-10 percent" Is not                                             discussion.
                          supportable. Based on Table VI-1, the envIronment9'elfect on the CAH should
                          be negligible.                                                                                                       Pg.  114, para. 1. "Major negative effects upon the muskoxen population from oil
                                                                                                                                                      development could occur, considering the present management objectives for
                    Pg. 113, para. 3. "Displacement from calving areas would have a negative effect on                                                continued population growth of the herd under natural regulation and the
                          muskoxen production."                                                                                                       displacement from habitat likely to occuOl
                          Displacement from calving areas nay have a negative effect on muskoXen
                          production If they are near 2E 2,t their upper limit If utill"            high quality
                                                                                                                                                                                           -17-

                                                                                                                                                   Pg. 120, para. I - Swans, Geese, and Ducks. One study that should be referenced In
                           It Is Inappro*prlate to attempt measure Impacts against an open ended                                                          the Murphy, et al. (1986) "Lisburne Terrestrial Monitoring Program - 1983. The
                           management policy when there Is no discussion of the carrying capacty of the                                                   effects of the Lisburne Development project on Geese and Swans." The results
                           habitat and where limiting factors to. growth may occur. This discussion                                                       of this study Indicated that there was little effect on the nesting and area use of
                           confuses whether Impacts are being measured agaInst today's current population                                                 geese, swans and ducks In the Lisburne development area.
                           (implicit In the def initions in Table VI-1) or against some future potential. If the
                           future potential Is being used as a yardstick, then one must discuss some limits                                        Pg.  120, para. 11. Ali references to the West and Snyder-Conn Report should be
                           to future population. Clearly this management goal will have to be altered In                                                  deleted for the reasons provided earlier In the comments on Pg. 100, para I and
                           the future as the herd reaches lea maximum utilization of whatever habitat Is                                                  2.
                           most critical.
                                                                                                                                                   Pg.  121, para. 7. "Table VI-7 shows the amount of habitat that could be affected by
                           If the negative effects are being measured against future potentialt It should be                                              development resulting from full leasing, assuming snow geese are displaced 1.5
                           clearly stated and the proper discussion of habitat limitations should be Included.                                            and 3 miles as observed by Gollop and Davis (1974).r
                           If the negative effects are being measured against today's current population,
                           then references to the management objectives should be deleted as they confuse                                                 The reactions of fall-staging snow geese to noise were studied by Gollop and
                           the Issue.                                                                                                                     Davis (1974) and Wisely (1974). In those studlesp gas compressor noise simulators
                    P. 114, para. 2. "Howevers considering the larger extent (159,000 acres, 43 percent) of                                               were placed in fall-staging areas and the reactions of flying and feeding flocks
                                                                                                                                                          were observed with and without noise production. Some general conclusions,
                           all high-use muskoxen habitat within the 1002 area, as well as more than 33                                                    which cannot be evaluated quantitativelyt include%
                           percent of the population's high use habitats throughout the Arctic Refuge which
                           could be affected under full leasing, a change In, distribution or decline affecting                                           1)    noise may decrease the number of flocks that land at a particular site;
                           25-50 percent of the population may occur."                                                                                    2)    noise may cause a temporary alteration In the flight path of goose flocks;
                                                                                                                                                          3)    Yee:e:e may avoid feeding sites where high noise levels are present;
                           1) Given that the 2-mlle sphere of Influence figure used to derive the affected                                                4)         Ing flocks may react to the sudden occurrence of gas-compressor type
                           area Is based on a maximum distance to Illicit a behavioral response which may                                                       noise up to 3 ml away (Gollop and Davis 1974); and
                           have no demographic consequences (and did not In Reynolds and LaPlant!s study)                                                 5)    feeding flocks may approach to within 300 rn of continuously-operating
                           and 2) there Is no data to indicate that the muskox are even approaching full                                                        gasr@coompressor -.rise simulat tors, '---t most flocks appear to avoid the area
                           utilization of their habitat, and 3) the herds are expand!% their range driven by                                                    within 900 m in front of such noise simulators (Wisely 1974).
                           a high productivity, It Is difficult to support a conclusion that a decline of up to
                           50 percent may occur.                                                                                                          Gollop and Davis (1974) did observe some snow geese disturbance up to 3 miles,
                                                                                                                                                          but, as with other studies cited In the 1002 report, this should not be given as an
                    Pg.  114, para. 9. "Effects     on the regional moose population from habitat loss and                                                adequate Indication that geese would be totally displaced out to 3 miles. In fact,
                           mortality due to oil development In the 1002 area would be minor."                                                             Gollop and GavIs report In their Table 8 that the mean distance that snow geese
                                                                                                                                                          flared under simulator tests was 365 yds, or 0.2 miles. Thus the 1.5 and 3 mile
                           Due to the very low population of moose on the Coastal Plain, the extremely low                                                limits suggested by the report are gross overestimates and are not supported by
                           loss of habitat expected, the ability of moose to habituate to disturbance and the                                             the cited literature.
                           ability of ADF&G to regulate moose harvest, It Is reasonable to expect a
                           negligible, rather than a minor, effect.                                                                                Pg. 121, para, S. "Reduced time spent feeding and lost habitat In which to feed would
                                                                                                                                                          result from petroleum development, adversely affecting accumulation of the
                    Pg.  115, para. 6. "A moderate decline of the wolf population Using the 1002 and                                                      energy reserves essential for migration. Davis and Wisely (1974) estimated that
                           surrounding area could result from the cumulative effects of direct mortality                                                  staging juvenile snow geese unable to adjust to aircraft disturbance accumulated
                           and reduced production or survival of young, caused by reduced prey                                                            20.4 percent less energy reserves due, to lost feeding tlme@w
                           avallability.0
                                                                                                                                                          Davis and Wisely's discussion of the energetic effects of disturbance is
                           As poInteO out In the state references, there Is Indeed a relationship between the                                             questionable because the authors assumed that disturbance reaction time would
                           abundance of wolves and the biomass of ungulate prey. Howeverv even If one                                                     subtract In equal proportions from all other activities. A more conservative
                           hypothesizes a 40% decline In the PCH from 190,000 to 100,000 animals, It Is                                                   approach would be to assume that the geese were capable of at least some
                           difficult to demonstrate that 3 to 10 wolves would be In any way limited by a                                                  compensatory Increase In feeding rate. The estimates of 20.4% reduction and
                           herd of such magnitude. The cited references all deal with wolf/caribou                                                        9.5% reduction In energy reserves acquired by juvenile geese subjected to 2-h
                           densities that are orders of magnitude higher than 0.00002 to 0.0001. Further,                                                 Interval fixed-wing and helicopter overfilghtst respectivelyp are probably
                           no consideration Is given to alternate prey species.                                                                           overestimates of the bioenergetic Impact of these disturbances.
                           The environmental effect an wolves from the proposed development should be
                           changed to negligible.                                                                                                                                               _19-

                  Pg. 121, last para. A decline In waterfowl populations has not been documented In the                                                                     LITERATURE CITED
                        Lisburne operational area. This fact Is counter to the supposition made that a
                        decline In waterfowl could occur as a result of development.
                  Pg. 122, para. 2. "The average number of snow geese annually staging on the 1002                                         Bergerud, A. T., R. D. Jaklmchuk and D. R. Carruthers, 1984. The Buffalo of the
                                                                                                                                                 North: Caribou (Ramifer tarangus and Human Developments. Arctic 37(l):
                        area could be reduced by almost 50 percent."                                                                             22.
                        The affected habitat has been grossly overstated based an a misapplication of                                      Colville River Fish Studies, 1985, by Entrix for ARCO Alaska, Inc.
                        Gollop and Davis's results and the assumption that geese could not compensate
                        for lost feeding time or habituate to disturbance. This has led to an equally                                      Dau and Cameron, 1996.          Responses of Barren Ground Caribou to Petroleum
                        gross overstatement of the potential ef fects on snow geese.                                                             Development Near Milne Point, Alaska. Report to Conoco, Inc. and ADF&G.
                  Pg. 123, para. 4. "Recent work near Prudhoe Bay has shown that reduced numbers of                                        Davis et al.p 1993. Disturbance and the Delta Caribou Herd in Caribou and Human
                        shore-birds occur near roads In the oil field (troy and other, 1983; Troy, 1984)@"                                       Activity, edited by A. M. Martell and 0. E. Russel, Procedures of Ist North
                        Troy's work also shows Increased habitat use near roads for several species,                                             American Caribou Workshop, Whitehorse, Yukon 28 - 29 September 1993.
                        Including Northern Pintallsl Red-Necked and Red Phalarope3 In Impoundments,                                        DletrIck, L. Alaska Department of Environmental Conservationt Fairbanks, personal
                        and Seml-palmated Sandpipers In dust Induced early melt zones.                                                           communication.
                  Pg. 123, para. 11. "The major effects anticipated on the PCH from development could                                      Endicott Environmental Studies 1985. Prepared by Envirosphere for the U.S. Army
                        cause an effect on golden eagles because of decreased prey abundance or                                                  Corps of Engineers and Standard Alaska Petroleum Co.
                        modified distribution."
                                                                                                                                           Felix, N. A., and 3orgenson, M. T., 1985p Effects of Winter Seismic Exploration on the
                        There Is no reasont a priori, to assume that a 20 - 40% reduction In the PCH                                             Coastal Plain of the Arctic National Wildlife Refuse, Alaska     , p. 622 - 622, In
                        would necessitate a moderate Impact on golden eagles, given the high numbers                                             Garner, G. W., and Reynolds, P. E., editors, 1994 update report, Baseline Study-
                        and densities of the PCH.                                                                                                of the Fish, Wildlife, and their Habitatst Anchorage, U.S. Fish and Wildlife
                  Pg.  131, para. 6. "Moreover, the existence of oil facilities and activities would                                             Service, Region 7, 777 p.
                        eliminate the opportunity for further scientific study of an undisturbed                                           Felix, N. A. 3orgensong M, T., Raynolds, M. K.p Lipkin, R,, Blank, D. L., and Lance, B.
                        eco3y3tem.r                                                                                                              K., 1986a, Effects of Winter Seismic Exploration on Visual Resources,
                        While the opportunity for study of an undisturbed system might be eliminated,                                            Vegetation, and Subsurface Stability of the Coastal Plain of the Arctic NatlonaJ
                        the reality Is that millions of dollars worth of actual studies are guaranteed to                                        Wildlife Refuge, Alaska -In Garnerl G. W., and Reynoldsp P. E., editors, 1985
                                                                                                                                                 update report, Baseline Study of the Fish, Wildlife, and their Habitats:
                        take place If the coastal plain Is developed. The amount learned will far                                                Anchorage, U.S. Fish and Wildlife Service, Region 7, In press.
                        outweigh the studies that might be carried out with little economic Incentive.
                                                                                                                                           Felix, N. A., 3orgenson, M. T., Raynolds, M. K., Lipkin, R., Blank, D. L. and Lance, B.
                  Pg. 143, Table VI-8. The chart Indicates under "Artifacts at Development Sites" that                                           K. 1986b, Snow Distribution on the Arctic Coastal Plain and Its Relationship to
                        all would be lost In the full and partial leasing alternatives. When, In fact, under                                     Disturbance Caused by Winter Seismic Explorationt Arctic National Wildlife
                        RTrrent law prior to surface use, an archaeological survey must be performed                                             Refuge# k Garner, G. W., and Reynolds, P. E., editors, 1983 update report,
                        over the area that may be Impacted. Important archaeological sites are avoided,                                          Baseline Study of the Fish, Wildlife, and their Habitats: Anchorage, U.S. Fish
                        studied or removed to prevent damage to this resource.                                                                   and Wildlife Service, Region 7, In press.
                  Pg. 143 - 148. Summary of recommended mitigation for the        1002 area. We recognize                                  Frenchs H. M.t 1983, Surface Disposal of Waste Drilling Fluldsp Ellef Rlngnes Island,
                        the need for meaningful mitigation measures, many of those listed are presently                                          N.W.Ta Short-term observations, Arctic, Volume 38, No. 4, pgs. 292 - 302.
                        In force In the North Slope oil flelds; howeverv during the last ten years we have
                        found that some of the mitigation measures that were put In place at the onset                                     Gavin, A., 1990. Coastal Oil Development and Its Effects on Caribou Migration and
                        were unnecessary. We recommend a more general/flexible case-by-case option                                               Population Patterns in the Prudhoe Bay Region of Alaska's North Slope, 1969 -
                        to rnlt)gate the concerns of the present, using the past history as guidelines for                                       1979.
                        mitigation.
                                                                                                                                           Gunn, A. and F.L. Miller. 1986. Traditional Behavior and Fedellty to Caribou Calving
                                                                                                                                                 Grounds by Barren Ground Caribou In Rangifer, Special Issue fl, 1986.

                                                             -20-
                                                                                                                                                                                     -21-

    Jingfors, K. T., 1980. Habitat Relationships and Activity Patterns of a Reintroduced
    	Muskox Poplulation. M.S. Thesis, University of Alaska, Fairbanks. 116 pgs.

    Keith, L. B., 1981. Population Dynamics of Wolves in Wolves in Canada and Alaska,
    	edited by L. N. Carbyn, Canadian Wildlife Service Report #45.

    Nurea Reclamation, 1986. Final Wellsite Cleanup on National Petroleum Reserve -
    	Alaska, Volumes I-III, under U.S. Geological Survey Contract #14-08-001-21787.

    Prudhoe Bay Waterflood Environmental Monitoring Program, 1981-1984 by various
    	authors for U.S. Army Corps of Enginners.

    Robus, M. A., 1981. Muskox Habitat Patterns in Northeastern Alaska. M. S. Thesis,
    	University of Alaska, Fairbanks. 116 pgs.

    Shank, C. C., 1979. Human-related Behavioral Disturbance to Northern Large
    	Mammals; A Bibliography and Review. Foothills Pipe Lines (Shouth Yukon) Ltd.,
    	Calgary. 246 pgs.

    Shideler, R. T. 1986. Impacts of Human Developments and Land Use or Caribous. A
    	Literature Review. Volume II. Impacts of oil and gas development on the
    	Central Arctic Herd, Technical Report NO. 86-3, ADF&G.

    Skoog, R. O., 1968. Ecology of the Caribou (Rangifer tarandus grant) in Alaska.
    	Ph.D. Dissertation University of California, Berkeley. 669 pgs.

    U.S. Fish and Wildlife Service, 1982. initial Report, Baseline Study of the Fish,
    Wildlife, and their Habitats, Section 1002(c) of the Alaska National Interest
    Lands Conservation Act: Anchorage, U.S. Fish and Wildlife Service, Region 7.
    307 pgs.

    Walker, D. A., Walter, M. A., Lederer, N. D., and Webber, P. J., 1984. The Use of
    Geobotanical Maps and Automated Mapping Techniques to Study the Historical
    Changes in the Prudhoe Bay oilfield, Alaska; Boulder, University of Colorado,
    Institute of Arctic and Alpine Research. 63 pgs.

    White, R.G., Thomson, B.R., Skoland, T., Person, S.J., Russell, D.E., Holleman, D.F.,
    and Lcuick, J.R. 1975. Ecology of Caribou at Prudhoe Bay, Alaska. p. 151-201, In
    Ecological Investigations of the Tundra Blome in the Prudhoe Bay Region,
    Alaska J. Brown, editor, Biological papers of the University of Alaska,
    Fairbanks. Special Report 2, 215 p.

                                         -22-

               DO YOU WANT TO MAKE PUBLIC COMMENTS?

               If you would like to speak at the hearing todayq please fill in the blanks
               below and turn It in to one of the Fish and Wildlife Staff members present.
               You need not complete this sheet to submit written comments. Thank you.

               Please print

               N-

               Matting Address

                                                                                                                                    TESTIMONY REGARDING

               Check appropriate box belows
                 [3 1 an here to offer my own views.                                                                     ARCTIC NATIONAL WILDLIFE REFUGE, ALASKA
                               ---or-                                                                                       COASTAL PLAIN RESOURCE ASSESSMENT
                 C3 I an speaking for
                                       (please enter name of organization you represent)

                                                                                                                                             BY

                                                                                                                                     DEBBIE  S. MILLER
                                                                                                                                        1446 Hans Way
                                                                                                                                  Fairbanics, Alaska 99707

                                                                                                                                      January 5, 1987

                                                                                                    submitting written comments.         My voice is also the voice of
                My name is Debbie Miller and I reside at 1446 Hans Way in                           those whose efforts and dedication helped establish      I the Arctic
          Fairbanks,    Alaska.    I find it extremely inconvenient traveling                       National Wildlife Range for its unique wilderness,       wildlife, and
          to Anchorage with a six month Old in order to testify at a public
                                                                                                    recreational values:     individuals like Olaus Murie,        Clarence
          hearing.      Numerous  individuals and organizations,        including                   Rhode,   George Collins,  and Lowell Sumner.    Let's hope that their
          Governor Cowper,     requested   that publi  .chearings be held in                        work was not in vain.
          Fairbanks and Arctic Village. Our.requests have obviously fallen
                                                                                                          For  the  past    11 years I have been fortunate    to  spend    a
          on deai ears.                                                                             substantial amount of time living, working, and recreating within
                I am attending this hearing because I believe that     the  issue                   the Arctic National Wildlife Refuge.        I taugh,t school and was a
          of opening the Arctic Refuge coastal plain to oil and gas                                 resident   in Arctic Villagefor       thr.9 a years.    I have taken
          development is     the-most important conservation issue in my                            numerous backpacking, kayaking, and climbing trips      &n the  refuge.
          lifetime.    I cannot, in-good conscience, sit at my desk and
                                                                                                    I've been lucky enough to,witness the aggregation       of the  18o,ooo
          merely    write  a letter to the tee      .retary, . criticizing .'his                    Porcupine   caribou herd.     In   1982  1 assisted     former   refuge
          recommendation   which would open the coastal plain to full scale                         MA
      X                                                                          I                    nager   Ave Thayer on. a wl iderness assessment       study of the
      Q   oil and gas leasing.      I must publicly denounc  e the Secretary's
                                                                                                    coastal plain.    in 1983 1 assisted the Alaska Department of Fish
          illogical recommendation    which is not supported by the contents
                                                                                                    and Game with awaarial census of the Porcupine          caribou herd.
          of the coastal plain resource assessment.      I question whether the                     Currently I am  member of the consultation planning     committee    for
          Secretary     read    the   @assessment   prior    to   writing     his                   developing the  Arctic Refuge comprehensive management plan.
          recommendation.                                                                                The most tragic dimension of the resource asssessment Is the
                Although I am   testifying as an individual   I represent many                      Se cretary's recommendation.       I am extremely disappointed      that
          voices   which will not be heard today.      Ispeak on behalf of my                       the    Secretary   has   apparently   overlooked     the    significant
          daughter whose generation would like to see some of our Arctic                            wilderness, wildlife,     and recreational values of the coastal
          landscape preserved as wilderness for.their time.         I spea.k for                    plain,   as well as economic and geologic data contained in the
          the elder in Arctic Village who detests the idea of-opening the                           report.
          calving grounds of the Porcupine Caribou Herd to oil and            ga.9                       The Secretary misleads the public in      the opening paragraph
          development, but will not be given the opportunity to be heard in                         of his recommendation where he states that     the "coastal plain has
          their   own village.    I remind you that Arctic Village residents                        been predicted    to contain as much as 29 billion barrels of oil
          speak   English as a  second language and few elders are    capable of

          and 64 trillion cubic feet of gas, making it the most Outstanding
                                                                                                                         Furthermore, the Reagan administration has flooded the Oil
          oil and gas frontier area in North America-.."                 The Secretary                            and    gas leasing market.        Over the years lease sales have been
          further states that the mean recoverable value of 3.2 billion                                           cancelled due to lank of interest by the oil' industry.                        The
          barrels could account for almost 4 percent of the daily U.S. oil
                                                                                                                  average bid per acre            has dropped by more than half.                 The
          demand in the year 2005.          However,     the Secretary fails to.note                              department's      leasing program amounts       to a give away lease plan
          that the mean recoverable value is based on.the assumption that                                         for the oil industry.         Why not hold on to th      .ass tract .s .until the
          there is only a 19% nha     nag  of finding armajor oil reserve within
                                                                                                                  price of oil increases?
          the 1002 area.                                                                                                 The   Secretary's recommendation points Out that the nation
               Even if      there is 3.2 billion barrels of oil beneath the
                                                                                                                  might benefit from a more favorable balance of trade by saving
        .coastal plain      it is hardly worth-extracting such quanities                for                       $8.1 billion in the year 2005 on the cost of imported oil.                   This%,
          the equivalent    of six months supply oe oil for tht nation.               This                        may    sou.nd like a huge savings but what does this figure really
          is a drop in the bucket given our long term              energy    needs -     By                       mna*n  in relative terms.       If our trade deficit was $19 billion for
          comparison,     a  3.2 billion barrel field is merely one third the                                            Mont
                                                                                                                  the        h of December what will $8.1 billionr annual Savings
       -usize of recoverable oil reserves at Prudhoe Bay.                 On the world,                           represent 'in the next century?            I recently heard one        a-2onomist
          scale   such a field   .would offer little competition to           the    giant                        note    that our     trade    deficit could soar        to    $500-600    billion
          oil fields in the Middle East. Saudia Arabia and Kuwait boast of
                                                                                                                  dollars annually in thii-1990's. Balance of trade arguments do not
          fields   containing more than 60 billion barrels of oil.                   Let's
                                                                                                                  justify opening up our only undisturbed Arctic region in the
          face it,    on the world scale,       oil production in the U.S.          rivals                        United States.
          wheat production in the Soviet Union.              'Why not stockpile oheap                                    The report fails         to adequately assess       the environmental
          foreign Ioil as a strategic defense policy for the United States?                                       consequences      of oil and    gas leasing on the coastal         plain.      The
                It makes absoultely no sense to destroy the Only virgin
                                                                                                                  report is based on the underlying premise that that the oil
          Arctic coastal plain on          the North Slope for a few million or
                                                                                                                  industry has a proven good track record with respect to 10 years
          billion barrels of Oil.          Such action is completely contrary to
                                                                                                                  of oil development in the Prudhoe Bay area.                That's a bit like
          the purpose for establishment of the refuga.              In the late 1940's                            stating    that U'.S.    companies have a clean track record south              of
          several individuals recognized the northeastern corner of                                               the U.S. Mexican border. V          Im not implying that the oil industry
          Alaska   as offering a unique diversity of Arctic and                sub-Arctic                         has created a New River scenario on the North Slope,                ho .waver the
          species along with a wilderness quality that is unsurpassed.
                                                                                                                  industry has not been monitored on any regular basis by the State
          These wildlife and wilderness values still hold true today.

          of Alaska until     1982.    The state is Just ROW implementing                              States.
          hazardous waste and drilling mud regulations.        This coming fall                             I looked below me and watched one of Our           country's   most
          the Department of Environmental Conservation will open an air                                northerly bands of Dail Sheep grazing along a velvet green ridge
          quality monitoring station at Prudhoe Bay for the first time.                                below the glaciers.      And looking to the nor   th was perhaps the
               In reality,   there have been tons of thousands of 0    il spills                       most impressive view.        For it was there that I could see the
          reported in the Prudhoe I .Bay oil fields,   there have been serious                         distant Beaufort Sea and the horizon of white ice stretching
          problems with disposed drilling mud affecting aquatic life on
                                                                                                       forever.to the North Polo and beyond.       And between the Beau    .fort
          adjacene tundra ponds,    and there has been no.logitimate plan for                          Sea and the mountains lay the expansive,        gently rolling coastal
          hazardous waste disposal in recent years.                                                    plain, sweeping towards the coastal lagoons.        In one far reaching
               The Department of Environmental Conservation reports that                               glance    I was witnessing the most spectacular and                remote
          the Oil industry disposed of approximately 40,000 gallons of bona                            wilderness    setting -in the United States.        I realized at that
          fide hazardous waste material     to a local salvage operator on the                         moment in time that the Arctic refuge had         given m  .a, and our
          North Slope who had no experience dealing with hazardous waste.                              country,    the ultimate gift of true wilderness.
       -.UThe State of Alaska forced.the oil industry to enter into a                                       The Department of interior has failed to conduct an adequate
       86inding. contract to dispose of the hazardous waste properly.                                  wilderness review as- mandated under 1004 and 1317 of ANILC&.
          Otherwise,   the industry would have been faced with a Suporfund                             How ^.an the Secretary recommend oil and
                                                                                                                                                        gas leasing of the
          olean-up.                                                                                    coastal plain 29t_ while barely touching upon the wilderness
               Potential airand wato     .r pollution problems associated with                         values in the      1002 report?    Furthermore,     the Arctic Refuge
          massive oil development were not adequately addressed in the 1002                            201MSUltatiOn planning Committee has been instructed to not
          report.                                                                                      consider,   addressing    the   1002 area      when   developing.     the
                Several years ago I was fortunate    enough to scale one of the                        comprehensive management-.plan. since I     t will be     addressed by
          highest glaciated peaks in the Brook    s Range,   Mt. Michelson. Mt.                        Congress.    This is usually the forum where wilderness review
          Michelson is located in the heart of the refuge between the                                  mandates are met under Section 1317. If wilderness review is not
          Hulshula and Okpilak Rivers.        From the top Of this mountain I
                                                                                                       Included   in the comprehensive management plan,      and Only touched
          felt honored and so humbled to be a part of so vast a wilderne
                                                                                                       UPOD in the 1002 report, it has simply fallen through                 the
          vista.    To the south, west and east stretched an endless a..          :sf                  cracks.
          snow covered     W%twl
                                     I was standing on one of the highest                                   I recommand.that   the Secretary conduct    a complete wilderness
          mountains    of  our most  northerly mountain range in the United

         review of the 1002 area as mandated under Sections 1317 and 1004.

         The 1002 area is do facto wilderness and should be designated as

         wilderness to protect the area from man's industrial Intrusion.

              Finally I will any that I agree with pg. 46 of the report

         which states that:

              "The 1002 area is the most biologically productive part of

         the Arctic    Refuge for wildlife and is the center of wildlife
         activit; on   the refuge.   Caribou migrating to and from the 1002

         area   and    the post-calving caribou aggregation        offer     an

         unparalleled  spectacle."

              If we open the 1002 area to oil and gas leasing we will be

         cutting off the most vital arm of the refuge.       It is true that

         the greatest concentrations and diversity of Arctic wildlife
     M
         occur on the coastal plain of the refuge.     A pipeline bi-secting

         the calving, foraging, and insect relief grounds of the Porcupine

         Caribou Hard, along with a road complex and drilling pads, will

         adversely alter the habitat and create major negative impacts on

         the herd.     The wilderness character of the refuge would be

         destroyed. These losses cannot be compensated. There is only one

         Arctic refuge in the United States.

              I   encourage the Secretary to read the resource assessment

         and   to revise his recommendation in favor of             wilderness

         preservation. Thomas Fuller once said that "A blind man will not

         thank you for a looking glass." Take a closer look at the 1002

         area Mr. Secretary, and I hope you are not blind.

                                                                                                                            USFWS
                                            Mitchell Management                                                             Page 2
                                             202 Deerfield Dr.
                                           Anchorage, AK, 99515
                                                                                                                            proper documentation one might conclude that the wildlife use
                                              January 5. 1987                   Hand Delivered at                           areas were artificially enlarged so as to increase the projected
                                                                                Public Hearing                              loss of habitat.
                     U.S. Fish  Wildlife Service                                Anchorage, AK                               4.    1 believe that a major shortcoming of this draft report is
                     Attn: Division of Refuge Management                        January 5, 1987                             the failure to provide a basis for equally comparing the
                     2343 Main Interior Bldg.                                                                               projected conditions of the study area         under each of the
                     18 & C Sts. N.W                                                                                        alternatives.
                     Washington, D.C:, 20240
                                                                                                                            For example, Alternative E - Wilderness Designation, is not
                     Reference: Public Comment on Draft ANWR Coastal Plain Resource                                         adequately addressed.     The environmental consequences section
                                Assessment and Recommendation to Congress                                                   consists of only some 400 words.       Discussion is limited to a
                     Gentlemen:                                                                                             static situation responding only to the forces of nature.          In
                                                                                                                            order to make an informed decision among the alternatives, the
                                                                                                                            condition in the study area under a wilderness designation must
                     Please consider  the following during your preparation of the                                          be projected into the future in the some way as should be used
                     Fij.al ANWR Report and Recommendatiob to Congress:                                                     for the other alternatives.    Th-effects of presumably full and-
                                                                                                                            undisturbed 'subsistence hunting pressure on the various wildlife
                     1.  1 support the Secretary's recommendation that the Arctic                                           populations must be addressed.    As an example, one must address
                     National Wildlife Refuge be made available for oil and gas                                             the likelihood of and effect of repeated subsistence takes of 25
                     leasing.  I believe that exploration and production can be                                             polar bear per year as was the reported case in Kaktovik during
                     carried out without significant environmental degradation.                                             the 1980-1981 harvest.
                     2. There are numerous intersectional inconsistencies within the                                        This section should address the changes that can be expected to
                     report as It now Rtands, perhaps reflecting the various opinions                                       occur   in the cultural 'socioeconomic environment       over    the
                     and bias of individual writers.  These should be edited out. An                                        foreseeable future'     Th'se would include a continuation of the
                     example can be found in the discussions of the effect of                                                                         a
                                                                                                                            trend towards a cash based society at Kaktovik, projected
                     development on archaeological resources.   Table VI-8, page 143,                                       population trends and the effect of changes in population on the
                     indicates that all artifacts at development sites will be lost.                                        use of the area's subsistence resources, projected effects of
                     The unnumbered summary table on pages 148 and 149, however,                                            changes in the efficiency by which the local residence will carry
                     indicates negligible effects on these resources, perhaps based on                                      out subsistence activities and the like.
                     pre-construction investigations which would be required in accord
                     with proposed Stipulation 29.                                                                          5.   The statistical treatment in Chapter III is more      confusing
                                                                                                                            than it need be, as evidenced by the various claims and
                     3. Key items of documentation are missing.       One example is                                        counterclaims    about the areas potential and         intentionally
                     ocumentation of why five out of fourteen years of concentrated                                         misleading the   public.   This goes deeper than a typographical
                     use defines a core calving area compared to perhaps seven out of                                       error on pages   5 and 6 where "more than" was twice dropped from
                     fourteen years or two out of fourteen years. Review of the data                                        "...[more than) 0.6 billion barrels of recoverable        ...  (more
                     shows natural breaks at three and seven years, not five.                                               than] 9.2 billion barrels ... "
                     There is also a lack of documentation for many of the wildlife                                         The primary confusion arises out of the following sentence on
                     use areas presented on Plates 1 through 3 which were used in the                                       pages 49-50 :
                     overlay method to assess direct habitat loss or alteration.    One                                          "It is estimated. if there is economically recoverable      oil
                     example of this deficiency is Plate I E where approximately 150
                     square miles of land at the mouths of the Staines and Canning                                          present (the chance of which is estimated to be about              20
                     Rivers has been designated "Confirmed coastal denning area" based                                      percent), that there is a-95- percent chance of more than 0.6    BBD
                     on one observed den since 1951.  Approximately 250 square, miles                                       and a 5-percent chance of more than 9.2 BBO recoverable in       the
                     at the mouth of Marsh and Carter Creeks are similarly designated                                       1002 area as a whole."
                     based on two dens in the last 15 years.  Considering such large
                     areas when making loss of habitat estimates seems to be                                                Based on this sentence, it would seem like you could multiply    the
                     unrealistic when it is proposed to limit activity within only one                                      20-percent "economically" by the 5-percent "more than 9.2        BBO
                     half mile of a confirmed den (Proposed Stipulation 19).    Lacking

                   USFWS                                                                                                      USFUIS
                   Page 3                                                                                                     Page 4

                   recoverable" and arrive at a I-percent "more than 9.2 BBO                                                  Thank you for your consideration of these review comments.         In
                   economic-ally recoverable".   If this 1B the case, just say so.                                            closing, I would like to very briefly address what I believe to
                                                                                                                              be two misstatements of fact which have often been made in the
                   Alternately,    Table   111-4,    page 72.    indicates that      the                                      press and other public forums.
                   "economically" factor is already contained in the 95-percent,     ie:
                                                                                                                              Firstly, the 1002 area is not the last chance to preserve a
                        95-percent probability of greater than 0.59 BBO Conditional.                                          section of the arctic coast as wilderness.      In excess of some
                        economically recoverable oil.                                                                         400,000 acres east of the Aichilik River have already been
                                                                                                                              designated as wilderness.
                   Regardless of whether it is one or the other. or somewhere in
                   between, the language needs improvement for the sake of clarity.                                           Secondly, it has been said that, given only a 20-percent chance
                                                                                                                              'of finding economically recoverable quantities of oil in the
                                                                                                                              area, it is not worth the chance of environmental disruption
                   6.   At times the report slips facilely back and forth between                                             caused   by   construction of      roads,   pipelines,     processing
                   addressing the entire Refuge and the limited 1002 study area.                                              facilities, docks, and similar facilities.       Should the area be
                   One such example is the Recreation section on page 45 where in                                             opened for leasing however, and no economically recoverable
                   the course of three paragraphs we change from discussing one Jo                                            reserves are found. the environmental consequences will be
                   the other some eight times.     This tends to be confusing to the                                          limited   to   those associated with Alternate        C    - Further
                   reader and should be minimized. It is noted in passing that this                                           Exploration, which are all. with one exception, identified as
                   section falls within the "undocumented" category discussed in the                                          minor or negligible in the Summary of Effects table on pages
                   preceding item number 3.                                                                                   148-149. Should no economically recoverable reserves be located,
                                                                                                                              development will be limited, for the most part, to the low impact
                   7.   Use of emotionally   charged language should be avoided like                                          winter construction and drilling of wildcat wells.
                   the plague. The Wilderness and Esthetics section of the Existing
                   Environment Chapter is a particularly bad offender. The sentence                                           Sincerely.
                   on page 46 which reads, "Caribou migrating to and from the 1002
                   area   and the post calving caribou aggregation          offer     an
                   unparalleled spedtacle" is an example of one such sentence which
                   has been publicized nationwide by an Audubon Action Alert.
                   I believe that it could be successfully argued that the migration                                          Dennis W. Mitchell
                   and aggregation of Monarch butterflies is of parallel spectacle
                   as is that of wholes in the Baja California area.

                   B.   I concur with the above cited Audubon Action Alert in that I
                   believe that the status and projected results of all negotiations
                   regarding land trades effecting the 1002 area must be discussed
                   in this report.      The economic benefits or losses which may be
                   realized by various governmental organizations and            private
                   citizens based on exploration and/or production of this area will
                   be significantly effected by such trades.       I fail to see how
                   inclusion of this information can be avoided in as much as it has
                   been   reported that such trades may be          conditional     upon
                   Congressional action based, in part, on the subject report.

                                                                                                                                                                                                                     2

                                                                                                                                     conservation system unit that protects, in an undisturbed con            dition,
                                                                                                                                     a complete spectrum of the various arctic ecosytems In North
                                                          Nina Mollett                                                               America...The coastal plain in its present state has outstanding
                                                          1900 Gilmore Trail                                                         wilderness values: scenic vistas, varied wildlife, excellent
                                                          Fairbanks, Alaska 99712                                                    opportunities for solitude, recreational challenges, and scientific and
                                                                                                                                     historic values ... The 1002 area is the most biologically productive
                                                   January 9, 1987                                                                   part of the Arctic Refuge for wildlife and is the center of wildlife
                                                                                                                                     activity on the refuge."
                  U.S. Fish and Wildlife Service
                  Div. of Refuge Management Resources                                                                                The executive summary, page 1, states that in addition to specific
                  2343 Main Interior Building                                                                                        adverse environmental consequences of developing the 1002 area, the
                  18th and C Streets, N.W.                                                                                           presence of infrastructure supporting oil and gas development would
                  Washington, D.C. 20240                                                                                             eliminate" the wilderness character of the area.

                                                                                                                                     The details of the enormous environmental problems wlth developing
                  To Whom it May Concern:                                                                                            this area, problems which include a critical lack of fresh water and
                                                                                                                                     the necessity for scarring up the land while digging out enough
                  This letter is intended as testimony on the draft Department of                                                    gravel to build on permafrost, will I am sure be dealt with In other
                  Interior Arctic National Wildlife RefusLe- Alaska. Coastal Plai                                                    comments. What I wish to emphasize instead is the irrationality of
                  Resource AssessmenV Report and recommendallon to the Congress                                                      the conclusion. Buried deep within this report Is the information
                  of the United States and legislative environmental impact statement.                                               that there is only a 19 percent chance of an economically viable
                  I have read this report and, as a fifteen-year resident with a long-                                               reserve being found In the coastal refuge. In reaching their .
                  term active interest in the issues involving the future of this state, I                                           conclusions the authors of the report ought to, but don't, attempt to
                  differ sharply with its recommendation to pursue leasing of the                                                    balance this chance against the indisputable fact of a wilderness area
                  entire coastal plain.                                                                                              unique in the world; there is no other coastal plain preserving such
                                                                                                                                     ecological variety I- America, nor in Siberia, nor in Scandinavia.
                  the recommendation to lease does not follow in any,kind of logical                                                 And beyond the unexamined assumption that unrecoverable
                  way from the contents of the assessment Itself: on the contrary,                                                   wilderness Is worth trading for a chance of recoverable oil, the
                  such a recommendation can only be made by ignoring the                                                             conclusion of this report relies on a further unstated assumption:
                  compelling evidence contained within the report, and reflects instead                                              that we are the last generation; that extracting oil which will serve
                  the predictable ideological biases of an administration that, while                                                us for a few decades-30-90 years, according to the report-is worth
                  giving lip service to "balance", has consistently favored development                                              laying waste to wilderness forever. The coastal plain is stated to he
                  of non-renewable resources over conservation of renewable                                                          "the most outstanding oil and gas frontier remaining In the United
                  resources, and short-term political interests over long-term public                                                States.' But what will happen to our import-export balance, our
                  values. The fact that Alternative A, leasing of the entire plain, is                                               economy, our national security, when the oil, assuming that it is
                  recommended, rather than Alternative B, which would exclude the                                                    found to be worthwhile extracting, runs out? Our government
                  critical Porcupine Caribou Herd calving areas, only serves to confirm                                              ought to operate under the assumption that there will be a future,
                  the impression that the conclusion of the report was predetermined                                                 which must be taken into account; if indeed this possibility of oil has
                  by ideology and was made independently of the objective assessment                                                 such value that it is worth destroying our wilderness heritage over,
                  contained within the same document. The conclusion is also in                                                      there ought to be a discussion of whether It might not be wiser to
                  conflict with that of the 1973 executive study, which recommended                                                  preserve the opportunity for our descendants, who will likely be
                  wilderness de 'signation for the entire wildlife range, with certain                                               hurting for oil more than we are now (the world is, after all,
                  exceptions, and the 1982 Thayer review of the 1002 area, which also                                                currently experiencing an oil glut) and who may have greater need
                  recommended wilderness designation, except for the abandoned DEW                                                   for It, and more compelling nationaf security requirements. What
                  line stations.                                                                                                     gives our generation, like pigs at the sty, the right to lap up all
                                                                                                                                     available resources?
                  I favor wilderness designation for the coastal plain. The reasons for
                  such designation are contained eloquently within the report itself,                                                I don't expect that my letter will have any impact on the outcome
                  which on pages 45-46 states, "The Arctic Refuge is the only                                                        of the final report of an Interior Department which held public

                                                                                         3                                                                                                         4

               hearings on this matter not through any interest in the democratic                                          idea that compensation could be made-but to whom?-for loss of
               process but because it was forced to by a lawsuit. However,                                                 wilderness is of course an Interior Department fantasy, and the
               fortunately this decision is in the hands of Congress and not the                                           fact that it is couched in dry jargon makes it no less a fantasy.)
               executive branch: it would have been politically smarter, I should
               think, for the department to mask its ideological extremism by                                           3) As mentioned earlier, the final report ought, in the sections
               recommending the somewhat less radical alternative of leasing the                                           delineating.the potential benefits to be accrued from developing
               area with the EXCEPTION of its most sensitive areas, But it we wish                                         the oil reserves, to include a serious longer-term assessment. I
               to behave responsibly as, so to speak, executors of this estate, the                                        believe that an objective examination of the current situation and
               entire coastal plain ought to be designated wilderness. And this is a                                       the draft assessment would have concluded that leasing the 1002
               moderate suggestion, since the rest of the North Slope has already                                          area is not worth the price of wilderness destruction, But I can
               been thrown onto the development side of an unbalanced scale.                                               imagine a time of worldwide oil scarcity and energy needs so
                                                                                                                           pressing that this conclusion would have to be reassessed. If the
               Although I see-no chance of the conclusion of this report being                                             oil is in fact worth recovering economically, then the relative
               changed no matter how much carefully reasoned testimony is                                                  merits of extracting It Immediately, or preserving It for a future
               received, I would like to make the following more peripheral                                                time of perhaps greater need, should be carefully weighed. Such
               suggestions for the final report:                                                                           an assessment would be difficult; there are many factors which
                                                                                                                           wIll not lend themselves easily to numerical manipulation; but to
               1) Page 72 contains the information that there is a 19 percent                                              ignore the future entirely is to part with any claim to wisdom in
                  chance of economically recoverable oil, based on the "most likely                                        your deliberations.
                  case" assumption of $33 per gallon. There is also a 26 percent
                  probability figure given, under the "optimistic case' assumption of                                                                              Sincerely yours,
                  a $40 per barrel price. No basis Is given for adopting these
                  optimistic assumptions, and there is NO figure for what we might
                  call the "pessimistic, realistic case" under which the price would
                  remain around $15-$20 per barrel. Since It Is the existence or or                                                                                Nina Mollett
      C>          absence of economically recoverable oil that must be the basis for
                  a decision, the 19 percent figure, along with a more realistic
                  calculation based on current oil prices, ought to be located                                         cc:   Senator Bennett Johnston
                  candidly in the executive summary after the sentence, "This                                                Governor Steve Cowper
                  resulted in an estimated 95-percent chance of 0.6 billion barrels
                  of oil recoverable, a 5-percent chance of 9.2 billion barrels of oil
                  recoverable, and an average conditional economically recoverable
                  resource estimate of 3.2 billion barrels of oil," which is otherwise
                  misleading to anyone lacking an advanced degree in obfuscation.
               2) Please explain what is meant by Bill Horn's suggestion that
                  unavoidable habitat losses suffered during leasing be "fully
                  compensated"-or else drop the concept, which since it apparently
                  has no real meaning is misleading, lulling. Highway builders can
                  compensate private owners for loss of their property, but who is
                  to be compensated for the loss of caribou calving grounds? The
                  caribou? How will the Kaktovik Eskimoes be compensated for the
                  loss of subsistence opportunities and degradation of their quality
                  of life? With money?? How will our descendants be compensated
                  for the loss of the opportunity for solitude? In how many trillions
                  of dollars? (Please excuse the sarcasm, but I am at a loss how
                  otherwise torespond to the problem of official jargon; answering
                  in the same style of jargon would imply acceptance of the terms
                  of a debate which is In fact based on irrational assumptions. The

                                                      Pamela S. Nelson                                                               $2.000,000 per year by the most conservative estimates. These figures over the newt 20-30
                                                       P.O. Box 1127                                                                 years, the life of an oilfteld, are significant, and should,have been considered in the report.
                                                  Kotzobue, Alaska 99752                                                                S. The @&stern portion of the 1002 area is critical to the long-term ecology of the Bariks
                                                      Jarmiary 6, 1987                                                               Island lesser snow goose population. The Report to CA:ngreas proposes a stipulation
                                                                                                                                     restricting aircraft altitude to at least 2000 it (pag* 147) to minimize disturbance to the
             U.S. Fish and Wildlife Service                                                                                          staging snow goose. The literature documents frequent cases of snow goose disturbance from
             Attn: Division of Refuge Management- ANWR 1002 Report                                                                   ground personnelo vehicltst and low-flying and high-flying aircraft &like. In facto habituation
             2343 Main Interior Building                                                                                             to these disturbance* has not been documented for snow goose, *van in the heavily developed
             18th and C Streets M.W.                                                                                                 wintering areas of California. Weather conditions an the coastal plain during the September
             Washingtono D.C. 20240                                                                                                  staging period are usually too low to permit pilots to safely fly anything other than low
                                                                                                                                     HOO-500 it) altitudes. Since altitude restrictions are rot effective. and undisturbed intense
             Mar Sir/Madam:                                                                                                          feeding prior to migration is energetically assentialt the only way to avoid significant adverse
                                                                                                                                     impacts to the snow goose population using the ANWF1 staging area is to close it to all
                I would like to comment against oil and gas development on the coastal plain of the Arctic                           activities during the month and a half of staging. The proposed stipulations for surface and
             National Wildlife Refuge. The draft report to Congress and the numerous 1002 Baseline Study                             strial closures of the same area during muskox and caribou calving combined with closures for
             Update reports document the tremendous wildlife values of the area. Specifically, I recommend                           snow goose dictate that the entire eastern third of the 1002 area would be closed much of the
             the Wilderness (13) or the No Action (D) alternatives. I was a volunteer wildlife biological                            time between April 15 " September 30. The Report to Congress does not address whether
             technician an the 1002 studies in 1963 and have since spent considerable time living in the                             such closures in a maJor ailfteld are practical and enforceable over the long term. Similar
             arctic and working with migratory birds# caribou# and rural subsistence users.                                          efforts to maintain temporal and spatial closures in the Prudhoe Bay area have not been
                A cautious and conservative approach@ rather than the reckless and short-sighted Full                                successful over the long term. The oil companies found such closures too restrictive and have
             Leasing Alternative currently proposed in the draft report. should be taken in the management                           gradually tried to have them relaxed# to the detriment of the wildlife. Regulatory agencies,
             of the ANWR Coastal Plain because of the following reasons:                                                             frequently have been unable to maintain such closures beyond the initial few years after
                1. This area is the historic and recent center of calving activity for the Porcupine Caribou                         agreement, due to political pressures from industry.
             Hard (PCW. Based on data prestnitd in the Report to Congress, the 1002 Update Reports,                                     A recent poll conducted for the Alaska Oil and Gas Association concluded that about 70% of
             combined with my field experience an the ANWR Coastal Plain, it is difficult to understand how                          the Alaskans contacted were in favor of 4urture development of the ANWR coastal Plain.
             an extensive oilfield can be placed In the midst of a caribou calving ground without MiAt                               Conversely, a write-in opinion forum published in two January 1987 issues of the Anchorage
             significant adverse impacts to the hard. The development scenarios show the greatest                                    Daily News showed only 3e% of the responses favored future oil development on AHWR. More
             concentration of well pads and fooder pipalines in Resource Blocks C and Do and part 04 Block B.                        than half of the responses in The News were in favor of the No-Action or Wilderness
             precisely in the most frequently used %oral caribou calving area.                                                       alternatives.
                When I was working in the "core" calving area an the Jago River near VABM-Bittyo oven the                               Because the high caribou# migratory birdo arwi regional- international subsistence values of
             more presence of biologists an foat or small survey aircraft caused dispersal of caribou                                the ANWR Coastal Plain cannot be adequately protected by Alternatives A,B, or C, the most
             cow/calf groups. With the intensive ground activity of cilfiold workers and equipment combined                          prudent choices are No-Action (Aliarnalive D) or Wilderness (Alternative 9). The long-term
             with frequent helicopter and cargo aircraft overflightso displacement of the cow/calf caribou                           value of theme wildlife resources should not be sacrif  Iiced in favor of the short-term economic
             groups will occur. The Report to Congress states that about a third of the concentrated calving                         gains afforded by oil development.
             area would be affected by the Full and Limited Leasing Alternatives (page 107). It is known
             that development in the Prudhoe Bay area has displaced cow/calf groups from the Central                                                                                           rely,
             Arctic Hard (CAW, arW that concurrent to such development. CAH use of the Canning River
             Delta calving ground within the 1002 area has increased (page 106). In effect, development at
             the Kuparuk and Prudhoe ollfields has displaced part of the hard's calving to the 1002 area.
             The 1002 report fails to address how such likely displacement of PCH caribou from its care area                                                                           Pamela S. Nelson
             will be mitigated in view of the fact that calving displacement has already occurred# and that
             similar ailfiled development is occurring or plarrwd to occur west of the refuge (Pt. Thompson)
             and east of the refuge (Yukon North Mope). There will be fewer and fewer places for calving                             cc: Senator J. Bennett Johnston
             grounds to be displaced to. The Impacts of the actions on ANWR cannot be looked at in                                      Senator Ted Stevens
             isolation, but must be weinhad in terms of cumulative and chronic impacts an the ranas of the                              Rep. Don Young
             Porcupine Caribou Hard.                                                                                                    Rep. Moris Udall
                2. An economic analysis examining a decline in the caribou population and subsequent loss                               Governor Steve Cowper
             of its value to subsistence and loss of sport hunting and recreation revenues was not included
             *in the report. Thore has been considerable publicity lately that am sockoye salmon in Bristol
             Bay was worth more than a barrel of oil last summer. Similarly, one caribou taken for
             subsistence is worth over $300 in meat value alonep rot to mention the replacement costs to
             produce and transport an equivalent amount of beef to rural areas. Value added to the state's
             economy for each sport- harvested caribou could easily average $1000. Therefore, total value
             of about 2000-5000 caribou taken for subsistence, and another 500 taken for sport# exceeds

                                                                                                   areas with in the 1002 area resulting in a large part of the
                                                                                                   projected populaton decline or distribution change for 20-40
            P.O. Box 270                                                                           percent of the Porcupine Caribou Herd" (ibid. p-132). In
            Kotzebue, Alaska 99752                                                                 addition the proposed pipeline bisects the calving ground of
                                                                                                   the Porcupine Caribou Herd and could well block their
            February 4, 1987                                                                       movements to critical insect relief habitat along the coast.
                                                                                                   Much has been made of the successful proliferation of the
                                                                                                   Central Arctic Caribou Herd in the face of the Prudhoe Bay
                                                                                                   development. 'Analogies comparing the effects of current oil
                                                                                                   development on the Porcupine Caribou Herd must be drawn with
            U.S. Fish and wildlife Service                                                         enlition. Movements, density and traditions of the Porcupine
            Attn: Division of Refuge Management Resources                                          Caribou Herd differ from those of the Central Arctic Herd.*
            2343 Main Interior Building                                                            (ibid. 0.106). One very basic difference between the herds is
            18th and C Streets, N.W.                                                               that the Central Arctic Herd population Is estJmated at 10,000
            Washington, D.C. 20240                                                                 animals versus a population of 180,00.0 animals in the
                                                                                                   Porcupine Caribou Herd. Is it wise to extrapolate the pattern
            I would like to state my opposition to oil development on the                          of the Central Arctic Herd to a Herd that Is 18 times the
            Coastal Plain of the Arctic National Wildlife Refuge. I                                size?
            support Alternative E, Wilderness In the Draft Arctic National
            Wildlife Refuge, Alaska, Coastal Plain Resource Assessment.                            Development would have a major impact on water supplies in the
                                                                                                   Refuge. "As much as 15 million gallons of water may be needed
            The arguement used to justify the opening the Arctic National                          to drill an exploratory well. Taking this amount of water
            Wildlife Refuge to oil and gas development is weak at best.                            from the deficient 1002 area could have a major adverse
            *12 and gas supplies are needed for our country's economy and                          effect.Oilbid. p.99). "The large quantities of water required
            defense but our Country's National Wildlife Refuges should not                         for development drilling on the 1002 area Are not
                                                                                                   AvailAhle."(Ibid. p.101). Why pursue a course of development
            be sacrificed to produce oil. Oil is not a renewable
            resource, we will eventually need to adopt alternative energy                          when studies show the limited supplies of water are Inadequate.
            sources. The question is, should we destroy our country's                              to meet the oil development needs?
            limited resources and endanger the wildlife populations before                                         owing oil development on ANWRIS Coastal Plain
            we come to terms with the fact oil supplies will eventually be                         The case for all
            depleted, or should we develop alternate energy sources now                            is being justified in part *on the ability of industry to
            and preserve some areas of our country in their natural state                          minimize damage as learned from oil and gas activities
            for future generations?                                                                elsewhere in the Alaskan Arctic.'(Ibid. p.III.)    I think the
                                                                                                   facts show the industry still has a lot to learn. The oil
            I think the destruction of the resources on the Arctic                                 industry is still incurring significant damage on the
            National Wildlife Refuge would be too high a price to pay for                          resources. This assessment report anticipates moderate to
            a twenty percent possible chance of recoverable oil on the                             major negative effects to Permafrost, Gravel Supplies and
            Coastal Plain.                                                                         Ambient Noise Levels if Alternate A is selected. It projects
                                                                                                   "increased noise and disturbance levels displacing wildlife
            Developing the coastal plain would have serious adverse                                throughout the 1002 area.* (ibid. p.131). oil spills would
            impacts on wildlife. Major development Is proposed to take                             also be a threat to the resource.   'Any spill of oil or other
            place in the critical staging area for snow geese, the denning                         hazardous materials along the coast could severely affect
            areas for polar bear and the year round habitat of muskozen.                           coastal and marine habitats and fish and wildlife." (Ibid.
            Oil development could result in 'Increased disturbance with                            p.105). mAynt AantAl -spills of crude oil and refined petroleum
            possible avoidance by muskozen of 71 percent of their high                             products Are an inevitable consequencgo of oil field
            use, year-round with calving, habitats In the 1062 area                                daveloRmant. Since 1972 (at Prudhoe Bay) some 23000 mostly
            resulting in a change In distribution, population decline,   or                        small spills have been reported to the Alaska Department of
            no further expansion of the 1002 muskozen population.* (Draft                          Environmental Conservation.0 (Ibid. p.103). Even the limited
            Arctic National Wildlie Refuge, Alaska, Coastal Plain Resource                         seismic exploration on the 1002 area during the 1904-85
            Assessment. p.114).                                                                    resulted In leaks of crankcase oil, antifreeze, and hydraulic
                                                                                                   fluid from vehicles. (ibid p.102).
            Development could also lead to 6DIsplacenent of caribou from
            approximately one-third of the core, concentrated calving

              I do not believe the adverse effects and resulting destruction
              of ANWR'a Coastal Plain resources is justified to remove
              limited amounts of oil. The Arctic National Wildlife Refuge
              represents the last large area of unaltered tundra ecosystem
              in the United States". I believe we owe it to future
              generations to save intact representative areas of the major
              ecosystems of the world. Millions of acres of similar habitat
              along the coast west of ANWR have already been sacrificed for-
              oil development. The remaining coastal tundra habitat In ANWR
              is only a small percentage of what was one time available.

                                                     Sincere
                                                       1A
                                                     Kathleenly/M O'Reil
              CC:

              Ted Stevens
              U.S. Senate

              Prank Murkowski
              U.S. Senate

        CO    Don Young
              U.S. House of Representatives

              Morris Udall
              U.S. House of Representatives

              Bennett J. Johnston
              U.S. Senate Energy and Natural Resources Committee

              Steve Cowper
              Governor, State of Alaska
                                                                 O-R@eil

    January 22, 1987

    P.O. Box 338
    University of Alaska-Fairbanks
    Fairbanks, AK 99775-1040

    U.S. Fish and Wildlife Service
    Attn: Division of Refuge Management Resource
    2343 Main Interior Building
    18th and C Streets, N.W.
    Washington, DC 20240

    Gentlemen:

    	Attached is a copy of a letter I've written to Senator
    Bennett Johnston as Chairman of the Senate Energy and Natural
    Resources Committee, regarding the Arctic National Wildlife
    Refuge and the recently proposed "1002 Area" oil and gas dev-
    elopment.
    	I strongly oppose this development. I also believe the
    Draft Report reflects significant weakeness in the environment-
    al impact assessment. I outline my reasons in some detail in
    the attached letter.
    	Please register my concern and my position. Thank you.

    Sincerely,

    Jon Pfeffer

    P.O. Box 338
    University of Alaska - Fairbanks
    Fairbanks, AK 99775-1040

    Senator Bennett J. Johnston
    Senate Energy and Natural Resources Committee
    Senate Office Building
    Washington, DC 20510

    Dear Senator Johnston:

    	I'm writing to express my strong disapproval of Secretary of
    the Interior Bill Horn's recommendation to allow full oil and gas
    development within The Arctic National Wildlife Refuge's 1002 area.
    	I feel the preferred alternative asserted by the Secretary in
    the Draft 1002 Report is a fundamental policy statement. It pro-
    motes perceived immediate economic benefit over a more incremental,
    less tangible, but permanent benefit - more complete than and cer-
    tainly inclusive of economic value. This statement represents
    neither me nor, I suggest, the American public. Gives us research
    and development in a sustainable energy future, specifically in
    renewable energy resources - any maybe we'll have something to
    show for ourselves as a nation even before the proposed develop-
    ment of ANWR would yeild its alleged bounty.
    	Of the alternatives considered, Secretary Horn recommended
    full development notwithstanding the acknowledged unavoidable and
    very significant affect upon each of the concerns for which the
    entire Range (and subsequent Refuge) were originally established.
    The 19% chance of recoverable oil certianly does no merit full
    development. The prices of oil assumed in the report greatly ex-
    ceed short-term projections; there is time for more study....
    although one has to wonder if the problem lies more in evaluation
    of data than acutal compilation. (Horn's introduction to the 1002
    report represented what one local writer calls ("a 'seam'... a gov-
    ernment analysis in which you see a difference between what the staff
    wrote and what their bosses concluded." The 1002 report is full
    of seams.)
    	There should be no rush to avoid a circumspect public assess-
    ment and comment period. The 1002 Draft Report was initially
    published in insufficient quantity, and even with the recent ex-
    tension for public comment, we (the public) find ourselves bombard-
    ed with inforamtion and analysis, much of it, of course, contradictory.
    My qualms regarding the 1002 Report and its proposed development
    include the following:

    1. An unacceptably narrow perspective is being used to assess the
    environmental impact. The 1002 area is dissociated with adjacent
    oil fields currently operating and potential future leases, includ-
    ing off-shore leases. The impacts will be not merely distinct, or
    even additional, but synergistic. My concern is not merely for the
    caribou or any other single species as much as for the unparalleled

    diversity indigenous to that area. That diversity is 100% guaran-
    teed, and is dependent on the 1002 area in the way our bodies
    depend on our kidneys, for example. We do a disservice by discus-
    sing sizes of areas; we should instead assess function. Minimal
    management on the rest of the Refuge doesn't cut it. Adjancent
    wilderness and full development are not compatible.
    	Outside of the Refuge there are roughly 1100 miles of U.S.-
    owned Arctic coastline. Approximately 25 of those 1100 miles are
    presently protected from oil and gas development. We need more -
    and we're only asking for what already is.

    2. The impact of natural gas development is not assessed. While
    this may be convenient and economic for the purposes of limiting
    the scope of research, it is misleading; it renders the environ-
    mental assessment incomplete.

    3. Both The Alaska Department of Fish and Game and The Alaska Dep-
    artment of Environmental Conservation find the study lacking in
    essential information.

    4. The impact of hazardous wastes generated by future development
    is not sufficiently addressed. Recognizing that the political clout
    of Big Oil has successfully prevented oil wastes from being categor-
    ized as "hazardous" by the E.P.A. (ludicrous as that is to members
    of the public as well as the scientific community), I still want to
    know how this quantity of waste would be handled. Current methods
    on the Slope are not effective.

    5. Gravel and water are limiting factors. Removal of such quant-
    ities as are needed within the 1002 area will adversely affect the
    various watersheds - not merely the hydrology, but the entirety of
    the ecosystem based in them. Notable losers will be fish and the
    many predators of those fish.

    6. The geology of most of the 1002 area is "complexly folded and
    faulted" according to the report, "vastly different from the rel-
    atively simple structure that underlies the coastal plain west of
    the Arctic Refuge, such as Prudhoe Bay." What is not contained
    withinj that area contains, according to a local journalist, the same
    oil-bearing stuctures as the shallow West Sak and Ugnu deposists of
    Prudhoe. These deposits are of such low quality that the fields
    are actually cased off from operating adjancent wells. Additionally,
    we're talking about 26,000 feet deep wells, more than one winter of
    drilling, for the elusive oil. This situation clearly promotes
    many exploratory wells - and much attendant impact.

    7. Too many proponents of ANWR development cite the Prudhoe Bay
    pipeline as exemplary of wildlife management and ready adaptation.
    The Refuge is distinct topographically, and few correlations can
    be drawn between the respective ecologic communities. Addition-
    ally, the caribou "success" at Prudhoe is very moot; a distinguish-
    ed University of Alaska-Fairbanks wildlife professor, who has spent
    years studing those caribou, states unequivocally that the impact
    on that population is decidedly negative.

    8. "Project M" or "Megatrade", through which the U.S. Fish and
    Wildlife Service attempted to negotiate trades of land and sub-
    surface rights with both Native corporations and the State of Alaska,
    was - and continues to be - irresponsible. Moreover, it undermines
    Congressional intent. The public's impression is that there are
    lots of cards under the table here, and the game is starting to
    stink.

    	To sum up, a notable portion of Alaskans oppose ANWR develop-
    ment, although we are not represented in Congress as such. We,
    like those in the rest of the country, prefer a viable energy fut-
    ure, a foward-looking plan, and an active research and develop-
    ment program in renewable energy. The 1002 area of The Articic Nat-
    ional Wildlife Refuge is not the answer to our needs.
    	Please accept the challenge to vote NO on 1002 development.
    Give us Wilderness, protect the values for which we established the
    Refuge, and get the issue out of the way. At the very least, give
    us more research - on both oil probabilities and environmental
    impacts.
    	Thank you.

    Sincerely,

    Jon Pfeffer

                 Comments re.:  Department of interior                                                      4. Discussion of Impacts In Executive Summary
                                November 1906 Draft Arctic N.W.R.                                           The Executive Summary glosses over the impacts of
                                Coastal Plain Resource Assessment                                           development as described in Chapter VI.     The statement,
                                                                                                            "Most adverse effects would be minimized or eliminated
                                                                                                            through carefully applied mitigation .... exploration and
                 From:          Martha X. Raynold3                                                          development at Prudhoe Bay Indicates minimal Impact on
                                1099 Farmers Loop                                                           wilJllfe resources. Hence It Is reasonable to assume that
                                Fairbanks, AK 99709                                                         development can proceed on the coastal plain and generate
                                                                                                            similar minimal effects.", Is EXTREMELY misleading. First,
                                                                                                            the Impacts to caribou, muskox, and snow geese, as described
                                                                                                            In Chapter VI are MAJOR impacts that cannot be mitigated.
                 I appreciate the opportunity to comment on    the Draft ANWR                               Secondly, development at Prudhoe Say has had some very
                 Coastal Plain Resource Assessment, and sincerely hope that                                 significant Impacts on wildlife In the area.      And thirdly,
                 the deficiencies pointed out In my comments and others' will                               the Prudhoe Say area is not directly comparable to the 1002
                 be addressed In the final document. I thought most of the                                  area. The ANWR coastal plain provides much mote critical
                 report was well prepared, but found several problems with                                  habitat for caribou, muskox and snow geese than Prudhoe Bay
                 Chapter VI Environmental Consequences, and found the                                       ever did.   Most of the Impacts of the recommended
                 Executive Summary to be a very poor representation of the                                  Alternative A are very clearly stated in Chapter VI, and
                 contents of the report.    I also disagree with the Interior                               should be included In the Executive Summary.
                 Department's conclusion that Alternative A, full leasing of
                 the coastal plain, should be the recommended alternative.                                  5. Recommended Alternative
                                                                                                            Personally, I would recommend Alternative E. If and when
                 1.  Water and Gravel Resources                                                             oil and gas resources become so scarce and precious (as they
                 The problems caused by lack of water and gravel resources       on                         are clearly NOT right now) that we should risk the wildlife
                 the coastal plain are not adequately addressed.      Although                              and wilderness resources of the ANWR coastal plain, an act
                 their scarcity Is mentioned, the alternative measures which                                of Congress could allow drilling.     Until such time, the
                 would be required to extract the gravel and water required                                 coastal plain should be protected.     If development interests
                 for development are not fully described.     Consequently, the                             are so strong that drilling cannot be prevented, why Is
                 Impacts which would be caused by gravel and water extraction                               Alternative C not adequate?     The report states that even
                 are not covered in Chapter VI.                                                             under Alternative A, considerable further exploration would
                                                                                                            have to be carried out before any companies would be
                 2.  Central Arctic Caribou Herd                                                            Interested in leasing.    If preliminary exploration needs to
                 The Impacts of development on the Central Arctic Caribou                                   be done, why not allow that and THEN review the data and
                 Herd (CAH) are not adequately described.     The discussion     In                         assess the tradeoffs with more complete information to
                 Chapter VI does not include the impacts due to the pipeline                                decide whether to open the 1002 area to leasing?
                 and road which would be required to Join the 1002 area to
                 the Trans-Ala5ka Pipeline (TAPS).    This east-we3t connectInq
                 corridor would be a prerequisite for. development of the 1002                                                  Signed
                 area. it would have a very significant impact on the CAH                                                              Martha K. Raynold.3
                 by cutting across Its summer habitat, u3ed for calving an@                                                            Biologist
                 Insect relief.   The Impacts of this pipeline and parallel
                 road must be Included In the discussion :E the impacts of                                                      Date
                 development of the 1002 area. The impacts to the Porcupine
                 Caribou Herd are thoroughly addreszed.

                 3. Petroleum Re3ourc-- Potential
                 Chapter III states that there Is a 19% chance of there being
                 an economic size accumulation of oill 3nd gas on the coastal
                 plain. The Executive Summary doe-- not even mention the 81%
                 probability that NO economic oil or -gas exists in the
                 coastal plain. it only discusses the probable uize of such
                 an accumulation, should It )ccur. This is very misleading.
                 The full probabilities of finding oil and gas should be
                 presented very clearly in the summary.

                                                              dill-

                                                                                          v-e,

                                                                                        -0t,

                             rope-
                                                                                          eel

                                                                                                                                14-e

                                                                                                 CL

                                                        -ve

                  DO YOU WANT TO KQM PUBLIC COMMMS?
                                                                                                                                                                                                         All

                                                                                                                        TESTIMONY
                  If you would like to speak at the hearing today, please fill in the blanks                            ON DRAFT 1002H REPORT ON ANWR
                  below and turn It In to out of the Fish and Wildlife Staff members present.                           By Malcolm B. Roberts
                  You need not complete this sheet to submit written comments. Thank you.                               2001 Churchill Drive
                                                                                                                        Anchorage, AK 99517

                  Please print
                  Name                           t.1I                                                                   Ladies and gentlemen.            My name is Malcolm Roberts.               I am a
                  Mailing Address                                                                                       consultant in government and community relations here in
                                                                                                                        Anchorage, and I am representing myself.

                  Check appropriate box belows
                   E3 1 as here to offer my     ova views.                                                              I have read the 1002H report and would like to commend you on its
                                   --or-                                                                                quality and thoroughness.              Unfortunately, having worked in
                   C3 I an speaking for
                                            (please enter new of organization you repreaWn-0                            Washington, D.C. as a Special Assistant to the Secretary of the

                                                                                                                        Interior, my hunch is that very few members of the U.S. Congress

                                                                                                                        will take   time to read it.

                                                                                                                        Instead they will rely mainly on the comments in the Washington
                                                                                                                        Post, :Elle New Xork Time;, their local newspapers and on the

                                                                                                                        personal briefings they receive from staff and from lobbyists on

                                                                                                                        both sides of the issue.

                                                                                                                        In other words, they will be inclined to approach a scientific

                                                                                                                        subject, which you have presented very well here, and react to it

                                                                                                                        on the basis of media reports and emotional appeals.
                                                                                                                                                                             4,j 0-1
                                                                                                                        In my view, America is ill-served by fa&dlst journalism and

                                                                                                                        bumper sticker wisdom.

                                                                                                                        One headline that reads "Oil developers trying to Invade                . wildlife

                                                                                                                        sanctuary" can be enough to sway an uninformed Congressman's

                                                                                                                        vote.

            For that reason, if sound public policy decisions are to be made                       If Ralph Nader, in the spirit of consumer protection, would spend
                                                                                                   $2,500 to fly coach from Washington, D.C. to Anchorage to
            by Congress, it is important that the substance of this report is
            presented in a manner that will counter some. of that                                  Dead.horse and then charter to the Wildlife Refuge and back, I
            emotionalism.                                                                          would suspect that he would return irate.

            I would like to suggest, not a correction of your report, but                          Mr. Nader, or any American citizen concerned about truth in
            some ad.ditional information added to your graphics which                              packagikig, would be disappointed to learn that other than
            illustrate effects on the biological environment.              When                    caribou, most wildlife do not choose to migrate north towards
            discussing each s"Pecie of wildlife (as on page 149)     1 suggest                     this country with such little forage and no cover.
            that you add the population totals.
                                                                                                   In fact, for ten months out of the'year, there is virtually no
            Secondly, I recommend that a graph .ic be included on the amount of                    wildlife in this Wildlife Refuge.

            public use.

         T
          4 In August  of 1970, 1 accompanied the U.S. Secretary of the                            Your report details the evidence you have been able to gather
            interior as we flew over the Coastal Plain, doing what many of                         about polar bears, brown bears, muskoxen, dall sheep, wolves,
            you have done, and r h6pe you will urge all members of key                             wolverines, arctic foxeV, whales, seals, peregrine falcons,
            Congressional committees to do likewise. We spent the day in a                         golden eagles and waterfowl.

            helicopter. we were looking for wildlife.
                                                                                                   That list is enough to make the average American's heart jump.
            After all, Congress in its wisaom dubbed this vast section of
            acreage a Wi.Idlife Refuge.                                                            My poin *t is..;as this area of nearly 3,000 square miles or some
                                                                                                   1.5 million acres, is being reviewed by Congress for its highest
            We saw several dozen caribou from the Central Arctic herd.        We                   and best use, let's be more graphically specific.

            saw one brown bear. It was dragging the freshly killed carcass
                                                                                                   Let's start with moose.  I quote from your report-
            of a moose.   we saw a large number of snow geese.     But for the

            expense and effort dedicated to the day's activities, the rsults
                                                                                                   "The number of moose using the 1002 area at any one time@ probably
            hardly compared with a visit to Denali National Park.
                                                                                                   does not exceed 25."   In other words, less than 1 per 100 square
                                                                                                   miles. The moose density in Anchorage is much E,@wr greater.

           The Alaska Department of Fish, and Game estimates th     at there are                        area, 1 to 2 dens   were found I  n 4 of the 5 years" between      1981
                                                                                                        and the present. "Another 5 dens have been located on ice near
           between 144,000 and 160,000 moose in the state.
                                                                                                        the 1002 area.'

           Dall Sheep:   I quote:   "Dall sheep are very rare in    the 1002 area.*
           Even the unitiated realize that dall sheep,       like most mountain                         Mu.skoxen: Reintroduced by Governor Walter Hickel in 1969, the
                                                                                                        muskoxen herd in the entire 18 million acre Refuge has grown from
           sheep, live in mountainous areas. These animals do not wander
                                                                                                        69 animals to 476. Domesiticated at the University of Alaska,
           north onto the flat or rolling lands of the      coastal plain.       By
                                                                                                        Muskoxen have shown no adversion to man's presence,        as long as
           the way, there are some 60,000 to 80,000 Dall Sheep in Alaska.
                                                                                                        man isn't hunting them.

           Wolves: I quote: "no dens have been found" in the 1002 area#
                                                                                                        Caribou: You estimaste that there are approximately 180,000
           and "The number of wolves using the 1002 area on a seasonal basis
           is low and apparently does     Inot exceed 5-10 animals annually."                           caribou in .the Porcupine herd and another 2,000 - 3,000 Central
                                                                                                        Arctic caribou move from Prudhoe and Kaktovik into the 1002 area
           wolverines: Quote: "recent FWS studies have resulted in            very                      after the Porcupine Herd moves on. Over all, there are between.
           few  sightings."    Your, re@port places one guess at around         90.                     550,000 and 600,000 caribgu in Alaska distributed in 25 distinct
                                                                                                        herds.   State biologists say that nearly all of these herds are

                                                                                                        healthy and growing.
           Brown bears: "use is estimated at one bear per 30 square miles,
           or approximately 108 bears."      Having spoken with those who flew                          Geese:     I quote:    "The coastal plain is not a major nesting
           a grid of the entire area for the gravity studies, I find this                               area."   it is, however, a major staging area -- as many as
           number hard to believe.       But if it is indeed accurate, it is                            595,000 waterfowl gather on the entire staging area that
           important for the American public to know that the Ak Dept of                                stretches along the coast into the Yukon territory.
           Fish and Game estimates that there are between 32,000 and 43,000
           brown or grizzly bears in Alaska.                                                            It should be noted that Prudhoe Bay, with. its high level of        oil
                                                                                                        industry presence, continues to serve as a nesting area             for

                                                                                                        all major species of geese, for swans, ducks and other waterfowl.
           Polar bears:     the report Indicates there is a population of

           roughly 2,000 polar bears in the Beaufort Sea, 87% of whose dens
           are located on the ice pack offshore.           Quote;   "in the 1002                        So, in summary, my recomendation is that you include       a chart on

            with your wildlife population estimates.             If my reading of the

            report is accurate, it would go something like this:
              F
                  Dall Sheep             none

                  Wolves                 5-10

                  Moose                    25

                  Wolverines               90
                  Brc@wn bear             108

                  Muskoxen                476

                  Polar bear dens         1-2

                  Caribou             183,000

                  Birds and waterfowl:

                  Swans            400 - 500

                  Ducks                355,0000
          OD

                  Geese               105,000

                  Golden eagles          2575

                  Peregrine   falcon eyries       2 (formerly occupied

            One element I     did not find     reported in the 1002 study, is the

            amount-of human activity, other than subsistence use, in the 1002

            area.

            I would like to know, and I believe the American people deserve

            to know, how many people visit this area annually.

            If there is very little wildlife. there.             Which is a fact.        if

            nearly  no one, other than government personnel visit there, which
            is a fact.      And if Congress refuses to open it ulp to tap

            potential oil and gas reserves ... someone needs to answer the

            question, what then is It for?         Thank you.
                  Da01   S7heep          none
                     I

                  Wol    r
                      -e                 5_10

                  M.   e                   25

                  W.lv.  in..              go

                                                          2532 Roland Road                             I flew over the Chevron well site during the summer  of 1986 and
                                                          Fairbanks. AK 99709                          saw that stack upon stack of pink styrafoam left behind when the well
                                                          January 20. 1997                             was abandoned had been blown apart by the wind and was scattured across
                                                                                                       the tundra. Oil exploration and development is seldom the clean slick
               U.S. Fish and Wildlife Sf:rvice                                                         affair that this report would have one believe.
               Division of Refuge Management                                                           I understand the U.S. Fish and Widllife Service is working on a
               2343 Main interior Bldg.                                                                project known.by some as the "megatrade". The Department of the
               18th and C Streets, N.W.                                                                Interior, apparently confident of the disposal of ANdR. intends to
               Washineton. D. C. 20240                                                                 pursue giving up the subsurface rights to lands undfr the AN4R coastal
                                                                                                       plain in exchange for surface rights to native inholdings within other
               Gentlemens                                                                              Alaska refuges. This decision would likely give the oil compan   'ies a
                                                                                                       freer hand to operate within ANWR should Congress open the area up.
               This letter responds to a request for comments to the draft Arctic                      It should also be pointed out that it took a law suit to gain the
               National Wildlife Refuge. Alaska Coastal Plain Resource Assessment                      right of the public to comment on this report yet hearings in Alaska
               prepared by the Department of Interior.                                                 were not held in Fairbanks, and Arctic Village even tholAgh they were
                                                                                                       requested.
               From 1976 to 1984 1 was employed by the U.S. Fish and Wildlife   Service
               in Alaska where I served on the staff of the Arctic National Wildlife                   One could go ont with the foregoing littany which demonstrates the
               Refuge (ANWR) as an airplane pilot and Assistant Refuge Manager. I                      prodevelopment bias of the Department of Interior. This is not
               spent many hours in the air and.on the ground within the coastal                        necessarily bad except that any recommendation of the Department of
               plain of ANWR.                                                                          Interior regarding the final disposition of AN4R lackscredibility
                                                                                                       because of internal bias towards one point of view. If one is truly
               Nowhere does this report make a purposeful statement that reflects the                  interested in an objective assessment of the national intercst with
               fact that the coastal plain of ANWR is one of the finest wilderness                     regard to the final disposition of the ANWR   ',oastal plain one will not
               and wildlife areas In North America. With the exception of a small                      find it in this report.
               sliver of designated wildernesseast of the Aichilik River It is
               virtually the only natural area on the north slope of Alaska and thus                   If there is oil under the coastal plain and   development is allowed
               in the United States.that is not dedicated to oil exploration and/or                    to proceed the value of the coastal plain as wilderness will be
               development. The original purpose of the Arctic National Wildlife Range                 destroyed. One cannot deface a "Mona Lisa" and still expect to have
               established in 1960 was to preserve unique wildlifei wildscomi4e. and
                                                                                                       a masterpiece. While it may be speculative    to say what may happen to
               recreation and scientific values. In a betrayal of those who worked                     the wildlife and especially the caribou of the coastal plain It is a
               so hard to have this area protected the ANILCA legislation does not                     well established fact that If you destroy wildlife habitat or deny
               even mention the word wilderness as one of the purposes of the expanded                 use of same. wildlife species that cannot adapt to.altered circumstances
               Arctic National Wildlife Refuge. Yet wilderness preservation is one                     will not survive. There.is more than ju-,t a slipht possibility that
               of the key issues and it is what makes ANWR in its own unique way                       inbre than one species of wildlife will not be able to cope with the
               comparable to any of our finest national parks. Would the American                      various disturbances and destruction of habitat resulting from explora-
               public really approve of the degradation of a national treasure if                      tion and development of  the ANOR coastal plain.   Is the possible gain
               this report unbiasedly assessed what was really at stake?
                                                                                                       in the short term worth  permanently degrading a natural area and
                                                                                                       placing at jeoprady the  well being of wildlife using the ANdR coastal
               It is with considerable sadness. though not surprising. that I    find                  plain In the long t@rm? The.Department of Interior apparently believes
               the Department of Interior recommending full scale leasing of the                       that it is'ln the national Interest to allow one of the nations premier
               ANWR coastal plain. Past actions of former Secretary of the Interior                    wildlife and wilderness  areas to be the next drilling target because
               Watt telegraphed the intent of this administration regarding the                        it is alledgedly highly  prospective for oil.  Yet at the same time this
               future of ANWR. Watt traded away the subsurface rights to nativellands                  nation has no national energy conservation policy, no alternative fuels
               around the village of Kaktovik and along the near coastal area south                    program and this administration has relaxed auto fuel efficiency
               of Barter island without the opportunity for broad public review.                       standards.  This nation is like a child on a ca.-idy eating binge except
               Heretofore the natives had title to only the surface estate of these   lards            our candy is oil.  Now the public is being anked to risk a national
               precluding development of the subsurface estate.    With public control                 trea3ure to continue this Pluttonous diet.    This should not be the
               of these lands within ANWR lost to private interests seismic exploration                next target for exploration-, it should be the last if at all.
               took place on these lands and Chevron drilled the first exploratory
               well within ANWR. All of this occurred prior to completion of this                      This nation will continue to be dependent on foreign oil imports far
               report and a decision by Congressapparently in an attempt to prejudice
                                                                                                       into thu future Irregardless of any possible contribution from ANWR
               the outcome in advance.                                                                 because tht.-re is a defacto policy of triurgy consumption rather than
                                                                                                       c:-,nservation of a non-renewable resource. Any oil from ANWR will be

                                                -3-                                                                                          -4-

                sucked out in 20 to  30 years leavinor in it s wake a degraded landscape                    On twe 75 if states that "new surv(-yF; might not differ much from
                and placing at risk far into the future nationally and internationally                      tht cumulative total of about 1300 rdles already collected." Not
                significant species of wildlife.    Humpty Dumpty cannot be put back                        mentioned here or elsewhere is the fact that in addition to the
                together again once the shove is given.                                                     hundreds of miles of seismic lines Impacts to the tundra also occur,
                                                                                                            from the many additional miles of random trails created by supply
                In the long run I believe the net benefit to this nation from retaining                     trains that haul fuel and other supplies to and from seismic trains.
                its premier wilderness areas in*tact will far outweigh the short term                       '1300" miles of seismic line provides the rpadcr with no clear picture
                benefits that may be gained from non-renewable resource extraction.                         of the actual miles of trails and back and forth travel that occurs
                One has only to look at our own national parks and refuges and those                        along any one seismic line.
                around the world to realize the benefits and wisdom of preserving
                our important naturalareas for the enjoyment of future generations.                         Page 74 Para. It What is reasonably near the coast? Use of rolligona
                                                                                                            to transport heavy equipment to a drill site might or might not be
                The argument that only the elite visit ANWR Is *baloney*. People from                       analogous to the use of "winter trails" by seismic crews. This would
                all walks of life make a deliber@ite choice to visit ANWR and savc their                    depend on the amount of snow cover, type of terrain and the numb(r of
                money to do so just like anyone else who wishes to take a wilderness                        passes ov(r any one trail. How are tolligons used with "care"?
                vacation. It is expensive but so is a vacation to Europe or some othcr                      Page 99,Para. 21 It states that additional crews "could" increase the
                distant point. It is good that there are still wild places that are
                @ot heavily visited. One of the primary reasons people visit ANWR                           overall impact. It stands to reason that additional crews "would"
                is to enjoy the quiet and solitude of a wilderness setting. This                            increase the overall impact rather than could as this carefully worded
                opportunity is becomming Increasingly rare as the worlds wild places                        sentence implies. Additional crews would mE-an more supply trains
                dwindle to a few remnants. People need a place where they can come and                      travelling across the tundra to supply seismic trains creating new
                find spiritual renewal which is not possible when. hoards of pcople                         trails and increasing the impact   on the tundra.
                are present. Development of the coastal plain would devestate the                           Page 99. pars. 4t Wh&t Is about 6 inches? Six Inches of snow is a bare
                quiet and solitude that people seek and are now able to find in ANWR.                       minimum standard. So stated it would allow opcrations in areas where
                                                                                                            there may be.less than 6 inches of snow as long as there was about
                Let us protect for now this natural masterpiece that Is the ANWR                            6 inches in most places. This imprecise and minimal standard is not one
                coastal plain. Put this one in the bank and give it the protection                          thst _;III- io-ure +.he greatest protecti_- of                    s..-IsMic
                of wildcrness status. If there is oil it Is not going anywhere. The                         and othfr exploratory.activities.
                price you are asking is too steep. Let's not make a premature with-
                drawal and risk throwing the bank Into default until we are sure there                      Page 1021 Ice well pads and gravel-timber insulation pads are mentioned
                is no other alternative.                                                                    as ways to ibinimize the amount'of gravel needed. In the following
                                                  Sincerely.                                                paragraph subsurface disposal of drilling muds is stated as a means
                                                                                                            of eliminating the need for large reserve pits. Yet when one reads
                                                                                                            about mitigation on page 104 the employment of any of these techniques
                                                                                                            to minimize effects on vegetation is not even mentioned or discussed.
                                                  Donald E. Ross
                                                                                                            The conclusion on page 105 that the effect of full leasing is anticipat-
                der                                                                                         ed to be minor on coastal and marine habitats is not accurate. Coastal
                                                                                                            and marine habitats would be significantly modified in places where
                                                                                                            port facilities are developed and causeways constructedto serve the
                P.S. Surprise me -and recommend wilderness diBlisignationl                                  same not to mention modification to coastal habitat3from transporting
                                                                                                            equipment and supplies inland from these sites. Some dredging may
                                                                                                            also be required. It may be true that the effect on coastal and marine
                                                                                                            habitats from fuel spills is anticipated to be minorat least until one
                                                                                                            occursbut at least this conclusion would be more consistent with the
                                                                                                            foregoing discussion.
                                                                                                            On page 106 it states that analogies comparing the effects of current
                                                                                                            oil development on tht. CAH andeffects of potential 1002 development
                                                                                                            on the PCH must be drawn with caution. on page 108 the statement
                                                                                                            is made that displacement of the PCH from a core calving area to a leas
                                                                                                            desirable area would be expected to reduce caribou productivity.
                                                                                                            Followed by a statement that no.recogniz.able. long-term effect on the

              the CAH as a result of displacement by oil development in the central
              Alaskan Arctic has been demonstrated to date. This does not strike
              me as a cautiously drawn analogy since the implication is because it did
              not happen to the CAH it would not happen to the PCH particularly when
              in a later paragraph it states that the lack of observable adverse
              effects from displacement exhibited by the CAH would be, unlikely
              for the PCH.

              The period for which dataon the PCH is available from 1972 to 1985
              is a relatively shorV one compared to the total unreported biological
              history of the herd. During the period from 1972 to 1985 the PCH
              also calved and moved in,significant numbf-rs west of the Hulahula River
              and can be expecicd to do so in the future. Just because the herd
              !as observed to calve in significant numbers east of the Hulahula River
              in most of these years does not mean that this situation will necessari--
              ly continue in the future. A core calving area Is a useful poiftt of
              discussion for biologists since It reflects where caribou were conscen-
              trated during the years of observation. It would however, be a mistake
              to conclude that because caribou used one area mors- than another during
              a particular period that the area used less frequently was also les 11
              important. From the standpoint of the well being of the herd denial
              of just part of the herd's historic calving grounds could have.long
              term negative consequences if exploration and leasing schemes are based
              on the assumption that one part of the range is less important than
              another simply because the period of observation was t06 short and we
              had'ah iricomplete picture of herd dynamics.

                                                                RICHARD V. SHAFER
                                                                    2012 SARATOGA AVENUE
                                                                  ANCHORAGE. ALASKA 4Q5Q4-
                                                                          (9071 274 3149                                                                                                  Comments on ANWR resource assessment

             PP FESSIONAL ENGINEER                                                                                                                                                        0     Petroleum         activity      in     the     Wildlife      Refuge        will     create     sorely      needed
             ALASKA CE 3640                                                                                                                                                                     employment opportunities throughout Alaska's economy.
             ARCT@C ENVIRO MENTAL ENGINEEPING
             ARCT C MARINE SYSTEMS
             PE T-ELIM OPERATIONS LANNING                                                                                                                                                 0     Leasing and development of additional petroleum reserves will strengthen
             SPILL CON7  NGENCY PLANNING                                                                                                                                                        federal, state and local tax bases.

                                                                                             01/21/1997                                                                                   0     Based      on     industry        experience      in     the     Prudhoe        Bay    area,     I    feel     very
                                                                                                                                                                                                confident that            with     prudent planning by                industry and           government, oil
                                                                                                                                                                                                exploration and (with luck) development can proceed in the ANWR coastal
                         U.S. Fish and Wildlife Service                                                                                                                                         plain area without significant or long term harm to wildlife resources.
                         Attn: Division of Refuge Management
                         2343 Main Interior Bldg.
                         l8th and C Streets, N.W.                                                                                                                                               Most of the proposed mitigative measures discussed on pages 145 through
                         Washington, DC 20240                                                                                                                                             147   of the assessment are consistent with present                                   industry practice in the
                                                                                                                                                                                          Prudhoe Bay area.               In general, these proposed stipulations can be expected to
                                                                                                                                                                                          ensure protection of wildlife and other environmental                                     values.          You may,
                                                                                                                                                                                          however, wish to consider the suggestions listed below by stipulation number.
                                 I would like to offer the following                   comments regarding the draft document,
                         Arctic National Wildlife Refuge. Alaska, Coastal Plain Resource Assessment,                                                                                      5.    Proposed stipulation              5 prohibits off-road                vehicle       use except by              local
                         published by the U. S. Department of the Interior in November 1986.                                                                                                    residents of by specific permit.                         This is a reasonable measure provided
                                                                                                                                                                                                off-road permits are quickly available in the event of an emergency such
                                                                                                                                                                                                as an oil spill.
                                 I have been a resident of Alaska since 1972, and during this time I have
                         been involved with a variety of operations in the arctic and subarctic tundra                                                                                    6.    This stipulation would                 prohibit exploratory activity during summer but
                         areas of the state.           My employment during this period has been with the federal                                                                               allows exceptions.            It is very important that the mechanism for exceptions
                         government as well             as with private industry.                 Most of my experience in this                                                                 be in working order in the event of a down-hole emergency.                                      It should also
                         state has been associated with environmental aspects or petroleum exploration                                                                                          be     recognized         that   there -are        risks and          costs     n-ssociated    with        seasonal
                         and     production.            I   have      degrees       in    civil,     petroleum        and       environmental                                                   drilling, e.g. a new crew cannot be as proficient as a crew which has been
                         engineering, and          I'm a registered professional engineer in Alaska.                                I have a                                                    working together for a period, and in an emergency situation a green crew
                         strong       interest      in      promoting         the      environmentally            responsible          economic                                                 cannot be expected, to respond as quickly nor as appropriately as an
                         development of our resources.                                                                                                                                          experienced crew.

                                                                                                                                                                                          11.   Where roads and pipelines are separate, some means must be designed For
                                 I  am      presently       employed        by     an     industry-sponsored           oil    spill     response                                                periodic inspection of the pipelines.
                         association.        However, I am writing this letter as an interested citizcn, no(
                         as an industry spokcsman.                                                                                                                                        12.   What is meant by "restricted surface occupancy"?                                Does that mean that well
                                                                                                                                                                                                pads would be prohibited within the three-mile zone?

                                 I support the Secretary's decision to propose petroleum leasing on                                            the                                        14.   Prohibition of permanent                   facilities within           3/4      mile or specified            water
                         coastal plain of the Arctic National Wildlife Refuge (ANWR) for the following                                                                                          courses ' seems           excessively      conservative.             Facilities     may      require       special
                         reasons:                                                                                                                                                               engineering treatment near water courses, but "near" might be 20 ft in one
                                                                                                                                                                                                case or 5 miles in another, depending on terrain conditions.                                               Also, it
                         �       Western countries in general, and the United States in particular, need to                                                                                     should      be      noted     that     it    is   usually      best,       environmentally        as       well   as
                                 reduce the present vulnerability to interruption of oil imports From the                                                                                       economically,         to develop           permanent        water      storage      facilities      near     water
                                 Middle East.                                                                                                                                                   courses.       Decisions on development near water courses should be made on a
                         �       We in the United States have a desperate need to reverse the deterioration                                                                                     case-by-casc basis.
                                 of our balance of trade.                                                                                                                                 15,   26.    Aircraft       altitude      restrictions         should     apply       not    only     to     petroleum
                                                                                                                                                                                                operators but to government and scientific activities as well.

                                                                                                                                                                                                                                                     2 -

                  Comments on ANWR resource assessment

                  27.    Fences can cause problems on         the Arctic Coastal Plain.         Tightly woven
                         fences (e.g. Cyclone fences) can produce undesirable snow dril-ting.               Open
                         fences (e.g. cattle fences) allow snow to pass but can entangle                  caribou
                         antlers.   In any event, the fences must be placed at considerable              distance
                         from facilities in order to allow room for deposit or. snow which has been
                         cleared from the facility area.        This deprives grazing animals of what is
                         otherwise good habitat within the fenced area.             Also, caribou often seek
                         out production     facilities as insect relief habitat.       especially   when     they
                         are being harassed by nose bot flies; fencing would deprive them of this
                         habitat enhancement.      Fences may be a requirement          at some locations for
                         protection of animals     from specific hazards and for security reasons, but
                         a blanket requirement for fencing seems unjustified.

                         I hope these thoughts and suggestions arc helpful.              I  would welcome a
                  phone call at 907-345-3142 during working hours                if  there are questions or
                  comments on any of these points.

                                                                 Sincerely,
                                                                 Richard V. Sha@,r,@;J

                                                                 3 -

    Jeffrey Sloss
    740 5th St.
    Janeau, AK 99801.

    January 14, 1987

    U.S. Fish and Wildlife Service
    Attn: Division of Refuge Management
    2343 Main Interiro Bldg.
    18th and C Sts., N.W.
    Washington, DC 20240

    Re: Draft 1002 Resource Assessment Report on the Arctic
        National Wildlife Refuge coastal plain

    To Whom it May Concern:

    	As an Alaskan resident I'm deeply concerned abou the
    operning of the coastal plain of ANWR to oil and gas
    exploration. I strongly oppose the violation of Alaska's
    premier wilderness sanctuary and part of the only arctic
    coastal plain wilderness in the nation. ANWR is a national
    and worldly conservation treasure which should remain
    entirely undeveloped for the national interest.

    	I submit the following points about the Draft 1002
    Resource Assessment Report :

    	Oil and gas leasing of the coastal plain could be
    	devastating for the 180,000 (+) members of the
    	Porcupine Caribou herd that depend on the area for
    	calving and post-calving activities.

    	The reporst does not take into account the impacts of
    	oil and gas development on the entire coastal plain
    	ecosystem.

    	The issue of how enough water will be obtained for
    	drilling activities (especially in winter) is a major
    	problem apparently not dealt with in the report.

    	The cumulative effects of oil and gas development on
    	adjacent state and federal leases, native lands and on
    	the outer continental shelf are not adequately
    	addressed.

    	I oppose any trading of any ANWR lands to Native
    	Corporations or the State of Alaska.

    	Accidental spills of crude oil and other petroleum
    	products are aninevitable consequence of oil and gas
    	development and is an unacceptable threat to the
    	fragile life of the arctic tundra.

    	The disposal of hazardous waste is a serious long term
    	problem for the entire north slope which has not been
    	solved in existing oil developments, much less this one.

    	It is clearly not in the national interest to promote
    	development of the nation's only arctic coastal plain
    	wilderness, also a world-class wildlife refuge.

    	Our nation's future energy requirements can and will be
    	met by increasing conservation of energy resources and the
    	development of viable alternative energy sources, not the
    	squandering of perhaps the last energy reserves for a 19%
    	chance at a few months of oil

    	I urge that the U.S. Fish & Wildlife Service protect
    	and manage the entire Arctic National Wildlife Refuge in a
    	manner which is consistent with the conservation purposes
    	for which it was established.

    	Thank you for the opportunity to comment.

    Sincerly,

    cc. Governor Steve Cowper
        Representative Don Young
        Representative Morris Udall
        U.S. Fish & Wildlife Service, AK

                U.S. Fish and Wildlife Service                                                                        There are numerous.problems with the 1002 report. Probably the most
                Attn: Division of Refuge.Hanagement Resources                                                         glaring is that the Secretary-s Recommendations are not based on
                2343 Main interior Building                                                                           information contained In the report. The report doesn't answer
                18th and C Streets, N.W.                                                                              crucial questions about some of the impacts that would result from oil
                Washington, D.C. 20240                           February 5, 1987                                     and gas leasing and production, even though that was Its purpose as
                                                                                                                      stated in ANILCA. For example, sources for water and gravel are not
                                                                                                                      adequately discussed, nor is the disposal of hazardous waste. We
                Dear Fish and Wildlife:                                                                               pride ourselves in this country on being intelligent enough to avoid
                                                                                                                      repeating mistakes, of the past. Yet in the t002 area, we have a
                This letter contains my comments relative to the draft coastal plain                                  government agency recommending that we do just that. The Department
                resource assessment (1002 report) for the Arctic National Wildlife                                    of the Interior is doing the American public a grave disservice by
                Refuge, released November 24,, 1986. 1 will not thank you for this                                    swallowing oil company rhetoric hook, line, and sinker. To point to
                opportunity to comment, as I understand public involvement was only                                   Prudhoe Bay as a shining example of the ability of environment and
                allowed as a result of litigation successfully brought against your                                   industry to coexist in harmony is misstating the truth. The impacts
                agency by public interest groups. The Department.of the Interior also                                 of oil development activities at Prudhoe Bay havebeen inadequately
                failed to hold a public hearing in my home town of Fairbanks, even                                    studied, just as the potential impacts on the coastal plain have been
                though a wide segment of the public requested one. I find it                                          inadequately addressed by both the 1002(c) and the 1002(h) studies.
                repugnant that my tax dollars were spent In an attempt to deny me an
                opportunity to comment on a public interest Issue that directly                                       The Fish and Wildlife Service has been negotiating land exchanges In
                involves me. Please address my comments In the final 1002 report to                                   the 1002 area with private corporations for years now. Why are these-
                Congress.                                                                                             exchanges, which are all set to go, not even mentioned in the 1002
                                                                                                                      report? Are these exchanges in the public interest? I don't see how
                I totally support Alternative E, wilderness designation, as the most                                  they can be. The justification I've heard for these exchanges Is that
                responsible management strategy for the Arctic Refuge coastal plain.                                  the Fish and Wildlife Service needs to obtain the surface rights to
                This area to a wildlife refuge, not a petroleum reserve.  It has been                                 inholdings on refuges In other parts of the.state, presumably to
                protected as such since 1960, and I see no valid reason for altering                                  facilitate "management and protection" of those lands. How can you
                this wise course of protection for internationally significant                                        reassure the public of your ability to "protect" these areas for fish
                wildlife and wilderness resources.                                                                    and wildlife when you can't protect it in the Arctic National Wildlife
                                                                                                                      Refuge, one of the oldest conservation system units in the state? Not
                I feel qualified to comment on this report for several reasons.                                       only are you not protecting the wildlife and wilderness resources of
                First, I have read it in its entirety. I have also studied-the                                        the coastal plain, as to your mission, but by your recommendations you
                Baseline Reports prepared pursuant to Section 1002(c) of ANILCA.                                      ;:j,jn
                                                                                                                           blut!ngtotheir diminishment. Don't expect the public to be so
                Second, I have a Bachelor of Science degree In terrestrial wildlife                                          e       want that to Uppen elsewhere, too.
                biology from the University of Montana. Last but not least, I am a
                resident of the state of Alaska, the United States, and the world. To                                 I could go on and on about the report-a inadequacies and biases. The
                me, being a citizen means I should be Involved in assisting the                                       statements made in both the Executive Summary and the Secretary-s
                formulation of wise national policy. The destruction of the surface                                   Recommendation, relative to the area's oil potential, are skewed to
                reaources of the 1002 area in the pursuit of unknown quantities of                                    favor the highest potentials possible without mentioning their low
                non-renewable resources is Irresponsible and as such does not                                         probabilities of occurrence. The report pays some lip service to
                represent wise policy.                                                                                subsistence uses of coastal plain wildlife, but passes on rapidly,
                                                                                                                      saying that losses would be "compensated", whatever that means. The
                one of the things that disturbs me the most is that the 1002 report                                   harm that development could do to subsistence uses outside the 1002
                says development of the refuge for oil and gas is necessary in the                                    area, which are extensive, is barely discussed at all. One of the
                national interest. I find this impossible to believe, when there                                      report-a more important omissions is that it does not consider the
                seems to be absolutely no leadership in this country for energy                                       many cumulative Impacts that oil development, both in and outside of
                conservation. I don-t see many programs being implemented to promote                                  the 1002 area, will undoubtedly have on wildlife and habitats. To
                the development of alternative energy sources, either. Without                                        attempt to look at the 1002 area in isolation is ludicrous. it
                programs implemented nationwide on these two crucial fronts, which                                    resembles a doctor attempting to do a thorough physical of a person by
                could provide our country with massive amounts of energy via savings,                                 only examining is head. It can't be done.
                there can be no valid national interest argument for the destruction
                of an important wildlife refuge. "Destruction" is not too strong a
                word, as it is exactly what would happen to the coastal plain's
                wilderness values, as well as to much of its surface area which now
                supports wildlife populations.

    As a resident of the state of Alaska. I firmly believe that it is not
    in the best interests of this state, or of the nation, to explore the
    coastal plain for oil at this time. Nor do I believe that it will be
    at any future date. We must stick to our commitments, made years ago,
    to the protection of wild places. If we don't they will be gone,
    along with a part of the American soul. That is why I urge the
    Secretary to alter his recommendations in favor of wilderness
    designation, the highest and best use for the Arctic Regue coastal
    plain.

    Sincerely,

    Laurence R. Sutton
    P.O. Box 84663
    Fairbanks, Alaska 99708

    cc: Hon. J. Bennett Johnston
        Hon. Morris Udall
        Governor Steve Cowper

    P-89

    P.O. Box 80368
    Fairbanks, Alaska 99708
    February 2, 1987

    U.S. Fish and Wildlife Service
    Attn: Division of Refuge Management Resources
    2343 Main Interior Building
    18th and C Streets, N.W.
    Washington, D.C. 20240

    RE: ARCTIC NATIONAL WILDLIFE REFUGE, COASTAL PLAIN RESOURCE ASSESSMENT DRAFT

    GENERAL COMMENTS

    This letter is in support of Wilderness Designation for the coastal plain
    (1002) area of the Arctic National Wildlife Refuge. I write as a long
    time Alaskan resident with extensive experience with Alaskan wildlife and
    wilderness. I hold degrees in biology and natural resources management
    from the University of Alaska and have worked professionally for many years
    as an environmental planner and natural resource manager. My family has
    backpacked throughout Alaska including the Arctic National Wildlife Refuge.
    I know first hand the outstanding wilderness and wildlife values to be
    lost should the coastal plain be opened to oil and gas leasing and believe
    it is in the long term national interest to forego this unique wilder-
    ness resource for the short term economic gain of oil development on the
    refuge's coastal plain.

    I have carefully reviewed the Drat Arctic National Wildlife Refuge Coastal
    Plain Resource Assessment and an impressed with the devastating impact oil
    and gas development would have upon the physical, biological, and social
    environment of the 1002 area. It is evident that there are no mitigating
    stipulations which can significantly reduce the inevitable loss of wilder-
    ness and wildlife values not only within the coastal area, but also through-
    out the entire Arctic National Wildlife Refuge as a consequence of oil
    development.

    The Arctic National Wildlife Refuge is the nation's only extensive wildlife
    refuge along the Arctic coast. The Refuge was established by Congress to
    preserve the area's unique wildlife, wilderness and recreational values. The
    coastal plain of the Refuge provides essential seasonal habitat for most of
    the Refuge's species of mammals, fish, and migratory birds. It is an integral
    part of the entire ecosystem which is required by these species for survival.
    The inevitable and unavoidable consequence of oil and gas development on the
    Refuge coastal plain would be the reduction in the size and diversity of wild-
    life populations throughout the entire Arctic National Wildlife Refuge.

                                   -2-

    Congress mandated that the entire Refuge be administered for specific
    purposes defined in the Alaska Natioanl Interest Lands Conservation Act:

    1. To conserve fish and wildlife populations and habitats in their natural
    diversity.
    2. To fulfill international treaty obligations of the United States wich
    respect to fish and wildlife and their habitats.
    3. To provide opportunities for continued subsistence use by local residents.
    4. To ensure water quality and necessary water quantity within the Refuge
    to conserve the fish and wildlife populations and habitats in their
    natioanl diversity.

    The report's findign indicate that the Secretary's recommendation for full
    leasing for oil and gas development is directly opposed to the Refuge purposes
    mandated by Congress. The "Recommended Mitigation" measures (p. 145) are
    grossly inadequate and misleading. As is apparent from reading the report,
    there are no mitigation measures sufficient to retain the unique arctic
    wildlife and wilderness resources of the Refuge in view of the scope of
    habitat damage directly and indirectly related to oil and gas developement
    in this biologically rich and fragile coastal plain. If anything, the
    report understates the environmental impact of oil development because the
    cumulative regional impact of potential oil development on adjacent coastal
    and off shore areas has not been addressed. Nevertheless, even within the
    narrow focus on the study, and despite the "Recommended Mitigation", the
    report concludes:

    -"Long-term losses in fish and wildlife resources, subsistence uses, and
    wilderness values would be inevitable consequence of a long-term commit-
    ment to oil and gas development in the area." (p. 143)

    -"Oil and gas development would result in widespread, long-term changes in
    the wilderness environment, wildlife habitats, and Native community activities
    currently existing in the 1002 area, resulting instead in an area governed by
    industrial activities. These changes include displacement and reduction in
    the size of the Porcupine caribou herd as a resul to widespread and intensive
    activities throughout one-third of its core calving area, as well as through-
    out a large part of its postcalving and insect-relief areas." (P. 143)

    -"But, even with effective mitigation, herd*displacement or reduction could be
    as great as 20-40 percent." (p. 144)

    From general knowledge of the fragile nature of the arctic coastal ecosystems
    substantiated by the draft report findings, it is evident that oil and gas
    leasing and development of the 1002 coastal plan area would:

    1. -Substantially reduce or elimnate fish and wildlife populations and destroy
    or make unaccessible to wildlife extensive areas of essential seasonal habitat.

    2. -Violate international treat obligations particularly in regard to migratory
    birds, caribou, and polar bear and other marine mammals; and, by example,

    *Porcupine caribou herd

    P-90

                                                           -3-                                                                                                              -4-

                      enc ourage the expoitation of circumpolar ecosystems and wildlife resources
                      by other nations.                                                                                                Moreover, the  wilderness coastal   area of the Refuge would provide a very
                                                                                                                                       valuable baseline study area from which environmental changes resulting
                      3-Significantly reduce or eliminate opportunity for continued subsistence                                        from oil developments on other arctic areas could be measured. Mitigation
                      uses not only for residents of Kaktovik, but also for residents of the                                           measures could then be taken before there is irreparable damage to the
                      interior villages in Alaska and Canada dependent upon the Porcupine caribou                                      arctic ecosystem.
                      herd for subsistence.
                                                                                                                                       SPECIFIC RECO*2NDATIONS
                      4.-Significantly degrade water quality and quantity within the coastal
                      area required by fish, migratory birds, and other wildlife.                                                      1. The final report needs to address the "land megatrade" issue. The
                                                                                                                                       Fish and Wildlife Service is actively negotiating the transfer of ownership
                      5.-Eliminate wilderness recreational opportunities in the 1002 area and                                          of 1002 lands to Alaskan native corporations. After 1991, these lands
                      significantly degrade the recreational experience on the adjacent Refuge                                         would be available for private ownership including oil companies. Neverthe-
                      wilderness areas.                                                                                                less, the physical, biological and socioeconomic assessment of the Draft
                                                                                                                                       Report is based upon the assumption that the 1002 lands would remain owned
                      The justification given by the Secretary for the full leasing recommendation                                     and managed by the Federal government (p. 98) These assessments in the
                      is the national need for domestic sources of oil anc*as and the need to                                          Draft are invalid and should be redrafted if the 1002 refuge lands are not
                      provide for the national security. However, the Report fails to provide                                          to be under Federal ownership and control. A full disclosure is required
                      sufficient evidence that oil development of the 1002 area would provide                                          of the rationaleand the i@xtent of the land trades under negotiation.
                      oil to significantly alter the nation's dependence on foreign sources.
                      With a predicted U.S. oil demand for the year 2005 of 16.5 million barrels                                       @2. It is incorrect to assume that the impact of oil development in the 1002
                      per day, and assuming that there may be a mean recoverable value of 3.2                                          area would be similar to that of the Prudhoe-Bay oil field. There are
                      billion barrels from the 1002 areab highly speculative potential oil reserve,                                    significant physical and biological differences between the two areas which
                      (p. 169), then the 1002 area would only supply the nation with the equivalent                                    will cause the adverse impact of oil development to be much greater in the
                      of 6J months of oil. This is hardly a significant contribution to the                                            1002 area. Moreover, there have been serious problems in the Prudhoe Bay
                      nation's long-term oil needs nor to the national security.                                                       operation particularly with air, soil, and water pollutiol and hazardous
                                                                                                                                       waste disposal,which have not yet been resolved.,
                      Ot the llUU miles of  arctic coastline in Alaska, it is only the JZJ mile
                      stretch within the Arctic National Wildlife Refuge which is currently closed                                     3. The report needs to expand upon plans to secure the great quantity of
                      to oil and gas development. With potential oil and gas reserve prospects                                         water required for oil development before a meaningful assessment of the
                      along this entire coast, as well as off shore, it is irrational and untimely                                     impact on wildlife can be made. There is not sufficient water supply
                      to open the Refuge area for leasing before all other potential oil prospects                                     to support wildlife as well as the oil development in the 1002 area. One
                      are explored and developed.                                                                                      of the specific purposes defined in ANILCA for the Arctic National Wild-
                                                                                                                                       life Refuge is to ensure water quality and necessary water quantity to
                      It is evident that the underlying rationalefor the full leasing recommendation                                   conserve fish and wildlife populations and habitats in their nat-al
                      is not concern for the long-term national need for oil but, instead, for                                         diversity. Therefore; since wildlife must be given priority in the
                      short-term economic gain. A sincere national commitment to maintain a supply                                     allocation of the limited water resource of the 1002 area, where is        the
                      of domestic oil for present and future generations would mandate the immediate                                   source of water required for oil development?
                      enactment by Congress of a Comprehensive National Energy Conservation Policy.
                      Implementation of such a policy today could, by the year 2000, save an amount                                    4. The final report needs.to expand upon plans for securing the large
                      of oil equivalent to the entire assumed recoverable oil potential of the 1002                                    quantity of gravel required for oil development. The major sources of
                      area.                                                                                                            the limited gravel resource within the 1002 area are river and riparian
                                                                                                                                       areas. Removal*of gravel from these special habitats would adverelY
                      A decision to forego oil development on the Refuge coastal plain today would                                     unpact fish, migratory birds, and musk ox and other mammals. Information
                      ensure a possible untapped oil reserve for the future. With "Wilderness                                          of the location of potential gravel sources for oil       development is
                      Designation" of the 1002 area, future generations would receive a legacy of                                      needed in order to assess the extent of.the adverse       impact of gravel
                      both an untapped oil reserve and the national treasure of a unique and intact                                    extraction upon wildlife.
                      irctic wilderness. Should it -then become necessary to develop this potential
                      oil reserve, future techn6l6gicat improv6ments may permit the extraction of
                      oil and gas without the devastating impact to the environment which would occur
                      today.

                                                       -5-                                                                                                     -6-

                    5  The potential soil, water, and air pollution from oil development                                   Opening the Arctic National Wildlife Refuge to oil and gas leasing makes
                    activities has not been adequately addressed. The cumulative impact                                    as much sense as would a proposal to meIt down the Statue of Liberty
                    of small discharges of pollutants introduced into the environment over                                 for national security and for satisfying the national domestic need for
                    the life of the oil field must be considered as well as the short-term                                 a supply of copper.
                    accidental releases. Proposed stipulations for disposal of fuel, hazardous
                    wastes, drilling muds, and other wastes are grossly inadequate to safely                               There are alternative and more effective means of securing a long-term
                    remove these pollutants from the Refuge environment (p. 147) There is                                  domestic supply of oil through a national commitment to oil and energy
                    no approved hazardous waste disposal site in Alaska. Reinjection of                                    conservation.
                    wastes into permafrost is not a safe option. Little is known haw such
                    wastes might alter the thermal balanne of the permafrost, nor how such                                 'Wilderness Designation"for the 1002 area would in no way deplete the
                    wastes may migratethrough the pennafrost.                                                              domestic oil reserves which may underlie the Refuge. This potential
                                                                                                                           reserve would remain a source of oil for future generations when technological
                    6. The final report needs to address the cumulative effects upon the 1002                              advances may allow oil and gas extraction without the inevitable and devas-
                    area of potential oil development along and off-shore of the entire arctic                             tating impact on wildlife and the arctic ecosystem that would occur today.
                    coast, particularly frow Prudhoe Bay east to the Refuge boundary. Should
                    the 1002 area be opened for leasing and development with construction of                               'Wilderness Designation" for the 1002 Refuge area would leave the legacy
                    an oil pipeline link to Prudhoe Bay, oil development could be greatly                                  to future Americans of both an untapped oil reserve and an unsurpassed
                    accelerated off-shore and on adjacent state owned coastal lands west of                                unique arctic wilderness.
                    the 1002 area. The Draft Report understates the extent of habitat destruction
                    within the 1002 area since the required infrastructure would serve not only                            I urge the Secretary to reconsider his recommendation. In the long-term
                    the 1002 oil fields, but would also provide support for oil development off-                           national interest in assuring domestic oil reserves for future Americans,
                    shore. it is wrong to assume that wildlife,'such as caribou, muskox,polar bear,                        and consistent with the purposes defined by Congress for the Arctic National
                    and migratory birds displaced by habitat destruction in the 1002 area,could                            Wildlife Range, I urge the Secretary to recommend that the 1002 coastal plain
                    find suitable habitat elsewhere in view of this potential development along                            of the Refuge be designated 'Wilderness".
                    the entire arctic coastal plain. There would be no "refuge" for displaced
                    Wildlife. An overview map and plans for potential oil development along the
                    arctic coast should be included in the final report.

                    CONCIJJSION

                    The 1002 area is an integral part of the Alaska National Wildlife Refuge
                    established by Congress to protect unique arctic wildlife, wilderness and                              Dorothy H. Thompson
                    recreational values riot duplicated in any other national park, refuge, or
                    wilderness area. It is evident that the 1002 area cannot be opened to oil
                    and gas leasing without permanent loss of these values to nation. The impact
                    of oil development defies all the purposes for the Refuge defined by Congress
                    in ANILCA. The findings of the Draft Report support the concliision.that on
                    this particular coastal area, oil leasing and development and wildlife refuge
                    are not compatible land uses. The choiceis clearly wildlife refuge or oil
                    development; not both.

                    The Secretary's stated concern for national oil needs and his assurances of
                    controlled development to minimize environmental impacts is outrageous con-
                    sidering that the Fish and Wildlife Service Is actively engaged in negotiations
                    to transfer the 1002 refuge lands out of Federal ownership. The recommendation
                    to open the 1002 area to oil and gas leasing may achieve short-term economic
                    and political ends. But the potential 6J months supply of oil from the 1002
                    area would not significantly contribute to the oil needs of the nation.

                                              ZL

                     First of all 1 would like to   mention that from 'what I have                                Last but not least, I do not think it makes good.business sense
              rea-d in the report. Arctic Village   was not taken into   consideratibn.                    to develope  *any more of our oil potential, while the    oil market is
              The studied  cover the immediate area of the   .coastal-plain. It does                       unstabled, OPEC has already wasted enough of our oil      dollars.
              not cover the full range of thla Caribou migration route. Which,
              would all be affected if the herd are disturbed in at least one area.                                                                 Thank-You
                     The Caribous survival depends on their basic instinct of fear.
              Since the Arctic National Wildlife Refuge has always been a wilder-                                                                  _?Incoln Tritt
              neBs area. Any activities by man would have an enormous impact on
              their behavior. I think the studies are disturbing enough.                                                                                                  @i -7 4
                     The people in my area especially the elders,primary diet is
              Caribou meat, also as far as obtaining the food, Caribou is more
              reliable than groceries. Simply because we understand the Caribou
              a lot better than your local supermarket. We can judge thequallty
              and quantity of Caribou we need for any length of time. we can't       do
              the.same with groceries, since we are in remote area and the reliabilit
              of transportation is always questionable* also most groceries shipped
              into the village is at beat one to two weeks old. Subsistence hunting
              and fishing is our only means of obtaining fresh food.
       T             My people has a practice that has been handed down from
              generations that is the area of the killing must be cleaned after the
              animal has been butched and removed. This lessens the chance.of the are
              being contaminated and diseased being spread by scavengers that comes
              into the killing area. This insures the continued existence of a
              healthy herd. There is no way that explorations and development will
              insure this.
                     Lastly, most studies refer to positive changes from subsistence
              to cash base econouty. Usually, increase education, employment and
              health services. But there is never any mention of the negative
              changes like now, like icrease in drugs, alcohol, crimes and suicide
              rates.
                     I believe that if there is to be any kind of exploration or
              development considerations. There should also be alternatives, planned
              forall negative aspects of such activities. Since this is basically
              the last of our wilderness area nothing should be left to chance.
                                     -next page-

                                                                                                      (2) Assumptions of Industry's Environmental Responsibility

                                                                                                      Coastal plain development would cause, in my opinion, a level of
                                                                 3 February 1987                      environmental damage greater than that acknowledged in the
            U.S. Fish & Wildlife Service                                                              Report.
            Div. of Refuge hanalement Resources
            2343 Main Interior jilding
            Washington,. D.C. 202 0                                                                   The Report reform to the Inevitability of all spills. This
                                                                                                      prediction in consistent with my own observations an the North
            REs Comments an Interior's Draft 1002(ANWR) Report                                        Slope. Eve n with best intent, these spills are never adequately
                                                                                                      cleaned up and the Oability of the industry to minimize damage*
            Having lived in Alaska for the post twenty years--beforo, during,                         must be viewed skeptically.
            and after construction of the North Slope Haul Road and Trans-                            Illegal hunting, feeding, and harramoment of animals (especially
            Alaska Pipeline--I have some serious concerns regarding oil and
            gas drilling .activities on the ANWR coastal plain. Throw aspects                         boars and wolves) within reach of roads and camps in a certainty
                                                                                                      which regulations to the contrary will not prevent. This is not
            of the Draft 1002 Report particularly disturb me:                                         adequately considered.

            (1) The Economic/Goologic Analysis                                                        The oil industry, pleading It cannot afford to conform to
            Interior'a recommendation that full leasing be permitted is not                           toxic-vast* regulations, is exempted from them. Drilling
            consistent with only a one-in-five probability that oil Is                                activity an the coastal plain will inevitably lead to water and
            present in economically recoverable amounts. Furthermore,                                 :cilccontamination by toxic drilling muds, among other pollution
                                                                                                      our vs. A serious problem anywhere, the risk to unacceptably
            considering that that estimate is based on an inflated oil    price                       high in the Arctic (because of slow decomposition rates),
            C*33 per barrel), we can assume that calculations using a more                            particularly when the health of the Porcupine Caribou Hard in at
            realistic price range (*14-*19 par barrel) would yield an even                            stake.
            lover probability.

            The estimates that  the field most likely has only 600 million                            (3) Aesthetic Values
            barrels total, but  May have some six times an much, further argue                        The Report's perspective in here utterly backwards.    Both Alaska
            against opening it  to development.   Even the larger quantity                            and the oil companies want to develop fields on the Arctic coast,
            would not contribute significantly to the U.S. oil requirements                           recognizing that theme fields may have some potential.    But they
            at our present rate of consumption; the smaller in truly                                  have done so, and they can continue to do no, on fields vest of
            insignificant.                                                                            AMWR. The 1002 lands, an the other hand, represent the only
            Both the geologic and economic analyses (a 95% probability of                             portion of the high Arctic coast in Alaska or Canada which we can
            only 600 million barrels of oil; only a one-in-five chance of                             preserve free from disturbance.   I believe this opportunity is so
            finding economically-recoverable oil at all) argue in favor of                            important that it, alone, should have precluded recommendation of
            the NO ACTION or WILDERNESS DESIGNATION alternatives at this                              the fuil-lossing alternative.
            time.

            alternative, to be  the only responsible management options for
            the Arctic coastaL  plain at this time. These alternatives, while
            protecting an absolutely unique and valuable ecosystem, would
            leave ample coastal and off-whore lands open to development.
            Wilderness designation would slao be consistent with the intent
            of Congress expressed in AMILCA and in submequent'votes in the
            U.S. House to designate the coastal plain an wilderness.

            Sincerely,

            June Weinstock
            1339 6th Avenue
            Fairbanks, AK 99701
            June W.
             339 6t
          F@ @a

                  Jerry c. Wickstran                                                                                                     r&-v1IEW CrIVENTS AND POLICY RECON4MENDATIONS
                  1009 E. 26th Ave.
                  Anchorage, AK 99508                                                                                                   ARCrIC NATIONAL WILDLIFE REFUGE - DRAFT EIS
                  January 15, 1987                                                                                                                         01/15/87

                  U. S. Fish & Wildlife Service                                                                           GENERAL CCMMENTS
                  2343 Main Interior Bldg.
                  18th & C. Street N. W.                                                                                  The report is an excellent example of EIS writing, editing, and illustration.
                  Washington D. C. 20240                                                                                   ISSUES
                  ATM: Division of Refuge Management
                                                                                                                               a.  congressional designation of a wildlife refuge put wildlife in the
                  Ladies and Gentlemen:                                                                                            highest priority position, however, the decision to not place the
                                                                                                                                   ,coastal plain in wilderness must have been made due to oil and
                  Enclosed are my cuoments and raccmmendations with reUtrtj to resclviM                                            gas potential.
                  the issues of opening the Arctic National wildlife Refuge to petroleum
                  leasing and develcyrtent. These comments are based on my review of the                                       b.  The issues are  nearly identical-to NPRA issues. The NPRA court
                  do=nent and my professional experierce as wildlife and fisheries                                                 suit over subsistence was decided by the 9th Circuit court ruling
                  biologist, land and resource planner and past program manager for                                                that there had been compliance due to deletion of core calvinq
                  Bim interagency leasing and environmental studies for the National                                               areas and Teshekpkik Lake waterfowl area, and the subsistance and
                  Petroleum Reserve in Alaska (NPRN).                                                                              other stipulations.
                  The best approach that Alaska car. take to getting the refuge opened                                         c.  Complex geology of the area requires drillinq to define subsurface
                  is to take a steady thoughtful approach, tone down divisive rhetoric,                                            values. Pear and opposition to leasing on NPRA proved to be
                  look at the long teim and nationwide interests, manage the land                                                  unfounded due to little or no exploration drilling and no develop-
                  carefully and plan for ultimate restoration of the area to as close                                              ment after leasing. Also, there was no interest in the 3rd lease
                                                                                                                                   sale.
                  to natural as feasible.
                  There is no doubt pure wilderness will be destroyed. we should adMit                                         d.  The Kupanik experience is the best technically documented experience
                  that up front and offer to trade this area for inclusion of wildern-sr,                                          regarding caribou calving.   Prudhoe Bay area had no inventory in
                  elsewhere. For example, part of NPRA - e.g. Teshekpuk, Utukok Upland,                                            advance - Kuparuk is a good exanple of cooperative design develop-
                  and icy cape have had little petroleum develqmient interest and may                                              ment.
                  be trade off potentials.                                                                                     e.  Alyeska. Pipeline experience demonstrates that elevation of the
                  With regard to the caribou calving controversy, I suggest that a                                                 pipeline works for pipeline passage.of wildlife. Gravel crossings
                  owTftitment to phase in of leasing, studies and inventory in advance                                             have not been used and thus are costly and unnecessary.
                  and better communication of industry efforts and success Jul the
                  Kuparuk are essential. There shwid however be immediate leasing                                              f.  Habitat should be looked at in broad perspective, e.g. gravel pads,
                  in all of the area except area D since the issue of Oil potential                                                etc., do convert a minor percentage of one type of habitat - e.g.
                  can only be resolved by drilling.                                                                                mist tundra, hut nay diversify habitat from a comprehensive
                                                                                                                                   standpoint by varying the habitat. Gravel, roads and pads -
                  The secretary of interior's recommendation is sound. Legislation                                                 if not being used by humans probably attract a variety of species
                  should include additional long term mitigation and *nanagement                                                   including caribou which nay find insect relief or a dry resting
                  commitments from the beginning. The long term view needs to be                                                   area. They way however an an ecosystem standpoint introduce use
                  expressed.                                                                                                       pattern changes, e.g. predators having easier travel routes.
                  Sincerely,                                                                                                   g.  The worst case scenario would be for industry, after finding and
                                                                                                                                   developing a field, to find it uneconomic, e.g. Milne Point. In
                                                                                                                                   this case the wilderness would be destroyed or -severely impacted
                  Jerr@_C. Wickstran                                                                                               and no benefits accrued. The best scenerio would be for a
                                                                                                                                   massive discovery which makes it all worthwhile.
                  JCW/acr

                  cc: RDC
                      state of Alaska
                      usEw - Anchorage
                      BIM - Anchorage
                      Anchorage Board of Realtors

                    RWIEW OOMMaM                                                                                         REVIEW WHEM
                                                                                                                         DRAFT EIS 01/15/87
                    DRAFT EIS 01/15/87                                                                                   Page Three
                    Page T;@;o

                    CONCLUSION & RBOaMENDATION
                    The Secretaryls recommendation of phased in leasing is the best approach.                            SPECIFIC COMMEWS
                    This could be Improved and implemented by:                                                           PPr.E 72, TABLE 111-4
                         a.  Institution Of Off season government or industryCOST well                                   How was the price of oil determined? Vaiat will be the likelihood of
                             exploratory drilling to define values in the trade off                                      bids if the price of oil stays dom? What will be the price per barrel
                             decisions regarding development of area D. The NPRA                                         to establish minimum bidsle Are there any alternative approaches to
                             experience of government exploration uas helpful.                                           leasing that should be considered - e.g. low minimum bid and sliding
                                                                                                                         scale.royalty?
                         b.  Support for and passage of energy conservation legislation.
                             In the best of discovery circLmtstanoes the nation's energy                                 Mile these factors are not  usually a preldmirary consideration they
                             supply and balance of payments will not be corrected.                                       do became part of the decision process and thus should be explained.
                         c.  An oil Import tax with proceeds to go directly to payment
                             an the national debt. This would also provide government    and
                             industry a long term stable basis to make minimum bid,
                             royalty rate and econanic development decisions.

                         d.  Lease stipulations including a requirement that roads,
                             pads, airstrip and other physical activities which mar
                             the wilderness, be designed at the beginning to facilitate
                             rehabilitation at the end of field life, to small "w"
                             wilderness or backcomtry status. Flor example pads, excavation
                             and pits should be rounded or lenticular in shape or easily
                             reshaped to such rather than square cornered contemporary
                             engineering designs.

                         e.  Initial legislation stating the goal of restoration of the
                             area to as close to natural as possible. This would include
                             removal of all structures, obliteration, removaland cosmetic
                             treatment of all physically disturbed areas including pits,
                             berms, roads and pads. The road to the Dalton Hiqhway should
                             not become a permanent transportation Link within the refuge,
                             but could provide access to the western boundary. The qravel
                             road, while largely rehabilitated, would form a hikinq trail
                             across the coastal plain. Pictures of the restoration and
                             cleanup record on NPRA should be used to educate the national
                             public.

                         f.  Legislation establishing a jointly funded sinking or reserve
                             fund to accomplish restoration. The Federal Ckwernment,
                             State of Alaska and the oil ocapardes; should contribute a
                             minor percentage of proceeds from sales, bonuses and net
                             profits to an investment fund. If 100 years is the hypothet-
                             ical end of operations, $1,000,000 set aside at 6% compounded
                             annually for this period amounts to almost $340,000,000.

                         g.  Halting land trades witli the Native Corporations. These
                             trades, although well ii.tended, may prove to be a complex,
                             particularly litigaus impediment to expedited leasinq. Rather
                             than a land trade, I recommend a percentage of State of
                             Federal income from the sale be committed to buy out critical
                             inholdirns in conservation areas, or fund other conservation
                             needs.

                                                                                                                                                                                              F I [:E-D
                                                                                                                                                                                                SEP i 0 1984
                                                                                                                                                             4EP L
                      Jerry C. Wickstrom                                                                                                         UNITED STATES COURT OF APPEALS             PHILLIP 6. MUM
                      1009 E. 26th Ave.                                                                                                                                .  .-                     t*!.    Vi o;MILS
                      Anchorage, AK 99508                                                                                                              FOR THE NNIii"eIRCUIT
                      (907) 274-9480 Home
                      (907) 258-1711 Business
                      (907) 279-9784 Recorder                                                                             SARAH KUNAKNANA, etc., et al.,                           Nos. 83-4325
                                                     RESUME                                                                                                                               84-3623
                                                                                                                                      Plaintiffs-Appellants/
                      1956-59     South Dakota  School of Mines    Geological Engineering                                             Cross-Appellees,                             Alaska (Anchorage)
                      1959-62     South Dakota  state university - BS - wildlife MaWement
                                                                                                                          VS.
                      1962        Karluk Lake Kodiak Island - Bureau of o-ial Fisheries,
                                  Red Salmon Research                                                                     WI'LLIAM CLARK, etc., et al.,                                0 R D E R
                      1962-65     Land EKaminer Realty specialist - BLM, Fairbanks                                                    DefendantS-Appellees,
                      1965-68     Wildlife Biologist, Watershed & Range Specialist, District
                                  Safety officer, Fire control Duties - BL14. Fairbanks.                                  and
                                    First Fisheries Inventory - Brooks Range, First BIM
                                    District Wildlife Biolcgist, First Fire Control - Soil                                AMOCO PRODUCTION COMPANY, at al.,
                                    Erosion Studies & Management Recommendations.
                      1969-73     Wildlife Biologist, Fisheries Bioloqist, Recreation and                                             Intervenor-Defendants/
                                  Land Planner specialist, BIM - Winnemacca District, Nevada.                                         Appellees/Cross-Appellants.
       OD                           First Wildlife Biologist, First Fisheries Studies, First
                                    District Wide Land Plan, First Interagency IAM Plan
                                    BU4/USFWIv District Safety Officer & Defensive Driving
                                    Instructor.                                                                           Berore:     ANDERSON, SKOPIL and POOLE, Circuit Judges.
                      1973-1977   Environmental Coordinator Alaska State Office - BIN
                                    First Environmental Coordinator, Developed Statewide
                                    d-2 Alternative,d-2 EIS Writing & Review, Washington, D.C.                                        The panel unanimously affirms the decision of the
                      1977-1983   Asst. Chief and Chief NPRA - Alaska State Office, BIX,
                                  105-C Interagency Report - leadership of 6 Agencies & State                             district    court.    An opinion will be filed and available within
                                    Borough.
                                    First on Shore Competitive Lea ing Regulations, EIS &                                 .the next   several days.
                                    Program.
                      1983 -      Real Estate - Foreign Trade - LTport/Expc  )rt - Business
                                  Profession & ownership.
                                    Corporate President & Owner, Board of Realtors - Plannincl
                                    & Zoning Chairman, 1986, Vice Chairman, Anchorage Foreign
                                    Trade Zone Group - A Nonprofit Corporation.

                                                                      F I L E D                            I. OVERVIEW
               I                    UNITED STATES COURT OF APPEALS      SEP 12 1984                    1             This appeal concerns oil and gas leasing on the
                                        FOR THE NINTH CiRCUIT                                          2
               2                                                    PHILLIP B. WINBERRY                    National Petroleum Reserve-Alaska (NPR-A), a national
                                                                     CLERY4 U.S. COURT Of APPEALS      3
               3   SARAH KUNAKNANA and JEAN                                                            4   petroleum reserve located on the North Slope in Alaska and
               4   NUMNIK,                                                                             5   encompassing 23 million acres. With certain exceptions, oil
               5        Plaintiffs/Appellants,           No. 83-4325                                   6   and gas production was prohibited within this reserve
               6                                                                                                   9 to the terms of the Naval Petroleum Reserves
                              vs.                     D.C. No. A83-337 Civil                               accordin
                                                                                                       7
               7   WILLIAM CLARK,  Secretary of          n p T N 1 0 N                                     Production Act of 1976 (NPRPA).    42 U.S.C. SS 6501-6507.
                   the Interior, and THE                                                               a
                   UNITED STATES DEPARTMENT OF                                                         9   In 1980, Congress amended the NPRPA to provide for "an
                   THE INTERIOR,
               9                                                                                           expeditious program of competitive leasing" in the NPR-A.
                        Defendants/Appellees,                                                        io
             10                                                                                            Id. at S 6508.
                             and                                                                     11
             11                                                                                                      Pursuant to this directive, an expedited leasing
             12    AMOCO PRODUCTION COMPANY1                                                         12
                   ARCO ALASKA, INC.; GETTY OIL                                                            program was developed. The program involved five annual
                   COMPANY; SHELL OIL COMPANY;
             13    and TEXACO', INC.,                                                                      sales of approximately two mIllion acres each. The Bureau of
                                                                                                     14
             14         Intervenor-                                                                        Land Management (BLM) published a Final Environmental Impact
                        Defendants/Appellants.                                                       15
             15,                                                                                     16    Statement (FEIS) concerning oil and gas leasing in the NPR-A
             16             Appeal from the United   States. District Court                          17    and subsequently issued its Record of Decision.      Lease Sale
             17                       for the District of Alaska                                           831, challenged here, was the first offering under this
             18  ' The Honorable James M. Fitzgerald, District Judge, Presiding                      18
                                  Argued a d ap iop@ pay 16, 1984
                                           Ne'cide     / 4                                           19    scheme.
             19    Before:   ANDERSON, SKOPIA.,  and POOLE, Circuit J udges.                                         Appellants Numnik and Runaknana and the     City of
                                                                                                     20
             20    J. BLAINE ANDERSON, Circuit   Judge:                                                    Barrow, amicus here, sought a preliminary injunction blocking
             21              Sarah Kunaknana and Jean Numnik, two Inupiat                            21    the lease sale. They noted that one of the primary
             22    Eskimos, appeal a district court judgment denying their                           22    objectives of the Alaska National interest Lands Conservation
             23    challenge to certain oil and gas lease sales by the Bureau of                     23
                                                                                                           Act (ANILCA), enacted just weeks before the NPRPA was
             24    Land Management within the Alaska National Petroleum Reserve.                     24    amended, was *to provide   the opportunity for rural residents
             25    We affirm.                                                                        25
             26                                                                                      26

                                                                                                                                       -2-

               I  engaged i n a subsistence way of life (the opportunity] to do                                           The district court entered its decision, finding in
               2  so." 16 U.S.C.. 5 3101(c). They contended that the BLM had                               2   favor of the government on the merits. The court enjoined
               3  failed to make certain determinations required by the ANILCA                             3   execution of the leases, allowing appellants to file in this
                  after concluding the lease sale would result in a significant                                court for injunction pending appeal. An injunction pending
               4                                                                                           4
               6  restriction of subsistence use by     the native Alaskans.                               S   appeal was entered on January 13, 1984, permitting lease
               6  16 U.S.C. 5 3120.                                                                        6   issuance but enjoining any exploratory drilling or any other
               7             A preliminary injunction issued on July 19, 1983,                                 lease activity that would substantially and adversely affect
                                                                                                           7
                  after the  district court concluded that the BLM had failed to                           8   subsistence use. This expedited appeal followed.
               9. make the required findings. The court permitted opening and                              9   11. DYSCnSSTON
                  accepting of bids by the BLH but enjoined execution of leases                                           Appeilants Kunaknana and Numnik contest the
            10                                                                                           10
            11    pending an expedited trial on the merits. Such a trial was                             11    validity of the district court's review. They argue that the
            12    required by the NPRPA, 42 U.S.C. 5 6508. Of the 81 tracts                              12    court considered impermissible materials, improperly limited,
                  offered for lease in Sale 831, bids on 17 were accepted.                                     discovery and erred in determining that the BLM's rule-
            13  1                                                                                        13
            14               Trial on the merits commenced December 12, 1983,                            14    making procedure complied with section 010 of the ANILCA.
            15    and the full administrative record was submitted to the        .court                  15    Intervenors Amoco Production Company, et al., cross-appeal,
            16    without objection. Counsel for the government announced that                           is    contending that Kunaknana and Numnik lack standing due to a
            17    its position had changed bince the preliminary injunction                              17    failure to participate meaningfully in     .the administrative
            is    hearing. 96 asserted that a mistake had induced the                                    Is    process preceding Lease Sale 831.
            19    government's initial position due to an assumption that the                            19               A.   Rtnnding
            20    BLM had made a determ3nation of significant restriction in                             20               Traditionally, a party has standing to seek
            21    subsistence use. Admittedly, such a conclusion would require                           21    judicial review of agency action where the challenged action
            22    further findings under 16 U.S.C. 5 3120(a).        At trial,                           22    has caused "injury in fact* to an interest 'arguably within
                  counsel asserted that the BLM had, in fact, concluded just                                   the zone of interests to be protected or regulated by the
            23                                                                                           23
            24    the opposite and offered a *Modified Record of Decision* to                            24    statute' allegedly violated.      91-1-a of Ca                11ock,
            25    explain this determination.                                                            25    690 P.2d 753, 776 (9th Cir. 1982) (quoting Agsociation of
            26                                                                                           26

                                               -3-                                                                                          -4-

    Data Processing Service Organizations, Inc. v. Camp, 397 U.S.
    1
    150, 152 (1970). Under this requirement, plantiffs must
    2
    show not only a "distinct and palpable" injury but also a
    3
    "fairly traceable" causal connection between the claimed
    4
    injury and the challenged conduct. Warth v. Seldin, 422 U.S.
    5
    490, 501 (1975).
    6
    	We find that the traditional standing requirements
    7
    have been met by appellants. The purpose of the ANILCA was
    8
    to protect those North Slope natives who, like appellants,
    9
    lead a subsistence lifestyle. 16 U.S.C. $$ 3111-3112. Oil
    10
    and gas development within the area would directly affect the
    11
    availability of those subsistence resources and limit those
    12
    areas in which subsisence activities could be conducted.
    13
    	We disagree with intervenor's claim that appellants
    14
    should be deprived of standing due to a failure to
    15
    participate meaningfully in the administrative process. See
    16
    Vermont Yankee Power Corporation v. National Resources
    17
    Defence Council, 435 U.S. 519 (1978). See also City and
    18
    County of San Francisco v. United States, 615 F.2d 498 (9th
    19
    Cir. 1980) and Seacoast Anti-Pollution League v. Nuclear
    20
    Regulatory Commission, 598 F.2d 1221 (1st Cir. 1979). The
    21
    rationale of Vermont Yankee has been applies in those
    22
    instances in which an interested party suggests that certain
    23
    factors be included in the agency analysis but later refuses
    24
    the agency's request for assistance in exploring that party's
    25

    26

                          -5-

    contentions. Id. at 553-554. Such a party will not be
    1
    permitted to challenge the agency decision on the ground that
    2
    it failed to consider the necessary alternatives. Id. The
    3
    district court declined to establish a broad rule which would
    4
    require participation in agency proceeding as a condition
    5
    precedent to seeking judicial review of an agency decision,
    6
    and we affirm.
    7
                    B. The Modified Record of Decision
    8
    	Appellants take issue with the district court's
    9
    inclusion of the Modified Record of Decision (MROD) as a part
    10
    of the administrative record on review. Characterizing the
    11
    MROD as an impermissible post hoc ratioinalization of an
    12
    agency decision, made in response to litigation, appellants
    13
    contend that consideration of the MROD was improper. See
    14
    Citizens to Preserve Overton Park v. Volpe, 401 U.S. 402, 420
    15
    (1971); accord Camp v. Pitts, 411 U.S. 138, 142 (1973) (per
    16
    curiam). We disagree.
    17
    	Agency actions are reviewed by examining the admin-
    18
    istrative record at the time the agency made its decision.
    19
    Overton Park, 401, U.S. at 419-420. Agency documents prepared
    20
    during and in response to litigation are generally excluded
    21
    from this review. Id.; accord ASARCO, Inc. v. U.S.
    22
    Environmental Protection Agency, 616 F. 2d 1153, 1158-61 (9th
    23
    Cir. 1980).
    24
    	The general rule prohibiting post hoc rationaliza-
    25
    tions is not without exceptions. In Overton Park, the
    26

                            -6-

    P-101

                 Supreme Court expressly outhorized the trial court to allow                         'not disclose the factors that the Director considered or

                 the Secretary of Transportation to 'prepare formal findings"                        this] construction of the evidence.90 CR 111 (citing
                 in order to "Provide an adequate explanation for his action'                        Overton ftrk, JA  at 419-20). It appears that without
              3                                                                                   3
              4, which the court could then review. 401 U.S.   at 420. The                        4  benefit of the explanation of agency action set forth in
                 Ninth Circuit has also addressed the scope of the district                          the MROD, the trial court would be prevented from determining
              5                                                                                   5
                 court's review of an agency decision, adopting the more                             whether the agency action was within the scope of its
              6                                                                                   8
                 .enlightened* approach which permits "explanation" of agency                        authority. We find, therefore, that the inclusion of the
              7                                                                                   7
              a  decision-making. ARARC 0, 616 F.2d at 1159.  In ASARCO, we                       8  MROD in the district court's review was both permissible and
              9  held that '[a) satisfactory explanation of agency action is                      9  necessary
           10    essential for adequate judicial review, because the focus of                  10              C. Section 910 Complianeg
           11    judicial review is . . . on whether the process employed by                   11              The appellants argue that the Department of
                 the agency to reach its decision took into-consideration all                        Interior failed to comply with Section 810.of the Alaska
           12                                                                                  12
                 the relevant factors.0  Id.1 accord Overton Park, 401 U.S. at                       National interest Lands Act of 1980 in holding Lease Sale
           13                                                                                  13
                 402; Bunker Hill Co. v- Engfronmantal Protection Ageneve 572                        831. 16 U.S.C. 5 3120. They contend that the department
           14                                                                                  14
           15    F.2d 1286, 1289 Oth Cir. 1977). The court limited the                         is    failed to accurately identify the section's requirements and
           16    purposes for which information outside the administrative                     16'   consequently failed tc fulfill those requirements. We
           17    record may be considered to use as Obackground information*                   17    disagree.
           is    and for "ascertaining whether the agency considered all the                   is    ,        The Naval Petroleum Reserves Production Act of 1980
           19    relevant factors or fully explicated its course of conduct                    19    requires the Secretary of the Interior to implement *an
           20    or grounds of decision." ASARCO, 616 P.2d at 1160. Finally,                   20    expeditious program of ccmpetitive leasing of oil and gas
                 the court observed that additional information should be                            in the National Petroleum Reserve in Alaska." 42 U.S.C.
           21                                                                                  21
           22    explanatory in nature, rather than a new rationalization of                   22    5 6SOO. The statute did not give the Secretary the
                 the agency's decision, and must be sustained by the record.                         discretion not to lease; instead, the Secretary was given the
           23                                                                                  23
           24    Id. at 1159-60.                                                               24    discretion to provide rules and regulations under which
           25             In the instant matter, the district  court noted                     25    leasing wQuld be conducted and was to develop restrictions
           26    that "without the [MROD1, the record befora this court will                   26

                                          -7-

                  necessary to mitigate adverse impact on the NPR-A. .1d.                                                  (1)  gives notice to the appropriate
               2  Expedited judicial review was an additional concern of this                                                   State agency and the appropriate
                                                                                                   2                            local committees and regional
                  legislation. Ld.                                                                                              councils established pursuant
               .3                                                                                  3                            to section 8051
               4             Shortly before the NPRPA legislation, Congress                        4                       (2)  gives notice of, and holds, a
                  enacted the Alaska National Interest Lands Conservation Act.                                                  bearing in the vicinity of the area
               5  Its purpose was to preserve scenic Alaskan lands, to maintain                    5                            involved; and
                                                                                                                           (3)  determines that (A) such a
                                                                                                   6
                  wildlife species and undisturbed ecosystems and, as                                                           significant restriction of sub-
               7                                                                                                                sistence uses is necessaryr con-
                  previously noted, to protect the interests of individuals                        7                            sistent with sound management prin-
                                                                                                   a                            ciples for the utilization of the
               9  engaged in subsistence lifestyles. 16 U.S.C. 5 3101. In                                                       public lands, (B) the proposed
                                                                                                   9                            activity will involve the minimal
                  order to assure the continuation of subsistence lifestyles,                                                   amount of public lands necessary to
            10                                                                                     10                           accomplish the purposes of such use,
                  Congress indicated that residents so engaged should play a                                                    occupancy, or other disposition, and
            11                                                                                     11                           (C) reasonable steps will be taken
            12    part in the administrative structure. 16 U.S.C. 5 3111-@                                                      to minimize adverse impacts upon
                                                                                                                                subsistence uses and resources re-
                  Section 810 of the ANIDCA, 16 U.S.C. 5 3120, provides the                        12                           sulting from such actions.
            13              -
                  procedural mechanism which insures this loc Ial input into the                   13          'Agency interpretations of a statute are entitled to
            14
                  administrative decision-making process.,                                         I.4. great deference and should be upheld so long as they are
                             Section 810, Public Law 96-487, 16 U.S.C. S 3120,                     15 reasonable.. Western Pioneer, Inc. v. United staten, 709  . F.2d
                  provide s inIrelevant part as follows:                                           16 1331, 1335 (9th Cir. 1983)v Unlted States v. Boyden, 696 F.2d
            17               (a) In determining whether to withdraw,                               17 685, 688 (9th Cir. 1983).  "This traditIional acquiescence in
            is                   reserve, lease, or otherwise permit.the use,                      Is administrative expertise is particularly apt* when.an agency
            19                   occupancy, or disposition of public lands
                                 under any provision of law authorizing such                       19 *has played a pivotal role in -setting (the statutory)
                                 actions, the head of-the Federal agency
            20                   having primary jurisdictionover such lands                        20 machinery in motion." Ford motor Credit Co- v. Milhollin.
                                 or his designee shall evaluate the effect
            21                   of such use, occupancy, or disposition on                         21 444 U.S. 555, 566 (1980) (guating Norwegian Nitrogen Products
                                 subsistence uses and needs, the availability
            22                   of other lands for the purposes sought to                         22 Co. v. United_SjAt&j, 288 U.S. 294, 315 (1933)). As we noted
                                 be achieved, and other alternatives which
            23                   would reduce or eliminate the use, occupancy,                     23 in Western Pioneer, 709 F.2d at 1335:
                                 or disposition of public lands needed for
            24                   subsistence purposes. No such withdrawal,                         24          Our task then, is not to interpret the
            25                   reservation, lease, permit, or other use,                                     statutes as we rhink beat, but rather to
                                 occupancy or disposition of such lands                            25          inquire whether the (agency's) construc-
            26                   which would significantly restrict sub-                                       tion was 'sufficiently reasonable" to be
                                 sistence uses shall be effected until the                         26
                                 head of such Federal agency--

                                            -9-

             I              accepted.   "To satisfy the standard   it is                                   agency's discretion the particular details concerning when,
                            not necessary for a court to find that                                     1
                            the agency's construction was the only                                         where, and how leasing within the NPR-A shall occur.
             2              reasonable one or even the reading the                                     2
             3              court would have reached if th:,question                                                  A second provisi .on of Section 810(a) requires.the
                            initially had arisen in a Judi &I proceeding."                             3
             4              (citations omitted.)                                                       4   agency to hold public hearings and make specific findings
             5              The plain terms of Section 610(a) require the                                  concerning significant restrictions upon subsistence uses
                                                                                                       6
             6   director or his designe  .e, here the BLH (agency), to                                a   caused by federal decisions involving Alaskan public lands.
             7   'evaluat.so three factors co ncerning the d -eci sion to issue oil                    7   16 U.S.C. 5 3120(a). The second sentence of this provision
             8   and gas leases involved in the programmatic leasing      sale.                        8   suggests that these procedures are necessary only if the
             9   These factors include:    (1) the effect of leases on                                 9   agency first concludes that the contemplated action may
                 subsistence uses and needsl (2) the availability of      other                            significantly restrict subsistence uses.      Id. To read the
           10                                                                                        10
           11    lands for oil and gas leasingl and (3) other alternatives                                 sentence otherwise would require that the     agency follow
                 which would reduce or eliminate the amount of land taken away                             these procedures any time it contemplated     Xederal action
           12                                                                                        12
                 from subsistence uses. 16 U.S.C.-S 3120(a). This provision                                concerning any public lands in Alaska and     would completely
           13                                                                                           1           -
                                                                                                     13
           14    must be read in light of section 6508 of the NPRPA which                            14    ignore the phrase "which would significantly restrict
           is    requires the agency to grant some oil and gas leases in the                         15    subsistence uses." The Inference to be drawn from this
           16    NRP-A. 42 U.S.C. 5 6508. The only wother lands' and 'other                          16    language is that Congress intended a two-step process:
           17    alternatives" that the agency could have considered without                         17    first, the agency determines whether the contemplated action
           18    violating section 6508 would be other tracts within the NPR-A                       18    may significantly restrict subsistence use; if it may, the
           19    which could be leased for oil and gas.                                              19    ageftcy must comply with the notice and hearing proc*edures.
                            As the district court observed, when the first                                 This construction of the statute is a reasonable one, relying
           20                                                                                        20
           21    sentence of section 810(a) is read in light of 42 U.S.C.                            21    on the plain meaning of the words of the statute.
                 5 6508, it requires the agency to evaluate the effects upon
           22                                                                                        22              Pursuant to this procedural scheme, the agency
                 subsistence needs of leasing the particular tracts tenta-
           23                                                                                              first defined "significant restriction' and then conducted an
                                                                                                     23
                 tively selected and to compare the relative desirability of                                                                                   stence
           24                                                                                        24    extended,analysis of the "significance" of subsi
           26    leasing other tracts within the NPR-A. This leaves to the                           2S    restrictions, as to both subsistence resources and user

           26                                                                                        26

                                                                                                                                      -12-

                1   access. MROD at 1, 5-25. This analysis allowed a finding of                         1   included the cumulative impacts of both the entire expedited
                2   no significance only if there were 'no" reductions or only                              leasing program and Lease Sale 831. This is evidenced by the
                    a                                                                                   2                                                  M              M
                3    slight" reductions or disruption of resources or user access                           fact that the agency remcved certain Jlldl., such as Caribou
                                                                                                        3                                                           009@
                    to those resources. MROD at 5-6. As a result of its                                     @-alving areas and Black Brant molting 7r-eas, from potential
                    analysis, the agency determined that neither the programmatic                            W@@                -               -
                                                                                                            leasing and included stibulations reqardinq subsistence use
                    leasing program nor Lease Sale 831 would significantly
                6                                                                                           in the leases. The agency imoosed these vrotective lease
                                                                                                        6                       a         -
                    restrict subsistence user. Appellants argue that this                                   c4nditions and stipulations in order _tQ oreclude
                7                                                                                       7
                8   decision was capricious and should be overruled.     5 U.S.C.                       8   restrictions on subsistence   uses that might be caused bv
                    5 706(2)(A).                                                                            activity permitted by the NPR-A leasing prolram,
                9                                                                                       9                                 1@
                              To make this finding the court must consider                                             Appellants argue that the agency adopted an
              10              whether the decision was based on a consideration                       10
                              of the relevant factors and whether there has been                            overly restrictive definition of the term *significant
              11              a clear error of judgment. Although this inquiry
                              into the facts is to be searching and careful, the                            restriction upon subsistence uses.      This.term is not
              12              ultimate standard of review in a narrow one.                            12
              13             .-The court is not empowered to substitute its                                 defined by.Section 810(a); consequently, the     Jagency has
                              judgment for that of the agency.                                        13
                                                                                                            defined it as (1) a reduction in the availability of
              14    Citi7pnq to Preserve Overton Park v. Volpe# 401 U.S. at 146;                      14
              15    southpagt Alaska Conspryaklon Council v- Watson, 697 F.2d                         is    harvestable resources caused by decline in the population of
                                                                                                            subsistence resourcesi (2) a reduction in the availability
              16    1305, 1312 Oth Cir. 1983). Additionally, we must consider                         16
                                                                                                            of resources, caused by an alteration in their distribution
              17    whether the agency articulated a rational connection between                      17
              Is    the facts found and the choice made. State of California                                or location throughout the NPR-A; and    (3) the limi .tation of
              19    v- Watt, 683 F.2d 1253 (9th Cir. 1982).                                                 access for subsistence harvesters. Arguing that the term is
              20           . We find that the agency examined the relevant                            20    analogous to the finding of "significant effect on the
              21    factors and did not error in its judgment. The district                           21    quality of the human @nvironment* of the NEPA provisions,
                                                                                                            appellants urge adoption of a broader definition. They argue
              22    court's decision includes findings of fact which evidence an                      22
                                                                                                            that a *restriction' is a much higher threshold than that
              23    articulated rational connection between the fActs found (by                       21
                                                                                                            required to trigger a NEPA procedural process and so should
              24    the agencyl and the choice made. Id. fir& CR Ill                                  24
              25    (Decision of Record). The agency's decision-making process                        25.   be prohibited.

              26                                                                                      26

                                              -13-                                                                                      -14-

                          We agree with the district court's finding that the                       1   appellants' expert witnesses; limitation of discovery; and
             I   agency definition of significant restriction' is within the                        2   improper resolution of the MROD issue on summary judgment.
             2   range of reasonable meanings which the words of the statute                        3             As noted earlier, trial court review of agency
             3   permit.  Loma L -                            , 705 F.2d 1123,                      4   decision-making is generally limited to the existing admin-
             4   1126 (9th Cir. 1983). The term 'restrict' may well be a                            5   istrative record. Overton Park# id. This record may be
             5
                 higher threshold than that required by NEPA, however, we   need                    6   supplemented with testimony from the officials who partici-
             6   not determine in this case whether the agency's general                            7   pated in the decision explaining their action or by formal
             7   definition survives tb. arbitrary and capricious standard in                       a   findings prepared by the agency explaining its decision.
             8   all cases or whether it is not at a high enough threshold.                         9   ASARCO, 616 F.2d at IIS9-60. Outside information is admis-
             9   we hold only on the record before us that the application of                     10    sible only for limited purposes. Id. at 1160-61. 5_01 Runkgr
             10                                                                                         B@LU, 572 P.2d at 1292 (outside evidence admitted to furnish
                 that definition to the proceedings here.and the actual                           11
             11  analysis that led to the decision reached was not arbitrary                      12    background information)l fi= &1= Association of Pacific
             12                 and that the proceedings undertaken                                   I Finharig -.,v- rnvironMpntal Protpetion Agency, 615 F.2d 794,
                 and capricious                                                                   13
             13                                                                                         811 (9th Cir. 1980) (outside evidence used to ascertain
             14  sufficiently complied with the requirements of section BID.                      14    whether all relevant factors  were considered). 'Iflechnical
                 We note also that the BLX explicitly retained the right to                       15
             15                                                                                         testimony . . . elicited for  the purpose of determining the
                 impose additional restrictions, including mitigation                             16
             16                                                                                         scientific merit of the-[agency's) decison," is not generally
             17  requirements during the permitting process to protect                            17
                 subsistence resources. The definition is within the range of                     Is    admissible. ASARCE, id. at 1161.
             is  meanings which could be given and is consistent wi   .th the                     19              Our review leads us to conclude that the    expert
             19  ourposes of the legislation and we affirm. 14-                                   20    witness affidavits offered by appellants, CR 68, are the type
             20            D. iggstriction of h2ppllantg' Case                                    21    of 'technical testimony" prepared "for the purpose of
             21            Kunaknana and Numnik contend that the    district                      22    contesting wthe scientific merit" of the agency's analysis
             22  court erred by unreasonably restricting the presentation    of                   23    which we rejected in ASARCO. The district court's decision
             23                                                                                         to exclude these documents on review is affirmed.
                 their case. Specifical:iy. error is alleged in    the district                   24
             24  court's refusal to consider the affidavits of two of                             25              Appellants' contention that curtailment of dia-
             25                                                                                   26    covery forced presentation of their case on an in   complete
             26
                                                                                                                                   -16-

               1  record lacks merit. The order staying discovery permittel
               2  deposition of BLM officials Jerry Wickstrom and JA-Pq rilliam
               3  and did not limit the areas of inquiry. CR 67. In view of
               4  thestatutory mandate to expedite, 42 U.S.C. 5 6508, we do
               5  not find that the district court abused its discretion in
               6  foreclosing discovery and setting an abbreviated briefing
               7  schedule.   O'grian v. Sky Chefs, Inc.., 670 F.2d 864, 869 Ot  h
               8  Cir. 1982).
               9             Finally, Kunaknana and Numnik claim that the
             10   district court improperly resolved this matter on motion for
             11   summary judgment. we disagree. our review reveals a trial
             12   by the court on December 12, 1983, followed by a resolution
             13   of the con-tested fact issues in a Decision of Record entered
             14   December.20, 1983. W. find,that the district court conducted
                  the proper inquiry in the acceptable format.
             Is
                  III. CONCLUSION
             17              For the foregoing reasons, we
                            AFFIRM.

             19

             20

             21

             22

             23

             24

             25

             26

                                             -17-

                                                                                                      Yet, on such information, Congress is expected to end the
                                                                                                      area's status as the last protected Arctic coastline in the
                                                                                                      U.S.

              January IS, 1987                                                                        As others have indicated, the executive summary seems to
                                                                                                      bias the report's results in favor of development. It quotes
                                            Dr. William D. Witherspoon                                the prediction of na 95-percent chance of the 1002 area
                                            2897 Country Squire Lane                                  containing more than 4.8 billion barrels of oil..." yet
                                            Decatur, Georgia 30033                                    omits that this in supposed to be contingent on there being
                                                                                                      at least one commercial discovery, the chances of which are
                                                                                                      assessed as 19 percent. The summary also exaggerates the
                                                                                                      report's optimism by quoting estimates of oil in-place
                                                                                                      rather than economically recoverable oil.

                                                                                                      But the summary is not the only problem. in my opinion, the
                                                                                                      precise-sounding figures themselves are &t bgA& seat-of-the
              Director, U.S. Fish and Wildlife Service                                                pants estimates, and at worst &ft overly optimistic
              Division of Refuges                                                                     interpretation. Here are some key points in the report that
              Room 2343 Main Interior Building                                                        trouble me:
              18th and C Sts., NW
              Washington, DC 20240                                                                    1.  For most of the area, only one seismic horizon has been
                                                                                                      mapped -- the "basement top" reflector (p.58). By not
                                                                                                      mapping the objective reservoir intervals, the authors avoid
                                                                                                      using the only data they have to determine whether reservoir
              Re: Draft Coastal Plain Resource Assessment, Arctic                                     intervals terminate on unconformities, disappear due to
              National Wildlife Refuge, Alaska                                                        facies changes, or thin laterally. All of these factors are
                                                                                                      real possibilities in the area.

      00                                                                                              2. Likewise, by mapping only the top of basement, the
              Dear Sirs:                                                                              authors tacitly assume that closure on their propects
                                                                                                      remains the same at the (higher) stratigraphic levels of the
              I would like to take this opportunity to comment on the                                 objective intervals. This is rarely the case in a fold and
              draft Arctic National Wildlife Refuge (ANWR), Alaska,                                   thrust belt: typically structures at higher levels are
              Coastal Plain Resource Assessment. I understand the deadline                            smaller due both to tighter fold geometries and interruption
              for such comments is January 23, 1987.                                                  by steeper thrust faults. This increases my skepticism about
                                                                                                      the two exceptionally large structures in the northeast part
              I feel qualified to comment on geologic aspects of the                                  of the 1002 area, IS and 19 (Figure III-1), which
              report because of my previous work in this area. From                                   undoubtedly contribute significantly to the optimistic sacle
              December 1980 through March 1984, 1 worked as Research                                  of the reserve estimaten.
              Geologist for one of the oil companies active in the area.
              My major responsibility was to provide regional geologic                                3.  At the root of the first two problems is evidently lack
              .support for exploration in the ANWR and adjacent offshore. I                           of access by the authors to the sophisticated seismic
              met with some of the authors of the report in Menlo Park and                            processing available in the industry. The seismic data as
              I visited the Coastal Plain of ANWR in 1963 as part of a                                shown in plate 5 is of poor quality. Combined with the only
              surface geology study team.                                                             moderate grid spacing, this contributes to an overall lack
                                                                                                      of confidence in the map on which the reserve estimates
              I respect both the geologists of U.S.G.S. and my former                                 depend so heavily.
              colleagues in the industry. However, I would be quite
              surprised if any of them would expect a decision-maker in                               4.  According to the report, 50% of the estimated oil is
              industry to lease a tract or drill a well based on the    depth                         contained in the "Folded Ellesmerian/Pre Missisippian" play
              and quality of the analysis presented in the report.                                    (p. 68). Yet the report itself raises many doubts about the

                continuity of these units into the study area. For example,                                 Second, one of the properties of a successful province like
                Figure 111-5 presents the interpretation that the most                                      Prudhoe Bay that one hopes will carry over into adjacent
                attractive reservoirs in this sequence (including the                                       areas is the source rock. But the report appears to put
                Prudhoe reservoir equivalents) are missing in the 1002      area                            hopes to rest that the pebble shale and older possible
                                                                                                            source rocks for Prudhoe could have generated oil in the
                due to erosionl                                                                             1002 area (page 62).
                On the same page, the report states, "However, their
                northward extent [into the 1002 area from exposures in the                                  I understand and to some extent sympathize with the desire
                mountains] depends on several factors, such as the rate of                                  of my former colleagues in industry to meet the challenges
                                                                                                            of the ANWR and particularly to provide additional geologic
                truncation on the unconformity, the amount of northward                                     control to assist current exploration efforts in the
                transport by thrust faulting, and the possible existence of                                 adjacent offshore.
                downdropped fault blocks north of the truncation edge, about
                which we have little direct information .... Ifmost of the
                Ellesmerian rocks are missing in most of the 1002 areai the                                 However, I think it does the American people a disservice to
                assessment number would be reduced considerably." (p. 66).                                  represent the area as a sure-fire success and solution to
                                                                                                            future energy problems. The area is already in service to
                                                                                                            the public: let it remain as the last prisiine Arctic
                One could add that these strata if present could lack                                       coastline and a preserve for future generations.
                porosity due to their history of greater deformation and
                overburden than at Prudhoe Say.
                5* The report states that potential source rocks for     the                                Sincerely,
                Eilesmerian play include fine-grained Ellesmerian rocks
                (believed to be gas-prone) and "possibly the Hue shale"
                (p.66). The doubt about the Hue is presumably because other                                 Bill Witherspoon
                rocks may intervene between it end any Ellesmarian
                reservoirs and because in any case "charge from above" is
                not generally considered a strong scenario. Since the Hue is                                cc:
                the only potential source rock the report confirms to be
                oil-prone (p. 62), there is doubt that the Ellesmerian play                                 Hon. Pat Swindall
                could be oil-bearing.                                                                       Hon. Lindsay Thomas
                My opinion is that the report does not contain enough depth                                 Hon. San Nunn
                for a geologist to responsibly conclude that "The area is                                   Hon. Wyche Fowler
                clearly the most outstanding oil and gas frontier remaining
                in the United States" (Executive Summary, page 1). The
                report adds considerably to our earlier understanding of the
                area, but the overall impact on the attractiveness of the
                area is negative in my view, for at least two reasons.
                First, the data confirms that the told and'thrust
                architecture as seen in the Brooks Range indeed
                characterizes the whole area. Notwithstanding encouraging
                results in areas such Idaho and Montana, thrust belts are
                among the most challenging of frontier areas. They present
                formidable obstacles to seismic processing and
                interpretation. They can be characterized by rapid and
                unexpected facies changes, often poor porosity, thermal
                regimes that tend to make them gas provinces, and small size
                and complex evolution of trapping structures.

                                                                                                                   that over half of my clients have been over 50 years old and
                                                                                                                   a few have been over 70, most all of moderate means.)
                                                    February 3, 19[37                                                    Thus my comments are not just based on academic or
                                                                                                                   doctrinaire opinion, but come from a close personal
               TO:      U.S. Fish and Wildlife Service                                                             involvement in this land and its wildlife that are unique in
                        Attention: Division of Refuge Management Resources-,                                       the USA.   I expected the Department of Interior to hold this
                        2343 Main Interior Bldg.                                                                   Refuge in trust for me and future generations. I feel that
                        113th and C Sts., N.W.                                                                     this trust has been betrayed by the Secretary's
                        Washington, D.C. 20240                                                                     recommendations.
                                                                                                                         I also challenge the Secretary's recommendations as
               FROM:    ViLrginia H. Wood                                                                          stated in Chap. VIII of the Draft Assessment on the 1002
                        1819 Muskox Trail                                                                          area because I believe that his assumptions equating Prudhoe
                        Fairbanks, AK 99709                                                                        Bay developments with those that would take place in the
                                                                                                                   1002 area are false; that they do not address the important
               RE:      Zomments on Arctic National Wildlife       Refuge Coastal                                  potential impact of ancillary infrastructures that opening
                        Plain Resource Assessment                                                                  the entire area to oil drilling and production would
                                                                                                                   require--including airfields, roads, more pipelines, waste
                        I wish to have the following  comments inserted in the                                     disposal and construction and maintenance camps; that it
               record.                                                                                             does not deal with the fact that, contrary to the Prudhoe
                                                                                                                   Say site, the 1002 area is extremely lacking in the water
                        First, let me state my bias openly and                                                     and gravel resources necessary for construction and
               straightforwardly. I admit to having a strong emotional                                             operation; and that the recommendations contradict the
               attachment for the Arctic National Wildlife Refuge; and          I air,                             conclusions of the Department's own biologists in the
               strongly opposed to any legislation by Congress which would                                         report.
               open up the coastal plain (the 1002 area) of this saoctuary to                                            On Page 6 it is stated:
               the oil indtistry for oil and gas leasing and development.                                                "Long term losses in fish and wildlife resources,
               This violate5 the very reason for which the refuge., was                                            subsistence uses, and wilderness values would be the
      _16      created by Congress in 1960--to preserve the area's unique                                          inevitable consequence of a long term committment to oil and
               wildlife, wilderness and recreational values".                                                      gas development, production and transportation ... Oil and gas
                        The Alaska National Interest Lands Conservation Act                                        discovery will lead to industrial development. There will
               (AMILCA)  added other purposes for the Refuge-                                                      be pressure to use this area as a base to serve exploration
                        1. To conserve fish and wildlife populations and                                           and development on the continental shelf, or to intertie
                         habitats in their natural diversity.                                                      with projected oil and gas developments an the outer
                        2. To fulfill international treaty obligations o@ the                                      continental shelf.
                         U.S. with respect to fish and wildlife and their                                                Oil and gas development will result in widespreadq long
                         habitats.                                                                                 term changes in wildlife habitats, wilderness environments,
                        3. To provide opportunities for continued subsistence                                      and Native activities. Changes could include displacement
                         us-as oy local iv%iiabitants.                                                             aiid reduction in the Bizw of the Porcupinie cariLL-L he.'d
                        4. To insure water quality and necessary quantity                                          (presently estimated at 180,000 animals) ... Geography
                         within the refuge.                                                                        apparently limits the availability of suitable alternate
                                                                                                                   calving or insect relief habitats for the herd".
                        My first statement is influenced by having personally                                            The Secretary's recommendation states that wildlife
               Inown the late Olaus Murie, the highly regarded pioneer of                                          habitat impacts would be "mitigated", but there are no
               arLtic biological research     in Alaska, who first conceived of                                    details on just how this could be done.         (My suspicion is
               a preserve that would set aside a representative area of                                            that mitigation would be waived if this put an economic
               arctic
                        Alaska large enough to preserve wildlife and habitat                                       burden on the oil companies.)
               for posferity.    tie envisioned a preserve large enough to                                               The assumption that the Prudhoe bay experience proves
               encompass a range of landscapes from the polar 5ea and                                              that oil drilling can take place on sensitive arctic habitat
               tundra. plains to the arctic alpine arid the boreal 40recftS@                                       with  little or no impact an wildlife or the environment is
                        I took part in the preliminary hearing held ir,                                            challenged by such highly-regarded biologists as Dr. David
               Fairban@is, Alaska which eventually led to the eALablishment                                        Klein of the University of Alaska, who has done extensive
               of the Arctic National Wildlife Range in 19&0.          For the pi@_@it                             research On caribou in Alaska and Canadal as well as on the
               11 years I have guided commercial backpacking and river                                             wild reindeer of Scandinavia.       He has said,
               rafting trips in various parts of the present Arctic                                                      "It's still an open question, but the Prudhoe Bay oil
               Natior.al Wildlife Refuge.      (I woulti lil,.e to interier-1. here                                field is such a mass of pipelines, roads, and facilities,

                                                                                                                                                     2

                                                                                                           clients from going anywhere near an oil field or using the
                without any good planning for caribou that the area appears                                infrastructure facilities, yet under the present status of
                largely lost to their use."                                                                the Refuge, or under wilderness statuss we could rove at
                     A news article in the Fairbanks Daily News Miner, dated                               will.
                Feb. 1, 1987, stated:                                                                           There is tight secrecy and security at.Prudhoe Bay.
                     "The state Department of Environmental Conservation                                   One is not allowed out of the terminal at Deadhorse Airport
                says oil and gas exploration and production produces                                       without a security clearance. This is not a national
                hazardous wastes, but the industry has been exempted from                                  defense restriction.    It is imposed by the oil companies.
                federal and state laws governing its management and                                        They also refuse to disclose drilling data that would help
                control."                                                                                  determine if the disposing of hazardous waste in dry wells
                     The article goes on to cite specific instances    of                                  in the arctic is feasible and safe.
                hazardous waste in the North Slope oil fields and the                                            The 125 mile coast of the Arctic National Wildlife
                difficulties involved in dealing with it.     Industry                                     Refuge is the only shoreline closed to oil drilling in the
                retaliated by saying that complying with regulations would                                 arctic.   There are still vast areas open to oil exploration
                be "economically devastating".                                                             and development in other parts of the North Slope c,+ Alaska,
                     'he colleyed justification for opening tne whole IvO2                                 and elsewhere in the state. The oil that might be in the
                area for unlimited oil drilling and production in direct                                   1002 area of the Refuge will still be there when we have
                contradiction of the stated purposes for which the Refuge                                  squandered the crude in other places and so will the caribou
                was established is that new oil fields are needed for                                      and wilderness. Let us then decide our priorities.
                "energy independence" and "national security".                                             f@q AbOvemmll4 I would prefer Alternative 0 - "no action"o
                     The environmental risks this portends hardly seem worth                               @ realizing that refuge status did not protect the 1002
                the approximately 196 days worth of recoverable oil possible                               area from a Secretary of Interior who chose to recommend
                at optimistic estimates based an the report's own figures of                               that it be opened up for full leasing and oil development, I
                the amount of daily use of oil predicted by the year 2005                                  feel I must apt for Alternative E--wilderness designation--
                divided into the amount.of oil that might be recoverable.                                  to give it adequate protection.
                     Especially when oil lease auctions on Alaska state
                lands are attracting few.bidders nowadays; when Arco and
                other oil companies are abandoning their present leasen
                because oil glut prices do not justify paying the reilt on
                them; and when oil companies in Alaska are closing down                                                              Signed
                viable wells because oil revenues are too low. Also by                                                                       Virgihia H. Wood
                administrative decree for some reason the oil reserves                                                                       1819 Muskox Trail
                stored for emergency use are now kept at a low percentage of                                                                 Fairbanks, AK 99709
                Lheir capacity.
                     Projected monetary returns from projerted 1002 area
                wells, should they become a reality, are based on a price of
                oil at 433 per barrel, a price not predicted by economists
                during the next decade.
                     V@aaping tha 55 mph speed limit, im%jlementing "'he
                compulsory energy efficient ratings an appliances, and
                mandating higher mileage per gallon ratings for new
                Lars--all of them recommended for elimination by this
                administration--would save as much oil as the 1002 area dmav
                produce at the given odds.
                     Nor does "national.security" seem a convincing reason
                to sacrifice the wilderness integrity of the coastal plai.,i
                of the Arctic National Wildlife Refuge when there is also a
                strong push to sell Alaska oil to Japan; or when our major
                threat to national security appears to be a "mistake" that
                might start a nuclear war, and the terrorist bombings and
                teL@Jng of hostages--none of which can be deterred by Alaskan
                oil.  I also recall that in our last "war" vie were defeated
                by peasants on 4oot and bicycles while we had all the oil we
                could possibly use for our military machines.
                     It is rather an irony that opening up the 1002 area
                to full oil drilling and production would preclude me and my

                                              3

                                         :5.C

                                                    WAV
                                                 ly,    @izat- Z@a

                                                            AeRC-

                                                                                                         Ole

                                                 e:d r

                                                         ZVI.

                                           ..........

                                                  IRE

                                                                                                                                                                                                                                                                                            'Ad
          ca

                                                                                                                                                                                                                                                                              -JW4,t@.o

                                                                                                             OR

                                                                                                                                                                                                                                                                          At)
                                                                                                                                71

                                                                                                                                                                                                                        .........

                                                                         . .... .                                             lee, ZA.-W,

                               oll

                           e0o"

                                          71

                            irl

                                       I,R
                                            Aly 414

                                                                                                                             USFWS. 14 Jan.'87, p. 2

              1031 S. Scoville Ave.                                                                                          A carefui reading of the draft assessment makes it clear that the facts as
              Oak Park, IL 60304                                                                                             presented in It support selection of "Alternative V. I do not believe that
              14 Jan.'87                                                                                                     any other conclusion can be drawn from an analysis of the information presented
                                                                                                                             in it as a whole if the public interest is uppermost in your mind. The
                                                                                                                             physical [pp. 15-231 and biological [pp. 15-38) environment of the ANWR is
                                                                                                                             without parallel in the United States and the traditional values of the Inuit
              U.S. Fish and Wildlife Service (USFWS)                                                                         eskimo people living in the area are dependent on its maintenance (other Native
      Attn:   Division of Refuge Management                                                                                  peoples in Alaska and Canada are also dependent on migrating animals that utilize
              U.S. Department of the Interior (USDI)                                                                         the �1002 habitat). These are clearly threatened by any oil exploration and
              2343 Hain Interior Bldg.                                                                                       development activities. Such activites are simply incompatible. Furthermore,
              18th and C Sts., NW                                                                                            there is no guarantee that any commercially recoverable oil even exists in
              Washington, DC 20240                                                                                           the ANWR. USDI is willing to jeopardize the ANWR and the animals and people
                                                                                                                             who depend on it for a 19.0% "marginal probability" of finding any "economically
              Dear Persons:                                                                                                  recoverable oil somewhere in the 1002 area" (p. 721. Even If oil was found, It
                                                                                                                             would literally be a drop in the bucket that would only marginally extend a
                   Subj: Comments on Dratt Coastal Flain Resource Assessment                                                 failed policy. The real answer is to shitt to sustainable and environmeliLaIlY
                           Arctic National Wildlife Refuge, Alaska (ANWR).                                                   compatible alternative energy programs rather than attempting to delay the
                                                                                                                             inevitable and degrading the environment in the process.
              This letter constitutes my comments on your draft coastal plain resource assess-
              ment for the ANWR dated November 1986 and prepared under your program in response                              At least at some times in the past the USFWS took its professional and legal re-
              to �1002 of the Alaska National Interest Lands Conservation Act (ANILCA).          I                           sponsibilities more seriously than it apparently does now.        Recognizing the
              cannot emphasize too strongly my believe that the public interest in this matter                               potential for*adverse effects that proposed energy development activities in
              can only be well-served by designation of the entire ANWR (including, most                                     the same area of the ANWR posed at that time (i.e., the arctic gas pipeline).
              emphatically, the critical.coastal.habitat of the 11002 area) as wilderness                                    the USFWS Issued a position paper in which it was pointed out that such develop-
              (i.e., splection of your "Alternative V as Identified on.pages 141-142 of                                      ment was fundamentally "incompatible with the basic values of the Range" in 1977 and
              the draft assessment).                                                                                         that the USFWS should oppose It because it had a "legal responsibility to preserve
                                                                                                                             the (ANWR's) integrity". As stated in that position paper (copies of this two
        -A    Regrettably, I must take issue with the contention in the draft assessment                                     page position paper and L.A. Greenwalt's one page cover memo of 21 Jun.'77 are
        CA    that the USDI's proposal to lease the entire 61002 area for oil and gas explora-                               attached to these comments);
              tion and development rests on any analysis of the facts of the matter [p. 11.
              The word analysis Implies reasoned examination. To the contrary, it has been                                         "The U.S. Fish and Wildlife Service is opposed to the proposed gas
              evident from the beginning that the USDI had a strong precommitment to oil                                           pieplin@ routing across the Arctic National Wildlife Range or, alter-
              exploration and development anywhere, at anytime, and at any cost to the public.                                     natively, along its northern or western borders. We do not believe
              Unfortunately, such precommitment is consistent with the historical way in                                           that the long-term National interest would be served by committing
              which the USDI has operated as well as the policy of President Reagan's Adminis-                                     this unique area to development for short-term benefit when its out-
              tration.   It preceeded any research or information gathering activities actually                                    standing values for wildlife and wilderness would be forever lost.         To
              conducted in carrying out 91002 of the ANILCA.       Indeed, it colored how the                                      protect our public trust and to exemplify our good conscience as con-
              USDI has gone about conducting its research and managing the A14WR during the                                        cerned ecologistsg we must object strongly to any development which
              past six years.                                                                                                      would threaten the int@g-rity of the ArcLie iuatio,,al Wildlife RanAe
                                                                                                                                   (emphasis added)."
              I was present in Kaktovik and the ANWR during part of the time the USDI was
              carrying out its �1002 program in the first four years after passage of the                                    As noted in the draft assessment [pp. 45-461:
              ANILCA. From interactions with USDI officials, it was quite clear what was
              taking place and that the decision to condone full leasing for any oil explora-                                      "The Arctic Refuge is the only conservation system unit      that protects
              tion and development desired by the oil industry had already been made. This                                         in an undisturbed condition, a complete spectrum of the      various arctic
              was obvious at the first scoping meetings in Kaktovik when USDI officials refused                                    ecosystems in North America (emphasis added)."
              to provide interested citizens with requested information or answers to highly
              pertinent questions and it has been equally obvious to the present time when                                         "Most of the major wildlife species occurring on the refuge (caribou,
              it has taken legal action to make this comment period possible.        It was also                                   moose, brown bears, wolverines, wolves, muskoxen. polar bears. and
              obvious when the USDI facilitated the "land swap" that allowed Chevron to drill                                      numerous species of birds) use 1002 area habitats for all or part of
              on the coastal plain and approved the use of tracked vehicles.for surface seismic                                    their life cycles (calving, nesting, breeding. staging).       The 1002
              work when less damaging technology that could obtain the same information was                                        area is the most biologically productive part of the Arctic Refuge for
              readily available.    Both of these actions can be interpreted as frustrating                                        wildlife and is the center of wildlife activity on the refuge. Caribou
              the expressed will of Congress.                                                                                      migrating to and from the 1002 area and the postcalving caribou aggre-
                                                                                                                                   gation offer an unparalleled spectacle."

             USFWS, 14 Jan.'87, p. 3                                                                                   USFWS, 14 Jan.!87, p. 4

             Some of the admissions regarding expected adverse impacts on species which depend                         would then become precisely how much damage.   For example, is the Porcupine cari-
             on coastal habitat in the 11002 area of the ANWR that appear in the draft assess-                         bou herd to be reduced by 20 or 40 percent (or somewhere in between)? Human systems
             ment are summarized below for emphasis:                                                                   (both engineered and regulatory ones) are Imperfect. Even under the best of cir-
                                                                                                                       cumstances with well-intentioned people. you can expect equipment to fail and
                  1. There would be a major change in distribution of both that portion                                regulatory systems not to accomplish their assigned tasks.   Such problems tend to
             of the central arctic caribou heard using theA1002 area and the Porcupine                                 occur more frequently in the arctic than in more temperate climates.   The wide-
             caribou herd.  The sum of loss of calving habitat, barriers to free movement.                             spread environmental noncompliance that took place during construction of the
             disturbance, stress, and "other factors" would "cumulatively" reduce both avail-                          trans-Alaska oil pipeline system is a classic example. We know of a number of
             able habitat and habitat values on remaining aras and "could result in a major                            significant, adverse environmental impacts that occurred during that project (e.g.,
             population decline and change in distribution of 20-40 percent" (p. 112). The                             fish kills from large oil spills and sedimentation) and the full impact of it is as
             �1002 area provides critical habitat for the Porcupine caribou herd. estimated                            of yet unknown. The ANWR Is too precious to allow it to be damaged for any reason
             to consist of as many as 180,000 animals (p. 1051. This risk alone should be                              let alone one that may be a "pipe dream" pushed by people who place personal greed
             enough to swing the decision against any further oil exploration and development                          about the public Interest.  It should be remembered that once upon a time there was
             activities in the ANWR.   It is unacceptable.                                                             an Infrastructure pushing for exploration and development of the "tremendous" oil
                                                                                                                       reserv;s bnelilved to exist in what was then called National Petroleum Reserve No. 4
                  Z.  It is predicted that "Major negative effects upon the muskoxen pupulatiun"                       (NPR-4 , o A asks's north slope (e.g., Senator Jackson of Washington, who no doubt
             could also occur from oil development, on the order of "a change in distribution                          received his information from the oil industry and Alaska commercial interests, once
             or decline affecting 25-50 percent of the population" [p. 114).                                           opined that there were 100 billion barrels of oil waiting to be tapped in NPR-4).
                                                                                                                       After spending something on the order of one -billion dollars of public money to
                  3. Although "only a few polar bears" might be excluded from their traditional                        drill deep, dry holes we seem to have laid that fantasy to rest.
             denning areas, it is acknowledged that this "would be a moderate impact" because
             biologists "believe that the Beaufort Sea population can sustain litte, if any,                           I strongly urge that the USDI change its position and recommend wilderness designa-
             increase in mortality" without a significant population decline [p. 1181.                                 tion for the �1002 area.  The entire ANWR should be protected to the highest level
                                                                                                                       possible and such incompatible uses as oil exploration and development should
                  4.  Although the cumulative effects of direct and Indirect habitat loss,                             not be allowed there. Your consideration of these comments would be appreciated,
             disturbance, and direct mortality might only result in "a reduction in the                                but it would be even more appreicated if the USDI would take them to heart and
        a    Banks Island population (of snow geese) or change in distribution of an average                           act accordingly. I also request that you provide me with copies of the final
       _L    of 5-10 percent" a reduction in snow geese annual staging in the 91002 area "by                           assessment, the required response to comments, and the final decision in this
       C)    almost 50 percent" could occur [p. 122).                                                                  matter.

                  5.  According to the draft assessment, a number of other adverse impacts                             Sincerely,
             are likely on various mammal, bird, and fish populations in the 51002 area
             but, with the exception of possible "moderate" declines in the golden eagle
             population it is hoped that the adverse impacts will either be "minor" or can
             be reduced to "minor" levels through mitigating measures (pp. 105-126).     In                            G.M. Zemansky, Ph.D.
             this regard, It should be remembered that reliance upon mitigating measures is
             not always found to be justified and that the cumulative impact of a series                               Attachment
             of "minor" impacts may be highly significant.
                                                                                                                       cc: Selected Members of Illinois Congressional D@.legaLiun
             The people living in Kaktovik value the natural resources of the ANWR very   highly
             and their traditional lifestyle is dependent on them. What does the USDI propose
             for them? As acknowledged in the draft assessment, they are likely to suffer
             cumulative adverse effects through "reduced availability of subsistence resources",
             "disruption of traditional subsistence use sites, and likely psychological
             effects" which, as a whole, are classified as "a major adverse effect" [pp.
             126-129]. The people of the north slope (including Kaktovik) have already suffered
             substantial disruption as a result of other oil exploration and development activi-
             ties. This disruption has been accompanied by increases in alcohol and drug abuse.
             We cannot in good conscience allow more such disruption. If we do, what this says
             about our values is self-damning.

             I have lived and worked part-time In Kaktovik and the ANWR for eight years. I am
             an engineer whose profession is environmental protection. It is my firm believe
             that we cannot afford to risk the ANWR. If you give the "green light" to oil ex-
             ploration and development in the 11002 area damage will occui. The only question

                  IV I-
                 UNITED STATES -;0%`EP"ENT
                 Memorandum
                                                                                                                                               STATEMENT OF POSITION OF THE
         To          Service Directorate                              DATE:                                                            U. S. FISH AND WILDLIFE SERVICE ON THE MATTER
                                                                               JUN 2 1 JW7                                           OF A GAS PIPELINE ROUTE FROM PRUDHOE BAY, ALASKA

         FROM        Director
                                                                                                                            To date, no cooperative land-use plan among State, Federal, and Native
         SUBJEcr:    U. S. Fish and Wildlife Service Position on Proposed Arctic                                            land owners has been established for the Arctic slope of Alaska. In its
                     Gas Pipeline Across the Arctic National Wildlife Range, Alaska                                         absence, the history of development in this region has been one of
                                                                                                                            commitment to National defense and the petroleum industry. As a result
                                                                                                                            much of this area has been degraded to varying degrees, most prominently
                                                                                                                            by thousands of miles of seismic trails laid out in checkerboard patterns
                     As you may know, the President is to make a determination of the need                                  across the tundra, and by airstrlps, drill.ng pads, acce-s r-ad1s,
                     for, and possible routing of, a natural gas pipeline system from the                                   and discarded equipment scattered across the coastal plain. More degrada-
                     Prudhoe Bay area of Alaska to the contiguous United States. This                                       ation will ensue with increasing exploration activities on the National
                     decision is to be made by September 1, 1977, unless the President                                      Petroleum Reserve.
                     Utilizes the option provided by the Congress, which would permit a
                     delay in issuance of the decision for up to 90 days after September 1.                                 Betwien the Canadian border and east of the Canning River lies the Arctic
                                                                                                                            National Wildlife Range, managed by the U.S. Fish and Wildlife Service
                     This decision will be a difficult one, with many sensitive factors to                                  with the paramount objective of perpetuating the wildlife and preserving
                     be considered. One of the more controversial routes proposes to cross                                  the delicate Arctic wilderness habitat. The natural conditions within the
                     the Arctic National Wildlife Range with a 48 inch pipeline that would                                  Arctic National Wildlife Range. with but few exceptions. have been
                     transport the gas, via the Mackenzie-Delta and Valley, through Canada,                                 preserved as the single remnant of the vast Arctic slope
       _P            to the Midwpstern States for ultimate delivery both east and west of                                   of exploration and development. The Arctic National Wildlife Range is
                                                                                                                                                                                      of Alaska free

                     the Rocky Mountains.
       -4                                                                                                                   the last unspoiled area of its kind in the entire Northern Hemisphere.
                                                                                                                            It is a biologically continuum of essentially unaltered arctic and subarctic
                     The Service has developed a clear position on this pipeline route, as                                  habitats, from the arctic lowlands and foothills, across the Brooks Range,
                     indicated in the attached statement.                                                                   and onto the forested northern plateau.
                     You or your staffs may be asked about the view the Service takes,and                                   Establishment of the Range resulted from wide-ranging support from noted
                     the general interest in this subject may generate press inquiries of                                   conservationists9 scientists, and many others, who more than two decades
                     Your offices. The Position taken, that of opposing the crossing of                                     ago recognized its intrinsic value for wildlife and wilderness. The
                     the Arctic Range by a gas pipeline, is based upon the fact that such   a                               establishing order declares the purpose of the Arctic National Wildlife
                     crossing is clearly not compatible with the basic purpose of the Arctic                                Range to be the preservation of unique wildlife, wilderness, and recrea-
                     Range and, therefore, must be opposed by the Service.                                                  tional values. A gas pipelina through or irinediately skirting the Rarge
                                                                                                                            and the probable ensuing developr.ent are clearly contrary to t" mandat:?d
                     This position statement will be used to portray the Fish and Wildlife                                  purpose of this order. Such activity would destroy wilderness values and
                     Service's position on this subject, and should be your source document                                 irretrievably disrupt many wildlife populations and their habitats.
                     for dealing with inquiries and in making your own responses to questions
                     about the issue. For additional information. if needed, you may contact                                All the Range's fish and wildlife, including the polar bear, muskox, Dall
                     Burkett Neely, Division of Refuges, Washington, 0. C. (Telephone No. 202-                              sheep, barrenground grizzly bear. and peregrine falcon. is vital to th,-
                     343-4047 ). Mr. Neely is the FWS's coordinator for this project.                                       natural interpIN of ecological forces. Of particular concern is the welfare
                                                                                                                            of the Porcupine caribou herd, a major international resource which is
                                                                                                                            vulnerable over a vast area because of its migratory behavior. Experience
                                                                                                                            with the Arctic, Forty-mile, and Nelchina caribou herds, and with herds
                                                                                            O-ec                            in Siberia. show human disturbances and/or developments on the traditional

                     Attachment

                               Buy U.S. savi"Ji Bondt Rrgsdarly an the Fay"U Savinp Fian

                                                 2

                   range of caribou to be a principal factor disrupting the population
                   dynamics of this species. The ultimate consequence has been a decline
                   in herd size. A gas pipeline through the Arctic National Wildli,fe Range
                   would cross the herd's traditional calving grounds in Alaska as wellas
                   the Yukon Territory.
                   The Dempster Highway, scheduled for completion in 1977, crosses the
                   herd's crucial wintering grounds. The combined impacts from these
                   developments and the legical extension of activities from them would
                   undoubtedly cause a major reduction in the size of the Porcupine
                   caribou herd.

                   The U. S. Fish and Wildlife Service is opposed to the proposed gas pipeline
                   routing across the Arctic National Wildlife Range or, alternatively, along
                   its northern or western borders. We do not believe that the long-term
                   National interest would be served by committing this unique area to
                   development for short-term benefit when its outstanding values for wildlife
                   and wilderness would be forever lost. To protect our public trust and to
       'P          exemplify our good conscience as concerned ecologists, we must object
                   strongly to any developmeni which would threaten the integrity of the Arctic
                   National Wildlife Range.
       00
                   Since there are alternative routes available to transport Prudhoe Bay gas,
                   to market, the U.S. Fish and Wildlife Service opposes the Arctic Gas Pipe-
                   line route in that it is incompatible with the basic values of the Range.
                   It is our legal responsibility to preserve the integrity of the Arctic
                   National Wildlife Range.

                                                                                        General Comment Letters (R)

                                                                                                                                                                      Page

                                                              Veria R. Vancuren                                                                                        R-   I
                                                              Gillie Sebastian                                                                                              1
                                                              Sharon Silberstein                                                                                            I
                                                              John R. Howe         ...................................                                                      2
                                                              John C. Stout, Jr        . ............................................................................................3
                                                              John McGauvran, North Dakota Farm Bureau                          ............................................4
                                                              Sarah James                                                                                                   5
                                                              Wilbur M. Mills                                                                                               8
                                                              William H. Skelton                                                                                            9
                                                              Dan LaPointe, Maine Farm Bureau Association                       ........................................... 9

                                                              William J. Mulligan, Genesee Valley Regional Market Authority                          .................  10
                                                              Kevin D. Ott, National Association of Manufacturers                       .................................. 11
                                                              William P. DuBose, National Ocean Industries Association                           ....................... 14
                                                              Nell Burnside, Interriational Union of Operating Engineers                        ........................ 17
                                                              Felix Hess, Bethel Native Corporation                 .......................................................... 18
                                                              John E. Barker, ARMCO Inc               . ......................................................................... 20
                                                              William T. Blair, Ohio Chamber of Commerce                      ....................... .....- ............. 21
                                                              Judy Hall Alaback, Juneau Audubon Society                       .............................................. 22
                                                              Burnell R. Roberts, Mead Corporation.,                 ......................................................... 23
                                                              John C. Datt, American Farm Bureau Federation                        ........................................ 24

                                                              Jacob Ahgook, Nunamlut Corporation                    .......................................................... 25
                                                              Scott W. Reed         .................................................................................................. 26
                                                              George S. Mickelson, State of South Dakota                      .............................................. 28
                                                              John Devens, City of Valdez             .......................................................................... 29
                                                              Alvin H. Fleetwood, Alaska State Chamber of Commerce                             ......................... 30
                                                              David A. Bricklin, Washington Environmental Council                        ................................. 30
                                                              William H. Curtis, Puffin Diving & Consulting                  ............................................... 32
                                                              Mack Hudson, Alaska Controls, Inc                 . ............................................................ 32
                                                              Alaska Concerned Citizens              ............................................................................. 33
                                                              Jack C. Jordan         ................................................................................................. 33

                                                              Bernard L. Marsh         .............................................................................................. 34
                                                              Pearl Crouse       ..................................................................................................... 34
                                                              Charlotte W. O'Brien          ........................................................................................ 35
                                                              Lynn Mills     .......................................................................................................... 35
                                                              Alvita M. Porter       ................................................................................................. 36
                                                              South Carolina Concerned Citizens                  .............................................................. 37
                                                              Sharon Clark Gaskill, Madison Audubon Society, Inc                        . ............................... 37
                                                              Stevan Bosanac          ................................................................................................ 38
                                                              Tom Lewansid         ................................................................................................... 39

    Attention: Division of Refuge Management

    I urge you to recommend that the coastal plain of the Arctic
    National Wildlife Refuge in Alaska be opened to petroleum
    exploration and development. The production of oil on the
    arctic coastal plain would help limit America's growing
    dependence on importe oil. And, the petroleum industry has
    demonstrated that petroleum operations are compatible with
    preserving the arctic environment.

    Name   									Action Alert Give A New Year Gift To Wildlife?
    										Sign and Mail These Coupons Today!!

    										Deadline: January 30th:
    										To: Secretary Donald Hodd
    										Rm. 6151
    										Department of the Interior
    										Washington, DC 20240

    										Dear Secretary Hodd,

    										I object to the proposal to allow oil drilling in the Arctic National Wildlife Refuge.
    										This fragile arotic wilderness is the home of the last great herd of North American
    										caribou. Oil drilling and         activities would deter the caribou from their calving
    										areas, disrupt the rich diversity of arctic wildlife that exists thers, and damage the fragile
    										arctic      of the      . The amount of                  would not significantly affect
    										our         security, nor would it in any way compensate for the environmental damage
    										inflicted. I want this        part of our natural heritage preserv    generations to
    										come. I strongly urge you to not allow any development occur in this area. Pleas
    										include my letter in the public record.  Thank you.

    										Sincerely.

    										Signed

    										Name and Address 15       Lane, Mill Valley, CA
    										Sharon Silberstein          94941

    Street 5613 Hayter Ave.
    Lakewood, Calif 90712
    City    State     Zip Code

    I am against ANWR leasing.

    Attention: Division of Refuge Management

    Gillie Sebastian
    Name

    Rt 1 Box 247
    Street

    If someone could figure out a meter for the
    Sun, the oil and electric companies would get busy.

                 U.S. Fish and Wildlife Service                                                              "fringe types") are against It. I suspect these "fringe
                 Attn: Division of Refuge Management Resources                                               types"  are the people living the traditional way, the
                 2343 Main Interior Building                                                                 "subsistence-users" who depend on caribou for mlai. Another
                 18th and C Streets. N.U.                                                                    friend who has lived in Kaktovik and Arctic Village off and
                 Washington, D.C.    20510                    1/15/87                                        an for Years told me that the mayor of Kaktovik is publicly
                                                                                                             in support of exploration, but privately has grave
                 To Whom it May Concern:                                                                     misgivings about it. He said the mayor said he's afraid to
                                                                                                             come out with his true opinion because he's afraid of
                     I am writing you as   an Alaska resident opposed to oil                                 causing trouble In the community.     And I understand the
                 and gas exploration in the Arctic National Wildlife Refuge.                                 people of Arctic Village are largely opposed to exploration
                 I strongly feel it would be In the national interest to                                     in ANWR because of what it will do to the caribou.      All this
                 designate ANWR a wildilcuris area. for many reasons, so many                                just to suggest that you look carefully at whirb interest
                 I hardly know where to begin ...                                                            groups within the native community are saying whal. And
                                                                                                             consider what the social costs will be when the oil money (a
                     The amount of oil and gas the government says might come                                small sum. Probably, relative to the short-term profits of
                 0ut of ANUR's coast plain is    so small It doesn't luralify.                               the oil companies) starts pumping in and ripping their
                 the cost to wildlife and the overall beautiful wildacagis of                                communities apart. the way other Big Money has done in other
                 that place. And it bases its economic arguments as to the                                   parts of Alaska.
                 value of the oil on future oil prices that seem to me to be
                 much-lau-bish.    And where will the water to drill                                           Finally (and this is the most difficult Point to express)t
                 exploratory wells come from up there--the lakes are frozen                                  is It really in the national interest to eliminate most of
                 during the winter and pumping it in from the sea would be                                   the last stretch of wild arctic coastline in Alaska for a
                 really damaging, I think.                                                                   relatively few day's supply of oil? All the rest of that
                                                                                                             coast is open to oil development. I think the time has
                     It a13.qZCj me that the government has done so much lately                              come--I hear it in the national media and from my friends
                 to stop national energy conservation programs and other                                     and family in the lower 148--when a critical number of
                 programs that would develop alternative, less damaging                                      Americans are realizing that the "mental health" of the
                 sources of energy while pushing ahead with oil development                                  nation (if that's the right way to say it) depends an
                 in areas like ANUR which are so valuable for so many other                                  keeping the last few wild places on the North American
                 reasons.  This seems so short-sighted and politically                                       continent as wildactiall.   Over and over again people below
                 motivated--and JhCfiai&0i[1g to our national security in the                                have said to me: "Oh, you live in Alaska.     I don't think
                 future, when there will be even less oil and we'll halia-in                                 I'll ever get up there.
                 conserve and use other sources of energy.                                                   that-InGfi-n-lbace-"    I get the feeling when they telT me
                                                                                                             that that they're thinking of their own sanijy, and of
                    What about the    20-40 Percent decrease in the Porcupine                                keeping the opportunity open for their children and their
                 caribou herd, the 25-50% decline in the muskoxen                                            childrens' children to see wild Places. really natucal
                 population. the 50% decline in the area's snow geese, and                                   places so they can get a perspective an human society and
                 the significant declines In other wildlife populations                                      maybe just get away   from It for a while.    I don't think of
                 predicted by the INterior report?    I just don't understand                                myself as an "environmentalist" opposed to all development;
                 how that kind of destruction can be Justified for the                                       as an Alaskan I am now benefiting Personally from oil
                 relatively small amount of oil that mak come out of the 1002                                development at Prudhoe Say.    But I see development   in ANUR
                 area. I keep thinking of the buffalo, the grizzly bears, the                                as a had-deal for. Alaska as we)) as the nation, an
                 whales, and so on.  When will it end?                                                       unnecessary, foolish, short-sighted sacrifice of a      national
                                                                                                             treasure. I just hope Congress gets the message In     time that
                     I understand from a friend who is a computer consultant
                 working at Prudhoe and who was at the recent hearings on the
                 ANUR report in Kaktovik, that the natives there are                                                       Sincerely,
                 saciag5ly-Aimidej an the issue of whether or not to allow
                 exploration in ANUR, contrary to what is reported (at least
                 in the local Paper here in Juneau, which is a cautious,
                                         owned by someone in Florida) in the                                                           \JJoh1kW we
                 knee-jerk rag at best.                                                                                                     n - H.
                 media. Natives with strong commitments to and good                                                                     6087 Thane Rd.
                 positions in the corporations up there are for it; natives                                                             Juneau. AK. 99801
                 with less Power and money (my friend referred to them as

                                        JOHN C. STOUT, JR.
                                        PRACHTRU CZNrU HARM TUW=
                               Lq3 P&ACHTEM STRW, NX ATLANTA. GEORMA 30004M
                                                                                                          U.S. Fish a Wildlife service
                                                     January 12, 1987                                     ATTN: Division of Refuge Management
                                                                                                          January 12, 1987
                                                                                                          Page Two

                      U. S. Fish & Wildlife Service                                                       would do great injustice to ourselves and to future
                      ATTN: Division of Refuge Management                                                 generations to substantially damage such a unique
                      2343 Main Interior Building                                                         resource for short-term gain. There is no critical
                      18th & "C".Streets, N. W.                                                           oil shortage now.   In fact, we are wallowing in oil
                      Washington, D. C. 20240                                                             and doing everything but conserving it. One day we
                                                                                                          will pay a price for that, too, just as we will pay
                                Re: Arctic National Wildlife Refuge                                       for leasing the Arctic National Wildlife Refuge for
                                                                                                          oil exploration.
                      Dear Sir or Madam:
                                                                                                                     The coastal plain of,this refuge should
                                Please be advised that I am strongly                                      be designated as a wilderness area  *  @t should not
                      opposed to opening up the Arctic NationaF Wildlife                                                                        tion.
                                                                                                          be.opened up for oil and gas explora
                      Refuge for oil and gas exploration. This refuge
                      was set aside for the protection of wildlife,                                                  I am sending a copy of t is letter to
                      including the principal calving grounds of one    of                                elected representatives in Congress. I am askin
                      the largest caribou herds in the world. it is    also                               ii-cii -of them to Co=sponsor legisla-EfUnto inciud!
                      a critically important habitat for a number of                                      the Arctic National Wildlife Refuge and its coastal
                      other rare and endangered species, such as golden                                   p-ra-1-n-in the national wilderness preservation
                      eagles and polar bears. Endangered whales also                                      system.
                      dwell in the adjacent Beaufort Sea.
                                                                                                                     Thank you for your kind attention to my
                                At a time  when our oil and gas industry                                  comments.
                      is practically shut  down in the lower 48 states,
                      particularly Louisiana, Texas and Oklahoma, it                                                                      Very truly yours,
                      makes absolutely no sense to open up such a
                      critically important wildlife refuge to oil   and gas
                      exploration. Moreover, I understand that there is
                      only a 20% chance of finding economically
                      recoverable oil beneath the coastal.plain    in  the                                JCS:ls                          Ihne. Stout, Jr.
                      refuge. If it is not economically feasible to
                      develop oil in the lower 48 states, then one must                                   cc  Senator Sam Nunn
                      question the wisdom of the substantial destruction                                      Senator Wyche Fowler
                      opening up the Arctic National Wildlife Refuge WJIJL                                    Hon. John Lewis
                      cause in light of the dubious benefit to be
                      obtained.-

                                As one of those who worked long and hard
                      for the preservation of critical Alaskan lands, and
                      one who has also visited these Alaskan lands, we

    LEGISLATIVE OFFICE
    P.O. Box 2793
    904 Divide Avenue
    Bismark, North Dakota 58501

    Farm Bureau & Affiliated companies

    North Dakota Farm Bureau

    January 27, 1987

    U.S. Fish and Wildlife Service
    Division of Refuge Management
    2243 Main Interior Building
    18th and C Street NW
    Washington, D.C. 20240

    Dear Sirs:

    The North Dakota Farm Bureau is a general farm organization
    of some 23,000 member families belonging to 50 county Farm
    Bureaus. We are concerned about obtaining an adequate
    amount of fuel at at a reasonable price to carry out our
    farming operations.

    We believe that it is most important that our nation de-
    velop all sources of energy. Furthermore, adequate and con-
    sistent supplies of energy are critical if agriculture is
    to continue to meet our nation's demands for fuel and fiber.

    Farmers in North Dakota are most dependent on portable liquid
    fuels for production and transportation of agricultural com-
    modities and farm supplies. At the present time there are
    no alternative sources of energy available to run equipment
    on the modern day farm. And, according to what we have heard,
    your Service is concerned about offshore expoloration near
    Alaska. We believe this area is on of the most promising
    areas for exploration and development of the petroleum and natural
    gas resources. It is our belief that there should be no
    delay in the exploration of this area for energy.

    The environmental impact of the offshore oil industry is one
    which has an excellent record. Records show that only one
    spill in U.S. waters has resulted in significant amounts of
    oil reaching shore. More than 31,000 wells ahve been drilled
    in U.S. waters without a major incident. We do not believe
    that these small environmental risks justify a moratorium or
    any type of delay in exploration off Alaska. Delay of such
    exploration could have a major impact on agriculture and our
    nation as a whole.

    U.S. Fish and Wildlife Service
    January 27, 1987
    Page 2

    Please consider allowing this exploration off Alaska with
    no delay.

    Thank you.

    Sincerely,

    John McGauvran
    Director, Public Affairs
    North Dakota Farm Bureau

    JM/ms

    R-4

                  -North Dakota Farm Bureau Affilitates-
    Nodak Mutual Insurance Company, Nodak Agency, Inc. N.D.F.B. Trade Development and Service Corporation, Western Farm Bureau Life Insurance Company

                                                                 ArZCTIC, VILLA&e                         AN W P-       00-L    T-T H A V Cr #q      LOAIC, 1415'-r0fk%/ T*O T-T
                                                                                                   WH%c-H APr. VEPy, XMP0ATPNT- -M U&                         7a:'ii US-r My

         ------                                                                                      Ml                          __l)QlPv_-IjULt_y YOu. MAA,..E=___You.$a,

                                                                                                 __vs __A3_vft,4                                                   dcN.Ir
             Su P.,l EPT ------          (w AT
                                                                        C-Fu C- r=                  m r -T1.0                           ;N -ANy.W _Ply
                            tA                                                                            hr=AP,_, _,F.P,0&4 lj-hC_, -@IAg 0; _CUP, AN ce_z-rcP,., ..'XTS 0N_G

                       Si R:                                                                                                                -M
                                                                                                     j-)4Ar. Mvy @ @615TOfke, ANC-S                                   PJGf- A P Z; 44
                          __N0rrIr4ING-.  MUC-14 X_ -0-AM tw ORL SAY , MIGHT                        _-C F@g ... -r-4- a I I t4 .h.AR rn. 4@m
             No-r C14AijG-r= %?ouriL       mp'                  X-EF-ft '(3.- ANwp,                                                                                       PEVEa,
                                              rio Aeati-r               Aj                           S"ow - up       ui I" Im @ A. \(E:OR
             Qbsa -4,n c".1- Dg:VGl_0PA4eN7-j eveiv TP )4_@ DISC-113F                                           Vkfl-r@l I-N @ '+t_ Q F"           0-- -13-rViCiS @ILEMI fA)
                                                                                                                                                                      off
                                 Vs cre e  zur    C@c>a -. op,    /Y oT . --LSTI LL                    Arjff.&)f%%f,         WHEP -tilCry f)FtL- STAPot'NC@ t)t-\-vN
                  G A D1
             .WANT- you -m AGAD oN2               0 tl -@JtIA-r  X KA V t- TD Z) f) y                  TlAtov@C2,VC-0 -'foe   HISTORY Q!RR, i3co-) _HAVE '1141 C-Q, -youl0cm-
                                   TV5 LV_ YOV    Jt'nLF_ ArND%jr AiY-SELr- ZC                         CN ES.      Ov- Ou C-0 -0 %JT I A) -4AOR I E@&     RISS A . \A/ Tt4 I @v
                          ills @N. _5,;,)eS%5_rr_-t4CG - US6,9,,      Mj PAREN-rS
         ..A,AC-. -lacirm QNl-QUQ_hTEt:o . 6vT my r-/-kTmc-P_ VNbCrP.STt)ob                                                      -TT
                                                                                                       40 ON&__._APr=ft5            4e    AN %,v R    i
           -S L) m                     X GRF-\A/ up i'li TtiC Qcv0-rRy,                              ..f-'-AJT                             71@t&       NalEw
             WAT@,Js_ WAY O-F          , Ci FS.                                                        Op@t4 Ly       S_o W & N E E C>                          =r olgEry
                              'FOR HIGIA -W_h0c:fL _ZWAS SENT OU-r                   110                                                               RGASoK .4-RE-Y
             (DUT                                                                                                   -3--T:S %+4NT -Tl'rtiF-       or yc-AP, vjHr="
                                                              A ri sj,4, 6 Y F_ A Ps
             IHM4 CIN To rriwcnTION Pr0q&Arn -Vl46P_oL)C B-LP, F)""                                    \Aj r-_ A Tv+ E- P_ is Q-oc)L- aNgzj Na, AA
                                                                Tt4              S 14r, tt
                mouw@s C,@- CU-_Rr\ TyiST., IP OT HERLDS &S'MCSS COOE&E                                "r-_E2I'AJC, q+C-RP_ ALL '+hE,- -tJMF-,, PLSCo _Mr@S f).-
             1-@F_o ;N !3PmF9A0CAjCS.@,,,CAL;F. WoOKED AT GEN C-L:Lt--Py- Pop,                         61'C, CDPC-AJ      VI-A-r PLAC@E, SEF- all@-ra;JCF_ wHi@44_
                           = D i4oiLrH Al-Am. -1 (!F4rvF                                               PGLP, AftM -10 FROTeCT _tHIGR YOVI\JG, ON&S , .5
             13W'E, sl@irL                                       - 134ct\-- To my                                                                                                vcf4
             "OMEC: 19,10. 310CG +he_f4 X INV01\1G Wi@H COMMWiT-/                                      A S r_&SP I                         OUT C, KIC-- WoLvc- A"C':f
                                                                                                                          "TR U DE P,
                  liJC.- -ilo 13SPSA L- IV14C, ." 0 C- Ou 0_4TIOI,@ " P, Ml/                                           G-t@ coaot3cf F<::)P- wvtj(@,-,@50uzms
             F&V PLE                                                                                                           -tP                                    -NOT.AREA-
                                                                                                       p4Z(@ciic       iEn@ r sl, W,41K 4No.             C - -
                     My- VILLAG-E-     IS, TUS.T    Fl,. 5FAA,L-L- ViIIA6,4- Ou-isioe                  Stioul-D. STA'( C>PeN -Tco, -V'hC- 'o-Do';eou NOT- r0a

                  45 AN ALASRAM              X CAM        iEtL )(c)u    4 16 0 Cri- 141                4.         1-    HAV6       &,RC-(+T F@GeLitjr@ FOP-                   NA -r i'v
                  -EX P&PQ:C-wcP- %0!@- - MAVIE HAD wir)4 O;L 0-'vc'WM&'T                                         AND r E SP'7ECr WMeiLE .- wC- QLAMC: F OZOM
                            likE_vc- __3>@.Dmr _C-@03 -ANY Tti IMQ@ F-I?-VM                                                                                          2,
                                                    Pumpeb.our... OazE l')U MHK                                   _Fk0m. -Tfic-                                  F" S-T ZN-D'Il WP
                                                                                                                  _42@&Llcv E-S ....WE-_                69ATED f=ROM
                                                                                                                                   --AN wp-                  _.__re&oN .,-WF--.     ARC-_
                                                                                                                                                                                         rz EAT_
                                                                                                                                                                       @'ST
                                                                                                                                                                                  r -WAS
                                                                   cVTc__wil I L_E__ ---Coke-                                                                                  i'iv -,,d,13eAS&
                                                                                                                    W&TWi N
                                                                                                                                 JT
                                                                                                                                   y
                                                                                                                                     _
     ------- ---  __Abf@c_k I'W                          _sr=NTL7y._.Wtl-C-*4J _pjql'c_c- .
                                .105       UMT_11__.IZ.C                                                                                                  -us        -'s'le7rL& WLFERE
                                                                     L
                                        ..--,Op. rM GMi- 0              5-6AAC P rl?00 W-                                          A/0        No
                                                                                                                                      -w.         _T_.cDtjt_y._.t9fec - V(.L
                                          -V:" Zo..Q a Vv.H i @ H 1@ s rLis 0'v                                                             AL-L Tt-4C- \ft)pzcvq FLJ+_r Yut<0tj
                          X KDAb o' .
                  'F Eea-_                                                       P6)METEA,
                                 ).C'-@     Pt (?- S_ E: ST                                                                                                  WAY-up _TZ3
                  C> to                                                              +eeil
                    F                                                                           -                 AkC-TLC. COC46TAU . pt-A;N , W")@j -wis V1431-
                                                                                                                  LA-N.D pc-c>pir= APiE!- ACuS-ro/w 776 QAR#G0u
                                                                                                                  nleA.T ArS T"iEa. P@ie-r - Su plr--R,%E- dFClbk
                                                                                                                  7H iS _A3 -TkJ TE Q@N4T;OM A L X_S_%Q E
                                           TO .&E-T AAt,< TECL("C- -F9-oA4
                                                                                                             _._64  c-    A  NWR --is         tjoT ..Asbum;w@Nce
                          ok C-Lose              Pe-oeLC T-H19T, 13ENEI=Z_T_._,                                   W. i..L t)     N ; fV@ A L_ 5              45n u RL 14 N C- &4@11_r 0
                  yz_j'tjApQj4LLy                   WA,-JT -M-oar-i develeptneki-T,                               WAVE                                           ONLY
                                                                                                                                                        T14 e               MrsftsoN
                    a rz E M 5*a m E          e (5p L 6 f  GIST IqIC--H (!)Lri- at 0i'Li                          CAM@Qocnj INCIease 110 0uvvl%l'5e-Q"s
                  .!Some Z)ON@- GE-T NcrrHimc, Sc, TAP, @r_ KNOW                                                  -@r 4RPpeyq AFTC-A, _Z_T
                                                                                                                  -                                             WAS
                                                                 6F reople.WAMT                                   .45 _4N Ivv           w t4 EM _I-HEY 177-CPP -0 A               t@l @A
                      wp- QLosE IZOR IDEVELOpmr-Nr WHILO                                                          US t--     o-F- ti)F- LANOo TP,-_szE- ARF somr-
                  .A tj               0% A N3                              I         M cz y
                  ZNjCLVD - A@N I                 ANT@- Wotj                                                   I "IMAL-5 T-HA-T APe NOT OACW f"J. <)Mo3,f!R5
                  5 4 jD '7 6 *1.         F A Las)<A . WA Al-r b & V F Lop M e"T 0
                                                                                                                  YET EVE0 IFT-C-sQ,                   17 y&P$?S of 1+N W K
                  :T_ jUS-T IDON'T BeL,'jGVLI= -f'hN-t FIGof-E- . X'j) _rGLL                                      ALA@ -tHE -FiMG AAY FA&IILy L'jvc'.c> As
                  you wow 7Ne PGOPIE _#@-F qnF- ;IQ tHt.                                                          SvOS15-1 E-NC& LI'Vi,,0C,_ 13[@TwECN lqTO-(Pq
                  -L.1                                                                fhA DE:                     -TKERE S         14
                     @-AlDj WARM ZT OPE-t4 AND                                                                                       4RDLy ANy L4-du(, -"ii@G-s
                  -04iep                              A<71E'% , +6 coN vad) @5c'F
                                                                                                                  .4Lcr(- oF Tws WF_ HAvr=                          -rb do W;Tl+ooT------
                  C>-r E-A,_ oa_ -3uST__ To GCT wHfvT 'r -y WANT.                                                                                                        -i @N G
                                                                             14C                                  WG _Lc3sT ALC3 I (2,j-_Ljvj@jc_44                           -6-   F A0

        OADS To 'Fisl4i WHC-N ONG OF 1-41E &QEWr
        CA ANC-c-, - CamG _-T-0 us; Dog- t,N     -FOR Mcw8y
      -----VVA-5..-.--V P _.___Tf4 F-%/ Pc@t5o NA LOT C@J= , SAIA LL_
                                                             AWL>
        LA              AL S       c    Tlkc-
                               t-u +i -     y ..V6 E L) po i S C)
                   L 7% @,._Ttl AT -WJS
                                   __WA@y_.13_Cfoa_& 1,7S-0, Sc:)

                                   4ts, KA r->
                                                          PNOTHe-k
                                A -.--As              _;S@
                                        JOG __JNF_jZoP
         _crREA7 .0-ttANQrS             AlAy 136       -
                                                     IVE       bo
                                         0-v  :ju  CF
         Q 4   41%&  Abu ov DA N C- G          i v i IVS 5AS  -f-he_
         C.@0.0_t:s@ ___@4F_:A_L7TH_ - ol= ALA ov r->..,. -T-HAT qo
         @ALA-Sk,+ iS Whor=gNEss            I s Ncr
                                         -r      Is    To
                 zr_ YOU. Q_oUL I> Pu        114 1'
                          tj I'm   youR_    t:>e- c-is     Mcak i m cr'-
                     -roi-l N i ;j c@, 4-n A-iv W R
          rt, v'T -per
                   a- Alln v Sri,     -MUCH     /A/7-C-a_c-S-r
          Alv y         U G  -%tho@ - PEVTlq IN iNC., -4-o
                   46 R LTH OF MY .-)Qc-oP',E         S7.7,4 T E
          Afjo     NATi'0&3
                   -Tr+ANK you --rcs(z, P-EA-D ON 010AIC-Cze-N-5.

          Is F-ILS I D E@OUT  OF Ap-c-nc viLt,,qe,,c*
          .R. Aqc--ric, VIL-LOCrE HEALn4-0MUPffTl0.fJ
                                   "E
          3. AQcz:-tic ViLL#qC_F eocL, li C-,'L r" 6 Ai IS E 9-
          4. VetvEr;e -A i2cT,c  VILL4G,6 - TR ('t3AL GOVE-RNMCA/7-
                    Ccn-(JN@11_ MEAAM-a-
                              i-epreSe_ArTAT;v& -oo PoRC,     CARI sou
             A nc
             "C-QV Jf4-TG!AZMqT/%oAJAL  T-Rr-A-r%l

    JOURNEYS NORTH

    Ambler, Alaska 99786

    3020 Northwest 50th St.
    Seattle, Washington 98107

    January 20, 1987

    U.S. Fish and Wildlife Service
    Attn: Div of Refuge Management Resources
    2343 Main Interior Building
    18th and "C" Streets, Northwest
    Washington, D.C. 20240

    RE: COMMENTS ON DRAFT 1002 REPORT

    My first trip to the Arctic Wildlife Refuge was in 1968, when I spent six weeks in the
    Schrader and Peters Lake areas. On a hike over to the Hulahula River, I caught my first
    glimpse of the sprawling coastal plain from the frontal slopes of Kikiktat Mountain--
    an intriguing landscape with a shimmering strand of white sea ice defining the distant
    horizon. I vowed to return, and did so the following year.

    In the Arctic springtime of June, I explored the plain and foothills of the Brooks Range
    south of Camden Bay. I wanted to photograph Arctic wildlife, and it was during this
    four week period I witnessed the most unforgetagle and exciting wildlife scene in the
    nearly twenty seasons I have spent in the Arctic. It was a peak lemming year, and I
    had timed perfectly the calving of the Porcupine caribou herd which filed past my
    camp day after day, the number of newborn calves steadily increasing. Snowy owls
    were numerous, I found several nests; as were foxes, both red and Arctic. I saw several
    grizzly bears and many golden eagles. Nesting birds were everywhere. I look back on
    that special time as one of the most memorable of my life.

    I have since returned to the refuge numerous times: hiking from the upper Okpilak River
    to Barter Island; floating the Canning, Hulahula, Kongakut and Sheenjek rivers; explor-
    ing many other drainages, named and unnamed. On some of these trips I was a guide
    and outfitter, sharing my experiences in the ANWR with others. I guided my first group
    to the refuge in 1975. Income from this seasonal activity is an important component
    of my livelihood.

    I hae always felt the hallmark of the Arctic Naitonal Wildlife Refuge is the continuum
    of wilderness from the Arctic Sea, over the Brooks Range to the forested lowlands of
    the interior. The Coastal Plain is essential to this continuum, as well as being essestial
    habitat to the wildlife for which the refuge was established.

    One of the most awesome wildlife spectacles in North America occurs there with the
    calving of the Porcupine caribou herd in June. This is followed by the post calving con-
    centration, when the animals move northward to the coast to escape the emerging hordes
    of insects. Often by early July, the caribou are found in dense herds numbering as many
    as 80,000 animals. I saw one such mass concentration in 1974 from the ground. It is
    somethings one can never forget.

    RE: Comments on Draft 1002 Report
    Wilbur Mills -- Page Two

    To open the Coastal Plain to intensive oil exploration and development would destroy
    all of this. The wilderness integrity of the Arctic National Wildlife Refuge would be
    gone. The sweeping view across the the plains from the frontal peaks of the Brooks
    Range would be broken by roads, buildings, airfields and drilling towers. The Porcupine
    caribou herd as we know it, numbering over 150,000 would become a mere remnant of
    what it now is. Gone would be the opportunity to witness the wildlife spectacles
    which I saw in 1968 and 1974. We would sacrifice this for what, in even the most
    optimistic estimates, would satisfy our oil needs for only a few months.

    To fully lease the Coastal Plain of the ANWR  for oil development as proposed by the
    Department of the Interior would be tragic. It would rob future generations of a com-
    plete Arctic National Wildlife Refuge. It would degrade beyond measure the premiere
    unit of the national wildlife system. It makes a mockery of the efforts by so many
    people over so lona a         to preserve a wildlife and wilderness legacy of global sig-
    nificance.

    The only alternative for the Coastal Plain is wilderness--complete, lasting protection
    under our wilderness system, so that those who inhabit this country long after wer are
    gone do not look back on us as shortsighted, greedy and foolish.

    Sincerely yours,

    William M. Mills

                                                                                                                     L
                                   4058 Kingston Park Drive                                                          Me CV01ce   OAgamaed -AgA(euglad'
                                  Knoxville, Tennessee 37919

                                      December 23, 1986
                                                                                                      December 23, 1986

                                                                                                      Director
                U. S. Fish and Wildlife Service                                                       U.S. Fish and Wildlife Service
                Attention: Division of Refuge Management                                              Division of Refuges
                2343 Main Interior Building                                                           Main Interior Building - Room 2343
                18th and C Street, N.W.                                                               18th and C Streets, N.W.
                Washington, D.C. 20240                                                                Washington, D.C. 20240

                dentlemen:                                                                            Dear Director:

                I understand that the Department of,Interior has tentatively                          This is to encourage your further support of oil and gas development
                recommended allowing oil and gas development of the coastal                           on the Artie Coastal Plain, an -area we believe holds enormous poten-
                plain portion of the Arctic National Wildlife Refuge to                               tial for secure supplies of domestic energy.
                proceed. I would strongly urge you to reconsider this
                tentative recommendation and, instead, that you recommend                             It goes without saying that the Maine agricultural community is
                that the entire Refuge be.designated as wilderness.                                   dependent on petroleum.for its well-being.of the Americans we
                                                                                                      serve. The ever growing reliance on supplies of foreign oil is a
                It is my understandinq that vour.report reflects that there                           cause of increasing concern and begs,& continuation of supply
        (b      is only a twenty percent.(20%) chance of finding economically                         cutbacks and escalation of prices.
                recoverable oil and that,such estimate is predicated upon
                an oil price that would be more than double what it is                                Experience has shown that oil activity in Alaska can be conducted
                now., At the same time, your report acknowledges that there                           in an environmentally safe manner as it buys us time   for'development
                would be significant adverse consequences on the outstanding                          of alternative energy sources.
                fish and wildlife resources in the coastal plain area.
                Such conclusions should be sufficient by themselves to                                We heartily endorse the recommendations contained in   the Interior
                reverse your recommendation.                                                          Department*s draft study calling for oil development   on the
                                                                                                      coastal plain of the Arctic National Wildlife Refuge.
                I have visited the Brooks Range on three occasions and
                plan to backpack in the Arctic National.wildlife Refuge                               Sincerely,
                in the next several years. The outstanding scenicbeauty
                of the area and the wildlife resource, including particularly
                the 180,600 head porcupine caribou herd, should be protected
                against a questionable oil and gas resource.                                          Dan LaPointe
                                                                                                      President
                Thank you.
                                                                                                      DL/lb
                                                   r
                                                      y
                                                     '@
                                              W.     @Htk   Al
                                                  ia.         ten

                WHS:jcm

                                                                                                   479 qVegleko tAveave TO. (Roy 490 _Auguo(a, vUapte 04290 207-692-4111

                    Genesee Valley Regional Market Authority
                    900 JEFFERSON ROAD      ROCHESTER. NEW YORK 14623       716-424-4600

                                        William J. Mulligan. Adminis"tor

                   January 15, 1987

                   Mr. Frank Dunkle, Director
                   U.S. Fish and Wild Life Service
                   Division of Refuges
                   Room 2343 Main Interior Bldg.
                   18th and C Streets N.W.
                   Washington DC. 20240

                   Dear Mr. Dunkle:

                   If you could see the Market on any given morning you would see a
                   flurry of activity, trucks coming in and heading out carrying food
                   products to various markets throughout the Northeast. This hub of
                   activity requires massive amounts of energy.

                   I'm sure you realize that the food business has changed in the past
                   few years and is no longer the labor intensive industry it once was.
                   New machinery and new methods have improved efficiency and serviced
                   the comsumer in a far better fashion, giving them more fresh products
                   at very competitive prices.
        L
                   Where then would the food industry, yes the Market Authority, be with-
                   out competitive fuel prices and a stable availability of product?
                   That concern has raised new alarms, because we see that the OPEC
                   countries are getting their act together, and prices are rising. We
                   see a growing dependence on foreign suppliers, as the balance of pay-
                   ments deficit soars and domestic production declines.

                   We have 125 member companies who depend on competitive fuel prices
                   and market availability to keep their doors open. They believe, as
                   do 1, we need new sources of domestic oil and gas and we need It soon.

                   The Northern Territory of Alaska -ANWR- appears to have the greatest
                   potential reserves of oil and gas. The section called 1002, less
                   than 10%of this vast park network, could and should be developed
                   with great concern for all the natural beauties in the Refuge.

                   The proven methods of oil and gas development in that region of the
                   world, show it can be done safely and efficiently. We urge you to
                   get on with the job.
                   Sincei:@@
                   Willi
                   Administrator

    NAAA

    National Association
    of Manufacturers

    Resources and Technology
    Energy
    Environmental Affairs
    Natural Resources
    Innovation, Technology & Science Policy       January 9, 1987

    Mr. Frank Dunkle
    Director, U.S. Fish and
     Wildlife Service
    Division of Refuges
    Room 2343 Main Interiro Building,
    18th and C Streets, N.W.
    Washington, D.C. 20240

    Dear Mr. Dunkle:

    The Natioanl Association of Manufacturers (NAM) appreciates the
    opportunity to comment on one of the most significant energy
    policy and national security issues of recent years, the Arctic
    Natioanl Wildlife Refuge (ANWR), Alaska, Coastal Plain Resource
    Assessment report. NAM supports and commends the United States
    Department of the Interior (DOI) for recommending that the Arctic
    National Wildlife Refuge's Coastal Plain be opened for oil and
    gas leasing, and urges the Congress to accept the recommendations
    contained in the draft report, released in November 1986.

    NAM is a voluntary business association of over 13,500 companies,
    large and small, located in every state. Our members range in
    size from the very large to over 9,000 small manufacturing firms
    that each have less than 500 employees. NAM member companies
    employ 85 percent of all workers in manufacturing and produce
    over 80 percent of an additional 158,000 businesses through its
    Associations Council and the National Industrial Council.

    NAM's interest in the ANWR report stems from the fact that our
    association's membership constitutes major users of energy as
    well as most of the domestic producers. Despite the diversity of
    NAM memberhsip interests, however, it is safe to say that they're
    all concernced with international competitiveness, its effect on
    the manufacturing trade deficit, the federal deficit, national
    security, and, of course, the health of the entire domestic
    economy.

    FOREIGN OIL IS DISPLACING U.S. OIL IN A U.S. MARKET

    Today, America's enery producers are rapidly losing ground to
    imports in the oil marketplace. National energy forecasters now
    predict that oil imports may increase from 35 percent of the U.S.
    market to 50 percent by the 1990s. Futhermore, U.S. imports
    from the volatile Persian Gulf area have increased 300 percent in

    Mr. Frank Dunkle
    January 9, 1987
    Page 2

    1986 and accounted for more than half the total increase in
    imports last year. What this means to America's energy consumers
    in the near future remains to be seen. But it certainly is
    evident that the nation is once again, experiencing the
    phenomenon known as "oilzheimer's disease", defined as the
    capacity to use more and more oil without remembering past
    negative experiences. If we do indeed look back to the
    experiences of 1973 and 1978, we begin to realize how close to
    the edge we remain in 1987 by increasingly relying on unstable
    foreign sources for major supplies of oil. Gasoline lines and
    upward price spirals could be just around the cornern.

    But, even with immediate access to high potential areas such as
    ANWR, this picture will not improve short-term. Exploration and
    development of Arctic oil and gas usually takes more than ten
    years from the initial discovery to first production.
    Consequently, and production form this area is not likely to
    occur much before the end of this century. At that time, oil
    production form current U.S. reserves is expected to have
    declined considerably from the present level of over 8 million
    barrels per day (bpd) to less than 3 million bpd, and Prudhoe Bay
    production which in 1986 is averaging 1.5 million bpd will have
    declined (according to the State of Alaska, Deparment of
    Revenue) to 280,000 bpd in the year 2000. To compensate for this
    loss of production new discoveries of domestic oil must be
    developed or imports must be increased. There are few
    alternatives.

    But despite its relative inaccessibility, at least
    geographically, ANWR is actually a valuable potential source of
    domestic oil, in part due to the in-place infrastructure from
    Prudhoe-Bay development.

    TRANS-ALASKA PIPELINE ENHANCES COMPETITIVENESS OF THE ANWR
    RESOURCES

    It should be remembered when considering development of ANWR that
    the Trans-Alaska Pipeline System (TAPS), which was completed in
    1977, and cost approximately 10 billion dollars is already in
    place. The close proximity of TAPS to the ANWR region only
    enhances the resource potential for this area and other economic
    reasons make ANWR attrative.

    The approximate $10 billion cost to place TAPS in operation
    represents a sunk cost; if capacity is fully used, the marginal
    cost of utilizing TAPS in independent of the sunk cost and is
    quite low.

    Since the cost of producing petroleum resources at any site
    includes development and transportation, the availability of TAPS
    capacity to transport potential North Slope production at ANWR
    and elsewhere represents a significant cost advantage vis-a-vis a
    site where a more expensive transportation option is required.

    1331 Pennsylvania Ave, NW
    Suite 1500-North Lobby
    Washington, DC 20004-1703
    (202)837-3000

    R-11

            Mr. Frank Dunkle
            January 9, 1987                                                                           Mr. Frank Dunkle
            Page 3                                                                                    January 9, 1987
                                                                                                      Page 4
            This cost advantage resulting from the availability    of relatively
            inexpensive TAPS capacity means that fewer resources need to be                           fields and railroads.  Wildlife habitats, environmental values,
            expended to produce the petroleum resources in ANWR then at a                             and the petroleum industry can and do coexist.
            comparable site lacking in-place transportation facilities.                               CONCLUSION
            Consequently, the availabilty of throughput capacity at TAPS for
            potential AWWR production is not only valuable in that it will                            As important as ANWR is, it's only one piece of the major energy
            help keep out foreign imports, but it will also be economically                           puzzle. ANWR is what could rescue this nation from foreign
            competitive.                                                                              imports and provide for some energy needs well into the 21st
                                                                                                      century. We must be able to plan for future needs, and ANWR can
            ENVIRONMENTAL CONCERNS                                                                    play a role in meeting these needs, In the context of
                                                                                                       omprehensive energy planning.
            "Economically competitive" however does not exclude
            *environmentally compatible" development. opposition to                                   in light of our overall domestic energy concerns, NAM's Energ
            petroleum operations on the ANWR plain arises from the concern                            and Natural Resources Committees passed a resolution which tHes
            that wildlife species and habitat will be significantly harmed.                           into perspective a much broader approach to the current energy
            Although any sizeable petroleum operation will have some Impact                           dilemma. A full text of this October 30, 1986 resolution is
            upon the environment, previous experience leads us to believe                             attached.
            that ANWR resources can be used in a safe and responsible manner.                         But as part of th is approach, NAN supports the draft Arctic
            one need only look "next door" to the Prudhoe Say operation.      It                      National wildlife Refuge, Alaska, Coastal Plain Resource
            has been proven that industry and environment can coexist in a                            Assessment being considered today, and we respectfully submit
        L   multiple use capacity.                                                                    that the Congress of the United States also accept and act upon
            In fact, several major problems have been resolved as a result    of                      the recommendation in the draft report.
            the Prudhoe Say operation. Aside from the hostile climate and                             NAM's long-standing policy has been that public land should not
            difficult logistics of operating in an extremely remote location,                         be closed to or restricted from resource development and
            the most challenging technical problems encountered and solved in                         nonwilderness multiple uses in the absence o  f compelling national
            the onshore Arctic were related to permafrost.                                            interests that override the need for adequate domestic oil,
                                                                                                      natural gas and other valuable resources. Before areas are set
            From the years of operating experience there has been developed                           aside for exclusive uses, every effort should be made to
            an environmental protection technology to minimize, and in some                           determine the availability of materials and other resources on
            cases eliminate long term changes to the tundra.    For example,                          the proposed set asides, and access should be assured to explore
            low-pressure tired vehicles have been developed which can cross                           and develop the area's resources.
            the tundra without crushing the vegetative mat or scouring the
            soils as tracked vehicles might.                                                          United States, energy policy should be oriented towards
                                                                                                      significantly reducing our nation's dependence on imported energy
            The issue of the caribou is of course a concern.    Again, Prudhoe                        resources.  The development of domestic energy resources, such as
            Say serves as an example. When the Prudhoe Bay oil field was                              those contained in ANWR, are the best hope to reduce America's
            developed in the mid-1970s, regulatory agencies acted cautiously                          energy vulnerability, and enhance the ability of manufacturers to
            and studies were conducted to determine the effects on the                                be more competitive in world markets, or at least amid those
            Central Arctic caribou herd.    In fact, the results of the studies                       economic influences brought on by unstable energy markets that
            and the tools implemented to prevent damage to the Central Arctic                         don't allow for proper planning of manufacturers energy needs and
            herd were quite positive, in that the herd has increased at a                             the producers, opportunity to explore.   Thank you for the
            rate of 12-18 percent per year over the past decade. At more                              opportunity to express our views.
            than 13,000, it numbers at least four times what it did in 1975
            before most of the Prudhoe Bay development activity began. The                                                               Since ely,
            positive results from Prudhoe Bay and other similar experiences
            from northern Europe and the Soviet Union, prove that herds can
            exist in the presence of industrial development, including oil
                                                                                                                                         Kevin D. Ott
                                                                                                                                         Director,
                                                                                                                                         Natural Resources
                                                                                                      KDO:Iek

              NA"A
                                                                                                            0 The President and the Congress have called for prompt
                                                                                                       studies of the economic and national security imrlication of low
              RESOLUTION SUPPORTING NEED FOR A STUDY TO ASSESS THE ECONOMIC                            crude oil prices and the dramatic increase in im,orts of crude
              AND NATIONAL SECURITY IMPACT OF INCREASED IMPORTS OF CRUDE OIL                           oil and refined petroleum products.
              AND REFINED PRODUCTS.                                                                         Therefore, the National Association of Manufacturers supports
                                                                                                      the urgent need for an Administration study to assess the economic
                   The NAM has had  long-standing p9licy supporting (1) an                            and national security implications of increased imports of crude
              adequate and secure supply of energy at competitive prices,     which                   oil and petroleum products. Recognizing that oil imports are only
              is necessary for the nation's economic growth and (2) an energy                         one of several critical imports that could.impact upon our national
              policy oriented toward significantly reducing our nation's                              security, such study should assess, among other things, the
              vulnerability on imported energy resources.                                             following relevant factors:
                   The NAM has observed the following:                                                      0   The impact on our trade deficit if projected increased
                                                                                                                oil imports continue;
                   o There does not appear to be free trade in the                                          o   Whether there will Ibe a significant worldwide crude oil
              international market for crude oil and petroleum products because                                  upply surplus in the  199019 to prevent OPEC, or others,
              of the collusive power being exercised by all or some of the                                      a
              member countries in OPEC;                                                                         from being able to significantly influence availability
                                                                                                                and/or price of U.S. imports;
                   o The continuation   of current crude oil and natural gas                                o   which producing countries will have excess capacity in
              price levels will result  in a dramatic decline in U.S.                                           the 1990's to replace imported oil that may be disrupted?
              production, an increase in consumption and a substantial increase                                 To what extent would incremental supplies be dependent
              in U.S. oil import dependence over the next several years;                                        upon Middle East reserves with their long-haul and other
        31         o Increased U.S. oil imports exacerbate the record trade                                     exposures;
        I&    deficit;                                                                                      o   The extent to which the downturn in exploration-
        CA)        o Similar trends will take place in other non-OPEC countries                                 occurring in the U.S., combined with the increase      in
              over the next several years and the net effect of rising world                                    demand at lower energy prices, is occurring in the rest
              demand and declining non-OPEC production will be a dramatic                                       of the free world. What implications does this have on
              increase in OPEC's output and control over the market;                                            the future worldwide supply-demand balance as the U.S.
                                                                                                                moves toward inqreasingly higher levels of import
                   o It appears very likely the United States will      have to rely                            dependence?
              on the Middle East for an increasing share.of its oil      imports;
                                                                                                            0   An analysis of the political environment in Middle East
                   o The infrastructure of the U.S. oil industry is declining                                   by 1990. What are the prospects for a supply disruption
              rapidly because of decreasing investment and will take years to                                   resulting from developments such an the Arab-Israeli War
              rebuild if major increases of oil and natural gas are required in                                 or Iranian Revolution during the period 1986-19907
              the U.S. at a later date;                                                                     a   The Iconstraints which will be placed on.our fore   ign
                   o The synthetic/renewable energy contribution to meeting U.S.                                policies with increased reliance on imports;
              energy requirements will continue to be minimal and significant
              supplies of alternate energy.cannot be expected to be available                               o   The effect which growing dependence on imported crude
              to supplement petroleum if there is an energy shortage in                                         oil and refined petroleum products will have an U.S.
              the 1990's;                                                                                       military planning and costs;
                   o The capability of the Strategic Petroleum Reserve to                                   0   The refined petroleum product needs of the military,
              provide protection against the impact of an oil disruption could                                  defense-related industries and vital federal, state     and
              dramatically diminish if current trends in imports continue;

                   local services under all foreseeable national emergency                                          NATIONAL OCEAN        INDUSTRIES ASS0('1A-1 ION
                   scenarios including an oil embargo, terrorist     attack,
                                                                                                      $! - Wz@@,
                   protracted regional and/or global war and the    ability of                                                     N   Slii1c AM)                      If,
                   the refining industry to meet the need for such refined
                   products;                                                                                                           January 20, 1997
                0  The impact of the oil price collapse on the oil service/
                   oilfield supply industry. what will be the lead times                              Director                                                           .1 t
                   involved in rebuilding this industry from the current                              U.S.. Fish and Wildlife Service
                   depressed levels (and which are projected to worsen)?                              Division of Refuges
                                                                                                      U.S. Department of the Interior
                9  The ability of the United States to activate shut-in crude                         Room 2343
                   oil and natural gas wells and idled or shut down refining                          16th & C Streets, N.W
                   capacity in the event of an interruption in the supply of                          Washington, D.C. 20240
                   imported crude oil and refined petroleum products;
                                                                                                          Re:  Request for Comments on the Draft Legislative
                �  The adequacy of alternative sources (including synthetic                                    Environmental Impact Statement and Resource Assessment
                   fuels) of energy in the event of an interruption in supply                                  Regarding the Coastal Plain of the Artie National
                   of imported crude oil and refined petroleum products;                                       Wildlife Refuge. (51 FR 42307, November 24, 1986).
                �  The projected free world supply-demand balance in the                              Dear Sir%
                   1990's compared with the supply-demand balance in 1979;
                                                                                                         On January 0, 1987, the National Ocean Industries Association
                �  The size the SPR should be in order to provide the same                            (NOIA) participated in the public hearing held in Washington,
                   margin of protection which exists today in the event of     an                     D.C. relative to the coastal plain of the Artie National Wildlife
                   import supply disruption;                                                          Refuge (ANWR). As we testified, NOIA strongly supports the U.S.
                                                                                                      Department of the Interior's proposed recommendation that oil and
                o  The current level of private stocks and inventories                                natural gas leasing be permitted In the ANWR coastal plain. Our
                   (compared'with 1979) as a margin of protection against                             comments are reiterated here for your Information.
                   a supply disruption;
                                                                                                          NOIA is a trade association based in Washington, D.C. and is
                �  The interaction and  obligations of the United States                              composed of over 325 member companies. Each of these companies
                   within the intennational Energy Agency program.                                    is engaged in one aspect or another of discovering and recovering
                                                                                                      our nation's offshore energy resources; from geophysical data
                �  The likelihood that OPEC will engage in another round of                           collection, drilling exploratory wells, and finally, developing
                   export refinery construction to capture value-added                                the oil and gas If it is found. Additionally, NOIA represents
                   benefits at such time as it regains market power. What                             all the companies who provide various services and supplies to
                   implications would such a development have on the ability                          each phase of offshore development. Examples of these companies
                   of the U.S. to maintain adequate domestic refining capacity                        include, but are not limited to, those that manufacture and
                   to process withdrawals from an SPR approximately double                            supply drill bits, blowout preventers, drill pipe, casing, .
                   the current size?                                                                  wellheads, logging equipment, and companies involved in diving,
                                                                                                      catering, banking, marine and air transportation, marine
                The NAM urges the President, after completion of the subject                          engineering, and construction. NOIA member companies are
         study, to  promptly determine (1) the levels and sources of imports                          headquartered in 34 states and in the District of Columbia and
         of crude oil and refined petroleum products at which a threat to                             have plant locations in all 50 states.
         our economic and national security exists and (2) the legislative
         and/or administration options available to reduce this threat.

                                                      Approved by the NAM Energy
                                                      and Natural Resources Committees
                                                      October 16, 1986

                                                                                                                                                3

                                                   2                                                        again control world prices and supplies, with U.S. consumers
                                                                                                            again facing soaring prices and a return to the energy supply
                    NOIA supports the U.S. Department of the Interior's (DOI)                               disruptions of the early 1970s.
               proposed recommendation that oil and natural gas leasing be                                      Therefore, it is more important than ever that our nati@n
               permitted in the Arctic National Wildlife Refuge (ANWR) coastal                              pursue an aggressive and-iffective leasing program which will
               p lain. We believe oil and gas exploration and development
               operations on the coastal plain are vital to America's energy and                            enable us to develop our best prospects for major new oil and gas
               economic future and national security.     The nation's best hopes                           discoveries.   With world oil prices remaining at such low levels,
               for major new oil and gas discoveries are in the ANWR coastal                                oil companies, as a result of depressed earnings, have
               plain and in the nation's offshore area, particularly off the                                sigmificantly reduced their capital and exploration
                                                                                                            eXpenditures.   With less money for exploration, we must focus on
               coast of California. Industry activity to date Indicates that                                the inas.t. promising oil and gas prospects, both onshore and
               significant petroleum reserves may lieunder the coastal plain                                offthore,..- First and foremost among these prospects is the ANWR
               and extend out under the Beaufort Sea. If the United states is to                            cowstal plain.
               free itself of Its dangerous overdependence on oil imports we
               must move ahead with the task of finding and developing the                                      %,*e have carefully reviewed DOI's draft report to the Congress
               potentially vast oil and gas resources off our coasts and beneath                            which does, a highly effective job of calling attention to the
               the ANWR coastal plain.                                                                      potentially vast oil and gas resources which may lie beneath the
                    Such resource potential cannot be    ignored.  Leasing,                                 coastal plain.  As DOI points out, there could be billions of
               exploration, and hopefully, production    of our nation's domestic                           barrels of oil under the coastal plain and similarly huge amounts
               energy resources must proceed b4@cause of our nation's                                       of natural gas.   In fact, the area's oil fields could be the
                                                                                                            largest domestic fields discovered since Prudhoe Bay and the
               increasingly precarious and uncertain     energy position.   We                              Kuparuk River fields.    Except for these fields, no U.S. field
               presently have a Surplus Of IOW-Driced petroleum ereated in large
                                                                                                            with reserves exceeding I billion barrels of oil has been
               measure by temporary overproduction by the oil producers of the                              discovered since 1948.    As DOI's draft report explains, a leasing
        01     OPEC cartel.   Low oil prices have, unfortunately, caused public                             program in the coastal plain area could contribute billions of
               misunderstanding and complacency, concerning our nation's future                             barrels of additional oil reserves toward the national need for
               energy needs.   The dark side of the temporarily low prices and
               the world supply surplus includes:                                                           domestic sources.   Not only might discovery of a giant or
                                                                                                            supergiant field contribute to domestic -reserves and production,
                    - significant economic disincentives to invest in domestic                              it could do so at a relatively, low average cost per barrel
                      petroleum exploration and development;                                                because of economies of scale.
                    - reversal of our unprecedented     energy  conservation measures                           Crude oil from the North Slope's three producing fields --
                      implemented over the past ten years
                    - decreases in alternative energy                                                       Prudhoe Bay, Kuparuk, Lisbrune and Milne Point (which may be soon
                                                         technology development and                         joined by the Endicott field) -- are already contributing about
                      application;
                    - increasing near-term demand and further dependency on oil                             20 percent of U.S * oil production.   America's dependence on
                      imports; and most importantly,                                                        foreign oil could increase markedly in the year     ''s ahead, as the
                    - a serious and potentially fatal weakening of the American                             older fields in the lower-48 states reach, peak @roduction and
                      energy community, including the support, service and supply                           start to decline -- as many already have.      Yet it is to Alaska's
                      industries.                                                                           undiscovered oil and gas that the nation.must t     urn, if our future
                                                                                                            energy security is to be more secure.
                    Based on current consumption rates and domestic oil
               production decline, our dependency on foreign oil could rise from                                We have no doubt, that based on the more than 20 years of
               the current level of 38 percent of U.S. consumption (as of                                   petroleum industry experience on Alaska's North Slope, oil and
               November 1986) to 50 percent or more by the early 1990s.       Such                          gas operations can be conducted on the ANWR coastal plain without
               dangerously high reliance on                                                                 harm to thel caribou or other wildlife of the area and in a manner
                                               oil imports weakens the U.S.                                 tha-t is totally compatible with the sensitive arctic environment.
               economy, undermines national    security, worsens the balance of                             We@.-,axe not, talking theory or concept here.  We can cite a record
               trade deficit and costs American jobs.     It means OPEC could once

                                                     4                                                                                                 5

                of effective environmental protection and time-tested safeguards.                                adva ntage over other Alaskan sites and may make it economical to
                We can cite the stringent standards and regulations imposed by                                   develop higher-cost reserves.
                the federal government and the State of Alaska to make certain
                that arctic wildlife and its habitat are fully protected.        We see                              In summary, NOIA believes that the Department of the Interior
                no environmental justification for delaying or prohibiting oil                                   is correct in proposing the opening of the ANWR coastal plain to
                and gas operations on the ANWR coastal plain.                                                    oil and gas leasing.    We firmly believe that this is a critically
                    This vitally needed oil and gas development will not only                                    Important step that must be taken it out nation Is to have the
                                                                                                                 energy It needs for the decades to come and If we are to free.
                help meet America's energy needs in the 1990s and beyond, it             will                    @ourselves from the threat of future energy supply disruptions.
                also bring Important economic benefits In terms of jobs and                                      At a time of continuing political ebaos and terrorism In the
                business for virtually every state In the. union -- and It will                                  Middle East, we have no choice but to find and develop the oil
                mean increased leasing revenues, royalties and other funds for                                   and,gas resources within our own borders. The ANWR coastal plain
                the federal government. These are significant benefits which                                     Is the place to start.
                frequently are overlooked In our discussion of the need for
                Alaska oil and gas development.                                                                      Thank you for this opportunity to express our views.           It NOIA
                    For example, between 1980 and 1986, major oil companies                                      .6i I can be of assistance to you, please do not hesitate to
                operating on the North Slope spen    It more then $10.5 billion In the                           eon tact us.
                United States on the development of those oil fields.         Every                                                                  Sincerely,
                state In the union took part In supplying goods or services              and
                the share of the business ranged from $3.4 billion In Texas, $1.8
                billion In California and $1.3 billion in Alaska to $300,000 In
                New Hampshire, and $200,000 In West Virginia.                                                                                        William P. DuBose, IV
                                                                                                                                                     Government Affairs Representative
                    It the coastal plain were leased and a majo'r.oll field
                discovered, sizeable royalty. payments would be generated. The                                '40 D/ t Im
                distribution of the potential revenues among -the federal,        state
                and local governments depends on the details of how the area Is
                leased.  But the resulting revenues.would be significant -- in
                1984 alone, Alaska received some $1.4 billion In      011 roya,lties,
                rent and bonuses from leases on Its own lands.
                    The American Petroleum Institute his eat       .I-ma-ted that, based on
                ANWR coastal plain peak production of between 350,000 and 2.@
                million barrels of oil daily, projected employment- gain would
                range between 138,000 to more than I m.i Ilion.- Job-a, andthe-gross
                national product would Increase from 0.14,. percent, to 1.01. percent
                above the levels that would otherwise be the case.
                    Significant oil discoveries -.within the coastal    plain could
                also help reduce, the notion's huge balance pf trade deficit by
                cutting back U. S. dependence,on foreign oil.      Development of the
                coastal plain would also have- the Impor,tant economic benefit of
                providing a continuing flow' for the Trans-Alaska Pipeline as            oil
                fields elsewhere on the North Slope are depleted.         Continued      use
                of the pipeline at cap  'aclty 'permits low-cost transportation of
                oil from the North Slope.,,The ava4lability of the pipeline to
                transport ANWR coastal    plain. oil provides a significant cost

            International Union of Operating Engineers
                 LOCALS 832, 832B, 832A, 832C

           AFFILIATED WITH THE API-CIO AND BUILIDING TRADES DEPARTMENT

    1218 JEFFERSON RD         ROCHESTER, NY 14623         PHONE

    January 17, 1987

    Mr. Frank Dunkle, Director
    U.S. Fish and Wild Life Service
    Division of Refuges
    Room 2343 Main Interior Bldg.
    18th and C Streets N.W.
    Washington, D.C. 20240

    Dear Mr. Dunkle:

    Right now the Operating Engineers are vitally concerned with getting
    a new highway bill passed by the 100th Congress. But, looming over
    the horizon is the long range threat of an energy crisis, especially
    a domestic energy crisis.

    As one who is responsible for the lives of 1500 members, an energy
    crisis would raise havoc in the construction industry, and especially
    with our members whose big machines gulp large amounts of motor fuels.

    It is our understanding that Prudhoe Bay production will begin to
    show a decline in the next year or two. And, from looking at the facts
    available to us, we think the Artic Region, designated as 1002, holds
    the greatest promise for new resources of these vital products.

    Many of our members hunt, fish and travel extensively in their leisure
    time, They are concerned with the environment, and in carrying out
    their daily tasks are very cognizant how the level of awareness has
    increased for its protection. No longer do bulldozers run roughshod
    over the terrain without environmental planning. The past years of
    oil and gas development in that region show clearly that development
    can be done with minimal damage to wildlife or natures other beauties.

    Failure to develop new Domestic sources of oil and gas could create
    misery in the human environment. We urge exploration and development
    of the ANWR's selected site known as 1002.

    Sincerely,

    Neil Burnside,
    Business Manager

    NB: 66

                     BOX 719
                     BETHEL. ALASKA 99559                                                                  decision to open ANWR would improve the economy and the
                                                                                                           employment opportunities in any business that supports the oil
                                                       January 15, 1987                                    and gas development.

                                                                                                           According to the report submitted by the Department of Interior,
               U.S. FISH & WILDLIFE SERVICE                                                                this country's dependence on imported oi V has increased based on
               Division of Refuge Management                                                               the demand for petroUeum products.     Recognizing OPEC's control
               2343 Main Interior Building                                                                 of the price if oil in the world market, we remember the 1973
               18th & C Streets, N.W.                                                                      trade embargo that emphasized the theory of supply and demand.
               Washington, D.C. 20240                                                                      We do not believe this country is prepared to experience what
                                                                                                           happened in 1973 but its trade deficit is increasing at an
               RE, Deve loping the Arctic Notional!Witldlife Refuge                                        alarming rate.   The demand for petroleum products wit'V continue
                                                                                                           on into the twenty-first century and we anticipate that this
               Gentlemen:                                                                                  country's trade deficit wilt continue to rise.      The decision to
                                                                                                           open ANWR for oil' and gas development would prepare the country
               The Bethet' Native Corporation would like to take this                                      to meet any anticipated demand without a greater degree of
               opportunity to express its position regarding the potential'                                dependence on foreign oil.    We would like to emphasize that this
               development of the Arctic Hationat'Willdlife Refuge.     We would                           country should not be at the mercy of OPEC when it can develop
               at'so like to acknowl!edge the outstanding record of the oil                                its oil and gas reserves.    Less dependence on foreign oillwould
               companies in protecting the fish and wildlife resources and                                 significantly reduce the trade deficit and this will only be
               their habitat as evidenced by the oil and gas develbpment in       the                      accomptlished by developing new oil!and gas deposits, like inside
               Arctic.  Those agencies arguing to preserve the fragile                                     ANWR. Not only would the trade deficit be reduced but many
               environment fait' to acknowtLedge the accomptlishments of the oil,                          by-products from an oil and gas activity would be provided to
               companies in mitigating the adverse impacts to the Arctic                                   the general public.
               environment.
               We feel'that developing ANWR will significantly improve the                                 The production of oitland gas activity has introduced many
                                                                                                           by-products that are being utilized in the home, business and
      00       economy, improve the job market and emptbyment, reduce the trade                            for recreation.   Those opposed to the development of ANWR should
               deficit, provide for many by products used in the home, business                            begin to realize that they utilize many by-products of an oil
               and recreationallareas. In addition, the decision to develop                                and gas development.    In addition, we believe that these same
               ANWR should acknowledge the oitlcompanies impeccable record in                              people have children and their future will depend on the
               protecting the fish and wildlife resources and their habitat.                               availability of the by-products that are utilized in the home or
                                                                                                           business. The decision to open ANWR for development should be
               We would like to comp ftment the North Slope Borough and the                                predicated on the future of our children and their children.'       We
               Department of the Interior for submitting well documented                                   have to begin thinking that anything we accomplish today is for
               reports supporting the development of ANWR.     We concur with                              the future generations that will follow with possibly a greater
               their  recommendations and want to provide the foltbwing                                    dependence on oitland gas and their by-products.       As responsible
               observation.  The oiVcompanies in Atlaska, and the continental'                             stewards, we should not deny them the avalVabillity of a resource
               United States, have experienced one of the most serious                                     that can be developed cheaper today then in the future where it
               set-backs in any economy.    The A Wskan economy needs another                              may be far too expensive to develop or produce.
               boost and the development of ANWR wilt significantly improve       the
               economy.  The oil' companies wit'll be provided an incentive to                             The decision to open ANWR should take into consideration the
               remain in Allasks and all: other support facillities closely                                existing oil and gas activity in Prudhoe Bay that has proven the
               ase0 ciated with oill companies witIt' be directly affected by                              compatibility of an activity with a harsh and fragile
               Congress's decision to develop AkWR.    The decision to open   ANWR                         environment.   We concur with the reports submitted by     the North
               for development wilt! have a rippW effect on all other                                      Slope Borough and the Department of Interior which emphasized
               businesses closely reUated to oiland gas development.       Not only                        that no significant impact has resulted to the fish and wildlife
               would the economy improve due to the ANWR development     but the                           resources and their habitat.     Contrary to concerns expressed by
               decision would significantly improve the job market and                                     the opposition, the wildlife within Prodhoe Bay have flourished
               employment opportunities.                                                                   and have adapted to the oitland gas activity with no significant
               Once Congress makes its decision to open ANWR for devetopment,                              problems.   We are optimistic that opening ANWR would be the most
               sill businesses associated with oitcompanies will be advertising                            responsible action our government can undertake.
               for workers and that wilt'reduce unemployment and provide a
               variety of jobs. The recent slump has drastically reduced the
        [@K    I

               job market and contributed,,hASUMka's unemployment.       The

                With oil and gas develkopment in ANWR we are optimistic that the
                :conomy will improve, emptloyment will be better and more jobs
                 vaibable, and the foreign trade deficit vil'T be reduced. Most
                importantly. we betieve that ANWR can be developed consistent
                with the compatibitlity requirements of the conservation system
                units as established by the Alaska National' Interest Lands
                Conservation Act (ANILCA) of December 2, 1980. We therefore
                support the development of ANWR by acknowledging and agreeing
                with the reports submitted ty the North Slope Borough and the
                Department of Interior.

                Sincerelly yours,

                Felix Hess
                Land Manager

                                              ARMCO INC.
                                     GENEPAL OYFICES - MIDOLETOWN. OM)O 4SO43                                            January     19n
                                                     C-                                                                  Page 2
                                                    AIMMO
                                                      V
                                               January 16.  1987
                                                                                                                         If we can be of any assistance to you  in these important deliberations, please
                                                                                                                         call.
               Director                                                                                                                                         Very truly yours,
               U.S. Fish and Wildlife Service
               Division of Refuges
               Room 2343                                                                                                                                               L
               Main Interior Building                                                                                                                           John E. Barker
               18th and C Streets, N.W.                                                                                                                         Director
               Washington. D.C. 20240                                                                                                                           Environmental and  Energy Engineering
               Dear Director:                                                                                                                                   Armco Inc.
                                                                                                                         JED/bn
               In my role as Director of Environmental and Energy Engineering for Armco Inc.,                            JEBS/45
               my responsibilities and concerns are very similar to yours, i.e., that there be                           cc: L. W. Hicks
               a proper balancing ofenvironmental and economic (energy) issues.

               I believe the record speaks for itself as to Armco's concern for the environ-
               ment. Through 1985 we invested $426,300,000 for environmental control facili-
               ties, In 1986 dollars, this amounts to over one billion dollars. Our annual
               operating expense (including depreciation) for these environmental control
               facilities is approximately $75,000.000 per year.

               A reliable, assured source of energy ' at a reasonable cost, is essential -
               absolutely critical - to a viable American steel industry. Ours is an energy
               intensive business. requiring on the average over 22 million BTU per ton of
               steel. While oil is not a direct source of the energy used for production of
               steel, the availability of oil has a significant impact on the price of natural
               gas, electricity, and coal because of the interchangeability of fossil fuels
               for many uses. Furthermore. oil is essential to the transportation of our raw
               materials and finished products. From 1975 to 1982 our average energy cost has
               more than doubled.

               I have read your excellent draft report of November 1986, entitled "Arctic
               National Wildlife Refuge, Alaska Coastal Plain Resource Assessment."

               In the interest of America's economic self-sufficiency and national defense, I
               firmly believe that the entire 1002 area should be opened for exploration and
               development of the oil and gas resources that are believed to be there. I also
               firmly believe that the important lessons learned at Prudhoe Say and in the
               construction of the Trans-Alaska Pipeline System should be utilized to the
               maximum extent feasible to mitigate environmental harm.

    Ohio Chamber of Commerce

    35 E. Gay St., 2nd Floor - Columbus, OH 43215-3181 - 814/229-4201

    January 19, 1987

    Mr. Frank Dunkle, Director
    U.S. Fish and Wildlife Service
    Division of Refuges
    Main Interior Buidling, Room 2343
    18th and C Streets, N.W.
    Washington, D.C. 20240

    Re: Comments on draft report of the United States Department
        of the Interior "Arctic National Wildlife Refuge, Alaska,
        Coastal Plain Resource Assessment"

    Dear Mr. Dunkle:

    The Ohio Chamber of Commerce, a statewide business trade association, supports
    the recommendation of the U.S. Department of the Interiro that oil and gas
    leasing be permitted on the Arctic National Wildlife Refuge (ANWR) costal
    plain.

    The ecomonic health of Ohio and of this nation depends on a secure energy
    future free from dependence on imported oil. Oil consumption in the U.S. has
    exceeded domestic production for more than twenty years. Concurrently, no
    U.S. oil field with reserves exceeding 1 billion barrels of oil has been dis-
    coveredsicne 1948. If we are to reduce imports, we must find and develop oil
    and gas here at home. According to the Interiror Department's draft report on
    ANWR, "the area is clearly the most outstanding oil and gas frontier remaining
    in the United States and could contribute substantially to our domestic energy
    supplies," capable of producing as much as 9.2 billion barrals of oil.

    The U.S. petroleum industry has nearly twenty years of experience in finding
    and producing oil on Alaska's North Slope and is commited to striking a
    balance between development and environmental protection in this area as has
    been their record in the past. As the Interior Department's proposed recom-
    mendation states, "Development of (the ANWR's) potential oil and gas resources
    could make a significant contribution to the economy and security of this
    Nation, and could be done in an environmentally responsible manner based on
    lessons learned at Prudhoe Bay and elsewhere."

    The Ohio Chamber of Commerce believes that the ANWR coastal plain development
    is a critically important step for our nation's energy future. We urge you
    and the Secretary of the Interior to recommend development of this vital area
    in your final report to Congress.

    Sincerely,

    President

                                    JUNEAU AUDUBON 5CCICTY                                                                                  JUNEAU AUDUBON 50CIETY
               C   _1               P.O. Box 1725     Xweau, AWO M2                                                                             Box 1725 a Mm% Abska 998D2

                                            January 14, 1987

               U.S Fish and Wildlife Service                                                                              We.think the decision to open up ANWR to  development should not be done
               Attn: Division of Refuge Management                                                                    capriciously. Estimates of oil reserves are speculative at best. The long-
               2343 Main Interior Building                                                                            term Impact of oil development on the wildlife of ANWR to still a basic
               lath and C Sts, NW                                                                                     unanswered question. We will all have to live with the consequences of
               Washington, DC 20240                                                                                   destroying this Irreplaceable area if that decision to made now; but if we
                                                                                                                      could defer a decision and make it more out of national need and on a solid
                                                                                                                      factual basis.rather than for temporary political gain, we believe our
                   The following comments by the Juneau Audubon Society concern the Draft                             country would be far batter served.
               1002 Report on oil and gas development on the Arctic National Wildlife
               Refuge (ANWR). Juneau Audubon objects to the SecretaryIa recommendation for                                                                    Sincerely,
               full oil leasing for the following reasons:

                   Due to the importance of ANWR for its unique wildlife, we would like
               oil and gas leasing postponed until there is a documented need for such
               development. The fragile and unique ecosystems in the arctic are being                                                                              Jo)y @Ra 1 "Alabac&k"
               rapidly developed the world over leaving very few areas for the wildlife                                                                            Conservation Chair
               that has played such a critical role In native subsistence and the ecology                                                                          Juneau Audubon Society
               of the arctic.                                                                                                                                      Box 1725
                                                                                                                                                                   Juneau, AK 99802
                   ANWR is not just a typical example of the Alaskan arctic coast. Unlike
               the Prudhoe Bay area, the caribou at ANWR are part of one of the largest and
               most far-ranging herds in the Alaskan arctic. The Alaska pipeline has
               restricted the movement of caribou at Prudhoe Day, but the caribou have
               survived since they can still access most of their traditional range. At                            _,,.@cs,Governer Steve Cowper
               ANWR howeverl oil development will likely make the traditional caribou                                     Representative Don Young
               migration to boreal forests in Canada difficult at best. The lose of this
               herd and the wildlife associated with it would have a major environmental
               impact on the Alaskan arctic and on the native people of Canada and Alaska.

                    Even on strictly economic terms, we feel the national interest would
               be better served by developing alternative energy sources and giving energy
               conservation a more important role in the nation's long-term energy plans.
               This oil will be available in future years when there may be a greater need
               for it than there is now. A world-wide oil glut has greatly depressed oil
               prices. Why should we squander Alaska's non-renewable resources In this way
               right now?   The natural values of ANWR, especially its unique fish,
               wildlife, and wilderness are much more important and irreplaceable than any
               amount of oil that can be recovered. And the value of such unique areas will
               only increase with time as al I of the unprotected areas of the arctic are
               developed. The risk of Jeopardizing our fish and wildlife resources,
               subsistence uses, and this rare wilderness, is too great a price to pay for
               oil that would only supply at most 4% of the total U.S. demand.

                                                                    A&I

                                                                 81 R. Roberts
                                                                 Chatmon and
                                                                 VW Executive Officer

                                                                 Viodd Headquarters
                                                                 Courthouse Plare Northeast
                                                                 DaVRA Ohio 45463

                                                                 Telephoner. 513-222-6323
                        January 20, 1987                                                                                     Director
                                                                                                                             U.S. Fish and Wildlife Service
                                                                                                                             January 20, 1987
                        Director                                                                                             Page 2.
                        U.S. Fish and Wildlife Services
                        Division of Refuges
                        Room 2343. Main interior Building                                                                    future. To accomplish this objective, we must undertake discovery
                        18th and "C" Streets, N.W.                                                                           and.then development of the coastal plain's potential petroleum
                        Washington, D. C. 20240                                                                              resources. I support your efforts and recommendations regarding
                                                                                                                             making the Artic Natural Wildlife Refuge (ANWR) available for such
                        Gentlemen:                                                                                           exploration.
                        In my capacity as Chairman of The Natural Resources Committee of                                     Sincerer!41
                        the United States Chamber of Commerce, I wish to express my support
                        of the Department of the Interior's Fish and Wildlife Services
                        recommendation that Congress enact legislation making the entire
                        coastal plain portion of the Arctic National Wildlife Refuge (ANWR)                                  BRR-lb
                        .in Northeastern Alaska available for oil and gas leasing, with
                        necessary environmental safeguards.                                                                  cc: Susan Connolly, US Chamber

                        It is important to the long range supply prospects of the United
                        States that we identify the location of the most promising oil and
                        gas prospects that exist on our Federal lands. I believe the most
                        promising on-shore frontier Is the 1.5 million acre coastal plain
                        in the ANWR.

                        As Chairman and CEO of The Mead Corporation, which is a major owner
                        and user of forest resources within the United States, I am aware
                        of the need for the extreme care that must be taken to protect the
                        valuable natural resources of this area. I am also confident that
                        with proper regulations we can ensure environmental Integreity in
                        all oil and gas operations that may eventually result in the area.

                        In summary, it is vitally necessary that our nation continue its
                        orderly oil and gas development to insure our energy and economic

                                                                        od 0 Mien,
                                                                                                  require that areas of potentially vast oil and gas resources, such
                                                                                                  as the Alaska coastal plain, not be closed off to energy exploration
       American Farm Bureau Federation                                                            and development.
                                                                     WASHINGTON OFFICE
                                                                     400 MARYLAND AVS.. ILW.            The American Farm Bureau Federation, for our more than 3
                                                                         SWIM foe                 million families nationwide, urges Congress to open the ANWR coastal
                                                                     WASHIMOTON. D.C. RW24
                                                                     AN" COD9.202 - &0"222        plain for oil and gas exploration and development.

                                                                                                                                Sincerely,

                                                                                                                                     4       17
                                           January 20, 1987.                                                                    John C. Datt
                                                                                                                                Executive Director
                                                                                                                                Washington Office
           Mr. Prank Dunkle, Director                                                             JCD/laf
           U.S. Fish and Wildlife Service
           Division of Refuges
           Main Interior Building, Room 2343
           18th and C Streets, N.W.
           Washington, D.C. 20240

           Dear Mr. Dunkle:

                 The American Farm Bureau Federation, our nation's largest
           organization of farmers and ranchers, endorses the U.S. Department
           of the Interior's recommendation that Congress enact legislation to
           permit oil and gas exploration on the Arctic National Wildlife
           Refuge (ANWR) coastal plain.

                 while meeting in Anaheim on January 15, 1987, delegates to our
           national convention adopted a resolution supporting the development
           of energy in Alaska's coastal plain. This resolution originated
           with the Alaska Farmers and Stockgrowers Association (Alaska Farm
           Bureau) which adopted the position at its annual meeting in November
           1986. It states:

                 "We urge Congress to open the Alaska Arctic National Wildlife
                 Refuge Coastal Plain to environmentally responsible oil and
                 gas exploration, development and production."

                 The Farm Bureau believes that it is imperative that  our nation
           develop all its sources of energy. Adequate and consistent supplies
           of energy are critical if agriculture is to continue to meet our
           nation's demands for fuel and fiber.

                 Nearly 80 percent of the energy used in agricultural
           production is derived from petroleum. Petroleum fuels have been
           an important contributor to the dramatic gains in agricultural
           productivity during this century.

                 Current economic conditions in both U.S. agriculture and
           energy industries make it all the moreimportant that domestic oil
           and natural gas production be encouraged and the dependence on oil
           imports be minimized. United States agricultural and energy needs

    NANAMUIT
    CORPORATION

    	Anaktuvuk Pass, Alaska 99721 . Village phone (907)  1-3227

    William P. Horne									January 19, 1987
    Assistant Secretary for Fish
    	and Wildlife Parks
    U.S. Fish and Wildlife Service
    Attn: Division of Refuge Management
    2343 Main Interior Building
    18th & C St., N.W.
    Washington D.C. 20240

    Dear Mr. Secretary:

    	I am writing to present the comments of the Anaktuvuk people
    on the draft report concerning resource assessments and
    recommendations for the Arctic National Wildlife Refuge Coastal
    Plain.  We believe that we have a special prespective on one of the
    alternatives contained in the Secretary's draft report, that
    is, Alternative E that would designate the NWP.  Cosatal plain as
    "wilderness".

    	My people live in the Brooks Mountain Range about 250 miles
    southwest of Kaktovik.  For many, many years we have used the
    lands in the central Brooks Range and the foothills to the north
    to maintain our culture and traditional lifestyle, and for
    subsistence hunting, fishing and trapping.

    	In 1971 congress passed the Alaska Native Settlement
    Act in which our aboriginal rights were extinguished in exchange
    for cash payments and, most importantly, the right to receive
    title to about 92,000 acres of land.  It is important to point out
    that the land we received under ANCSA was far less than the area
    we have traditionally used for subsistence purposes and continue
    to use even today.

    	In the first few years after the passage of ANSCA, we saw
    very few outsiders in our village and even fewer in the
    surroundings lands that we continued to use for subsistence
    purposes.  It was not until Congress began to consider the Alaska
    lands legislation in the late 1970s that hikers and others began
    to come to the village with greater frequency to gain access to
    the surrounding mountain area.

    William P. Horn
    January 19, 1987
    Page Two

    	In 1980, Congress passed the Alaska National Interest Lands Conservation
    Act -- ANILCA as it has come to be known--and as part of that legislation created
    Gates of the Arctic National Park.  About 69,000 acres of our ANCSA lands lie
    within this 8 million acre national park.  Within th new national park, Congress
    also designated almost all of the lands surrounding our ANCSA lands, as well as
    those selected by ASRC in the same area, as "wilderness".

    	At the time ANILCA became law, we dit not realize that "wilderness" designation
    would mean servere restrictions on the type of activities thate could
    be conducted on such lands.  For instance there can be no mechanized vehicular
    activities on "wilderness" lands unless "snowmobiles, motorboats, and other means
    of surface transportation traditonally employed" for subsistence purposes are
    used.

    	Although we continue to use snowmobiles in the winter months for access
    to subsistence resources, In recent years the Anaktuvuk people have come to use
    lightweight, all-terrain vehicles during the summer months to travel to areas
    away from the village for subsistence hunting, fishing and trapping.  We feel
    that use of ATVs has been part of a slow, evolutionary adaptation of modern
    means of transportation to engage in our traditinal pursuit of subsistence
    resources.

    	The National Park Service, however, in asministering Gates of the Arctic
    National Park, has interpreted the law to prohibit the use of ATVs in the
    "wilderness" area where many of our subsistence resources--such as caribou--
    are found.  The Park Service argues thate ATVs are not "means of surface
    transportation traditionally employed" for subsistence purposes.  This legal
    interpretation has resulted in severe hardships on the Anaktuvuk people in their
    efforts to obtain access to vitally needed subsistence resources during the
    summer months.  It is difficult for us to distinguish between snowmobiles, which
    are permitted, and ATVs, which are not.  Each is a relatively modern form of
    transportation that allows us access to subsistence resources in the winter and
    summer seasons respectively.

    	To resolve this problem, we have had to engage in costly and time--consuming
    negotations with the National Park Service.  It now appears that the only
    possible solution to the problem may be some kind of a new land exchange as well
    as new federal legislation that would possibly de-authorize the "wilderness"
    areas that we continue to use for subsistence purposes.

    	My purpose in providing these comments is a limited one.  It is to bring to
    your attention the problems we have encountered in attempting to carry out our
    traditional subsistence lifestyle in a "wilderness" area.  Therefore, we recommend
    that the Secretary not adopt Alternative E, which would place the ANWR Costal
    Plain in "wilderness" designation

    							Very Truly Yours,

    							Nunamiut Corporation
    							Harry K. Hugo, Vice - Pres.
    							for Jacob Ahgook
    							Jacob Ahgook
    							President

                                                                                                                                            -2-

                                                                                                               The bad part is just exactly what is being proposed by the
                                                                                                          Coastal Plain Resource Assessment. Public and private utilities
          SCOTf W. REED, Attorney at Law/P. 0. Box A/Coeur d'Alene, Idaho 83814/(208) 664-2161            greatly expanded their resources in the late 60's and early 70's
                                                                                                          upon the assumption that growth and consumption would continue on
                                                  January 21, 1987                                        a straight line forever.     I had the privilege of hearing Donald
                                                                                                          P. Model proclaim to the Idaho Water Resource Board the absolute
                                                                                                          reliability of Bonneville Power Administration's straight line
                                                                                                          projection.

                                                                                                               The pell mell government effort to increase production led
             Division of Refuge Management                                                                to the Washington Public Power Supply System fiasco that has
             U.S. Fish and wildlife Service                                                               devastated private bondholders although perhaps enhancing the
             2343 Main Interior Building                                                                  income of a large number of lawyers., The only good thing that
             18 & C Street, N.W.                                                                          can be said about the WPPSS disaster as designed and promoted by
             Washington, D.C.    20240                                                                    now Secretary Hodel is that. most of the plants will never be
                                                                                                          completed and therefore will not.compound the problem.
                       Re: Draft Arctic NWR, Alaskar                                                           The Pacific Northwest Power Planning Council has promulgated
                             Coastal Plain Resource Association                                           a Fish and Wildlife Program that is intended to restore the
             Dear Sirs:                                                                                   damage wrought by excessive hydroelectric construction.           While
                                                                                                          there are some funding problems implementing this program, the
                  As a member of the board of directors       of National Audubon                         direction is very clear. It is to restore wildlife.
             Society, I received a copy of the-testimony of President Peter
             A. A. Berle made on behalf of National Audubon Society concerning                                 In the Arctic you have the much preferable alternative which
             the draft Arctic National Wildlife Refuge assessment given                                   is to avoid the destruction in the first place.         In the Arctic
             January 9, 1987i This letter is written in total support of the                              this is particularly critical because there is little likelihood
             statement made by President Berle.                                                           of subsequent mitigation or restoration.
                  Let me add a little bit more in opposition to opening the                                    Those who would promote further drilling in the Arctic
             coastal plain to leasing at this time. in the Northwest we have                              either should be committed for psychiatric examination or else
             a surfeit of electric energy. Although this energy is not oil,                               they have already been in some type of mental ward out of touch
             it is directly and integrally related.                                                       with the energy world over the past ten years.          It was only a
                                                                                                          couple of years ago that Congress was being told it should repeal
                  When hydro electric energy started becoming surplus in the                              the ban on exports of oil to Japan so that Alaska could find a
             early 1980's the Northwest public and private utilities aggres-                              financially viable market for what was coming out of its pipe-
             sively sold their energy to California utilities.        Now with the                        line.
             advent of cheap oil, the California companies are switching back
             to oil generation which produces cheaper electrical energy than                                   Because of my appointment by National Audubon to the board
             can be supplied from here. The Northwest utilities are now in a                              of the Garrison Trust Fund, I have had the occasion to visit
             real financial bind.                                                                         North Dakota acouple of times in the past year.          The governor
                                                                                                          and the legislators of North Dakota would certainly be able to
                  The cause of the surplus in the Pacific Northwest in simple                             give you an opinion about        the desirability of further oil
             terms is two fold, one good and one bad. This area, particularly                             exploration and development at this time.
             in the state of Washington, had the greatest per capita electric
             energy consumption in the United States.          Major conservation                              North Dakota undertook      a major oil and coal gasification
             programs were undertaken both as a consequence of the Northwest                              development program in the       1970's.    The voters approved an
             Power Act and on the initiative of private utilities. The result                             initiative which imposed a major severance tax.        The result was
             has been a major reduction in resident as well as industrial                                 that for a time the North Dakota state treasury was overflowing
             consumption. This has been enhanced by the natural intelligence                              with oil money which of course got promptly allocated to impor-
             of the consumer who reacted to higher prices by cutting back.                                tant state programs such as higher education.

                  With the collapse Of OPEC and the decline In oil prices,
             development stopped. The coal gasification plant closed. The
             newspaper in Sismark reported when I was there last week that the
             remainder of the coal gasification company now occupies one room
             In an old office building in Minot.
                  The state to running a $100 million deficit.        The only
             possibility of financial recovery In this farming state Is for a
             return to power by OPEC and a corresponding increase In oil
             prices. The last thing they need is any further oil development
             of the type proposed for the Arctic.
                  My comments have been economic. but my concern is for the
             wildlife as so well expressed by President Berle. I urge you to
             go back to the drawing board and to put the entire Arctic
             National Wildlife Refuge In the deep     freeze-for which it was
             designed and intended.

                                                Your

                                                 c   (0. Reed

             cc% Peter A. A. Berle
                                               @
                                                 our

                                                 C' t

                                                                                                meet strict federal and state environmental standards and are
                                                                                                closely monitored by the appropriate environmental agencies.
                               STATE OF SOUTH DAKOTA                                                      We applaud the Interior Department's draft report on
                                       EXECUTIVE OFFICE                                         the ANWR coastal plain and endorse its proposedrecommendation
       GEORGE S. MICKELSON            STATE CAPITOL BUILDING             0051773-3212           that this important area be opened to oil and gas leasing to help
           GOVERNOR                 PIERRE, SOUTH DAKOTA 57601                                  meet our future energy needs.
                                    January 15, 1987                                                                          Sincerely,

            Mr. Frank Dunkle, Director
            U.S. Fish and Wildlife Service                                                                                                       N-
            Division of Refuges, Room 2343
            Main Interior Building
            18th and C Street, NW                                                               GSM:ls
            Washington, D.C. 20240

            Dear Mr. Dunkle:

                      Secure and reliable energy supplies are critically
            important to South Dakotans who use more gasoline and diesel fuel
            per capita than the national average to operate our farms and
       T    heat our homes.
       OD             That is why we support the proposed recommendation in
            the U.S. Department of the Interior's draft report that the
            Congress permit oil and natural gas development activities on the
            Arctic National Wildlife Refuge (ANWR) coastal plain. We believe
            that development of the potentially vast oil and gas resources
            beneath the coastal plain is essential in helping meet future
            U.S. energy supply needs and reducing our dangerously heavy
            dependence on oil imports.

                      At a time of continued political turmoil and terrorism
            in the Middle East, the national interest requires that we
            increase the search for and development of the oil and gas
            resources within our borders. The ANWR coastal plain provides
            one of the nation's best opportunities for major new discoveries.
            As the Interior Department's draft report states, "The ANWR
            coastal plain is clearly the most outstanding oil and gas
            frontier remaining in the United States and could contribute
            substantially to our domestic energy supplies.

                      The petroleum industry's nearly twenty years of
            experience in developing oil fields on the Alaskan North Slope
            proves that oil and gas activities are fully compatible with the
            arctic environment and wildlife and would pose no threat to the
            coastal plain's ecology. We are aware that such operations must
                                       4 0-aa
                                         ,'14

                                                 A

                January 27, 1987
                                                                                                                          U.S.Pish and Wildlife Service
                                                                                                                          January 27, 1987
                                                                                                                          Faqe 2
                                                     To THE

                U.S. Fish and Wildlife Service
                Division of Refuqe Management Resources
                2343 Vain Interior Buildinq                                                                               Now more than ever, we must move ahead with this ptcrtunity, especially
                18th & C, N.W.                                                                                            since it has been proven that the technology exists today to develop arctic
                Washington, D.C. 20240                                                                                    petroleum resources in an environmentally sound manner.
                Dear Sir:                                                                                                 in closing, I appreciate the opportunity to eqxmw our local interest and
                                                                                                                          support for this project of national concern.
                I am writing in regards to the U.S. Fish and Wildlife Service           report
                1002(H) an oil and gas leasing in the RM Coastal Plain.                                                   Sincerely,
                The City of Valdez, Alaska goes on record m44portinq and strongly        urging                           CITY CP VALDEZ, ALAM
                the Congress of the United States to open the ANWR coastal plain to
                environmentally responsible oil and gas exploration, development and
                production.

                The development of world-class oil deposits in the refuge proposed for
                leasing would promote economic development, reduce our dependence an
                foreign oil, promote environmental sound and orderly development in the                                   JD/Mr/Irf
                absence of an energy crisis, increase revenues from taxes and royalties,
                strengthen national security interests, restrain the national trade deficit
                and create thousands of new jobs.

                Although there is plenty of oil on the market today, domestic oil reserves
                are plummeting while consumption is rising. Prudhoe Bay, America's largest
                oil field, accounts for 20 percent of U.S. domestic crude production.
                However, it has already been pumped half empty and a steady decline in
                production will soon begin. As the City of Valdez is the terminus for the
                pipeline. the economic impact of that decline, based on value alone, is
                already being felt.

                If America forgoes or delays this major opportunity to reverse its
                increasing dependency on foreign oil, our vulnerability to oil price
                increases or shortages will increase to dangerously high levels in the next
                decade. The best way to assure that the United States will have a secure
                supply of oil is to pursue exploration and development here at ham and the
                best chance to find a new world-class domestic supply of oil is in the
                coastal plain of RM.

                7he environmental issue is not a wilderness versus no wilderness issue.
                7here are already 8 million acres of designated wilderness in ANKR_ 7te
                1.5 million acre coastal plain comprises only eight percent of the refuqe.
                Moreover 92 percent of the refuge is off-limits to oil and gas development.
                A multi-year record of petroleum development in arctic Alaska clearly
                demonstrates that such development can and does co-ekist with the
                environment.
                                                            ,Ole
                                                   A&I

                                            P_ 0. BOX 307 VALDEZ, ALASKA 99686
                                  TELEPHONE (997) 835-4313 . TELEX 25-381 . TELECOPIER (907) M2992

    ASCC
    ALASKA STATE CHAMBER OF COMMERCE
    Regional Office
    301 B Street, Suite 405
    Anchorage, Alaska 90501
    (907)278-3741

    February 4, 1987

    Director
    U.S. Fish and Wildlife Service
    Divisionof Refuge
    Room 2343 Main Interior Building
    18th and "C" Street
    Washington, D.C. 20240

    Dear Sirs:

    Speaking on behalf of the Alaska State Chamber of Commerce as its immediate Past
    Chairman, we declare our full support for Secretary Hodel's recommendation to open
    the Coastal Plain of the Arctic National Wildlife Refuge to oil and gas exploration,
    development and production under reasonable measures to assure the protection of wildlife
    and the environment.

    The Alaska State Chamber of Commerce is served by a Board of 50 representing business
    communities statewide... from Nome to Ketchikan. This communication speaks for 1,196
    of our members.

    Our support results from studies of the issues raised in the Secretary of the Interior's
    Study. We do not faul the conclusions presented in the study and our experiences over
    the years substantiate the major points made.

    Of major conern is Alaska's present oil production that yeilds 20% of our nation's
    production is declining with nothing coming up to sustain this contribution to our national
    security. Even with much of the infrastructure needed to brign ANWR Coastal Plain oil
    to U.S. markets already in place, it will take 10 years to bring any new fields into
    production. In the meantime, our nation's dependence on foreign oil grows right along
    with our trade deficit.

    How can anyone in good conscience jeopardize our nation's security by ignoring the
    responsible petroleum development in Alaska's giant Prudhoe Bay field just 65 miles to
    the West of the Coastal Plain? How many billions of dollars must be wasted in repeated
    studies of indentical issues and concerns?

    We recognize our support is critical to the opening of the Coastal Plain of ANWR and
    want you to know it is in place, 1.195 times.

    Sincerely,

    Alvin H. Fleetwood
    Director, Executive Committee

    Washington
    Environmental
    Council

    P.O. Box 4445
    76 S. Main Street
    Seattle, Washington 98104
    206-623-1483

    February 2, 1987

    U.S. Fish and Wildlife Service
    Attn: Division of Refuge Management
          Resources
    2343 Main Interior Building
    18th & C Streets Northwest
    Washington, D.C. 20240

    Re: ANWR Coastal Plan Resource Assessment

    Dear Director:

    These comments are submitted on behalf of the
    Washington Environmental Council. The Washington
    Environmental Council, of WEC, is a non-profit
    umbrella organization made up of over 65 separate
    conservation and recreation organizations. In
    addition the WEC has a separate membership of
    over 1100 persons.

    The WEC does not usually comment upon activities
    outside of Washington. An exception to that
    practice has been made here on account of the
    important national interests at stake in the
    Arctic National Wildlife Refuge. A number of
    WEC's own members have visited to refuge; a much
    larger number expect to be able to enjoy such an
    opportunity.

    The value of the refuge is self evident. It is
    the sole protected conservation unit on the north
    slope of Alaska. It offers the greatest hope of
    preserving a portion of the unique Arctic
    environment in its pristine State; its importance
    is more than national. As an integrated intact
    ecosystem the rufge is subject to no fewer than
    six international creaties and maintains
    six international treaties and maintains
    importance for the entire northern hemisphere.
    Because of these outstanding attributees to WEC
    urges the selection of Alternative E, wilderness
    designation.

               During the debates that led to the Section 1002 compromise, the                             In closing we would have to agree with Ted Stevens' metaphor
               Senate fully appreciated the wilderness characteristics of the                              that was articulated during the ANILCA debates: Indeed a
               coastal plain by recognizing that it, of all other areas,                                   pipeline across the coastal plain would be tantamount to a
               should be the last to be explored for petroleum resources.                                  slash across the face of the Mona Lisa.
               Nothing in the draft resource assessment warrants changing      that
               priority.  As it currently lies, the coastal plain by no means                              Thank you for your consideration of these comments.
               holds the last remaining hope for America's petroleum needs.
               In the six years since the passage of KNCILA hundreds of                                                                                  -Sincerely yours,
               thousands of acres of both onshore and offshore lands have been
               opened for oil exploration and development. America's
               potential for petroleum production literally remains untapped.
                                                                                                                                                                A@    id-14.
               The prospects of the coastal plain do not call for a reordering                                                                            President
               of priorities. A less than twenty percent chance of
               economically recoverable deposits hardly justifies a one                                    cc:   Senator Bennett J. Johnston
               hundred percent chance of desecration of this pristine                                            Senate Energy and Natural Resources Committee
               environment. Even if best estimates proved true, the coastal
               plain would only render a minute fraction of the U.S. oil                                         Honorable Steve Cowper
               demand during the period of production. Development of the                                        Governor of the State of Alaska
               coastal plain will not make the U.S. any more energy
               independent. Nor will it save the economy of Alaska.                                              Glen W. Elison
               Predicated upon the price of   oil at  $33 - $40 per barrel, it is                                U.S. Fish and Wildlife Service
               highly unlikely that the price will escalate sufficiently for
               the state to realize any of its royalty interests. Moreover,
               even if development proceeds, any return in at least 15 years
               away.
       :P      Events of the past six years, If anything, have d    ictated that
       6)      the fate of th; coastal plain @e sealed with wilderne4s
        L      designation. The Section 1002 study was directed at a time
               when the American economy was suffering the consequences of the
               Arab oil cartel. Since then the cartel has dissolved, oil
               prices have dropped to their true relative value, most areas of
               the continental shelf with high petroleum potential have been
               opened for leasing and exploration, and the true prospects of
               the coastal plain have been determined. Through the 1002
               report Congress now knows that the coastal plaints not another
               Prudhoe Bay. In view of all of these factors, Congress can now
               confidently designate the coastal plain for wilderness without
               the fear of sacrificing America's energy independence.

               It should be kept in mind that much is preserved and nothing is
               lost by such designation. The ANWR, with its coastal plain, is
               one of the true wilderness areas of our nation. in keeping
               with the spirit of the Wilderness Act it is one of the few
               areas of our country which truly remains in its primeval
               state. To preserve such areas is far more imporant for out
               heritage than the immediate financial gain of short term
               exploratory activities. Should we ever get to the point where
               the coastal plain is our last prospect for petroleum
               development, it could, with congressional approval, be resorted
               to in desperation. Until that time, such a treasure as the
               coastal plain should not be hocked, especially at fire sale
               conditions.

                                                                                                                     ALASKA CONTROLS, INC.
                                                                                                                            MAN-111M IIIRIR% RIPRIMNIAIRI

                                                                                                          1"' It-

                                                                                                                                            February 2, 1987

                                                  February 2, 1987
                                                                                                  U.S. Fish and Wildlife Service
                                                                                                  ATTENTION: Division of Refuge Management
                                                                                                  2343 Main Interior Building
           U.S. Fish and Wildlife Service                                                         18th and C Streets, N.W.
           ATTENTION: Division of Refuge  Management                                              Washington, D.C. 20240
           2343   in interior Building
           18th M:d C Street., M.W.                                                               REFERENCE: ANWR Draft Environmental Impact Statement
           Washington, D.C. 20240
                                                                                                  Dear Sirs:
           REFERENCE: ANWR Draft Environmental Impact Statement
                                                                                                  we endorse  the recommendations contained in the recently
           Dear Sire:                                                                             released draft Section 1022 (h) report and draft
                                                                                                  Environmental Impact Statement that the Coastal Plain of the
           We endorse the recommendations contained in the recently                               Arctic National Wildlife Refuge (ANWR) should be opened to
           released Draft Section 1022 (h) Report and draft                                       oil and gas leasing, exploration and development with
           Environmental impact Statement that the Coastal Plain of   the                         environmental safeguards.
           Arctic National Wildlife Refuge (ANWR) should be opened to
           oil and gas leasing, exploration and development with                                  ANWR is the most probable place to find oil in North America
           environmental safeguards.                                                              in significant amounts. This is important to the nation
                                                                                                  becasue of our strong current dependence upon foreign oil
           ANWR is the most probable place to find oil in North America                           and becasue, in the future, our reliance upon foreign oil
           in significant amounts.  This is important to the nation                               will be even more significant (by the year 2000, when ANWR
           because of our strong current dependence upon foreign oil                              production could be obtained, it is estimated that America
           and because, in the future, our reliance upon foreign oil                              will import upwards of 65% of its oil).
           will be even more significant (by the year 2000, when ANWR
           production could be obtained, it is estimated that America                             The environmental record of the oil industry on the North
           will import upwards of 65% of its oil).                                                Slope is spotless--no significant environmental harm has
                                                                                                  Fesulted from the major developments there so far. The oil
           The environmental record of the oil industryon the North                               industry will operate safely in ANWR, without affecting the
           Slope is spotless--no significant environmental harm has                               caribou and other wildlife which are present there, just like
           resulted from the major developments there so far.   The oil                           it has in Prudhoe Bay and Kuparuk', where the Central Arctic
           industry will operate safely in ANWR, without affecting the                            Caribou herd has increased in size 5 times in the last 15
           caribou and other wildlife which are present there, just                               years.
            like it has in Prudhoe Bay and Kuparuk, where the Central
           Arctic Caribou herd hasincreased in size 5 times in the                                Thank you for this opportunity to comment upon the draft
           last 15 years.                                                                         section 1002 (h) Report and Environmental Impact Statement.
           Thank you for this opportunity to comment upon the draft                               sincerely,
           Section 1002 (h) Report and Environmental Impact Statement.
           Sinc7e,lyf                                                                             Mack Hudson
                                                                                                  Vice President

           William H.  urtis
           Owner

                     2312 Uncoln Avenue Anchorage, Alaska 99517 (907) 248-4933

                January 19, 1987.

                U. S. Fish & Wildlife Service
                ATTN:  Division of Refuge Management
                2343 Main Interior Building
                18th & C Streets, N.V.
                Washington, D.C. 20240

                RE:  U.S. Department    of Interior 1002 Report Concerning ANWR

                Gentlemen:                                                                                       U.S. Fish and Wildlife Service
                                                                                                                 ATTN: Division of Refuge Management
                As interested Individuals we want to express our support of oil                                  2343 Main Interior Building
                and gas exploration in the Artie National Wildlife Refuge (ANWR).                                18th L C Streets. W.W.
                                                                                                                 Washington. D.C. 20240
                Alaska currently supplies twenty percent of the U.S. consump-
                tion of oil, most of which is from the large Prudhoe Bay field,                                  RE: U.S. Department of Interior 1002 Report Concerning ANWR
                now beginning to decline In production.        America needs to find
                new sources of petroleum in order to keep foreign dependence at                                  Gentlemen:
                a Minimum.
                                                                                                                 I am writing to express my full support for the Secretary of the Interior's
                The development of the ANWR would be In harmony with the enviro-                                 recommendation to open the Coastal Plain of the Arctic National Wildlife
                sent.  The twenty year history. of the near Prudhoe Bay field                                    Refuge to oil and gas exploration, development and production under
                shows that wildlife and oil development are indeed compatible.                                   reasonable measures to assure the protection of wildlife and the environment.
                Caribou in North Slope oil fields have tripled since development
                and bioligists expect ANWR caribou to adapt as well.                                             The resource estimates ranging up to 29.4 billion barrels of oil and 64.5
                                                                                                                 trillion cubic feet of natural gas in-place, which are set forth in the
                If the ANWR Coastal Plain Is approved for exploration. the        multi-                         Coastal Plain Resource Assessment of November 24, 1986. are very significant.
                billion dollar investments    Irequ-ired for development would provide                           If petroleum reserves of this magnitude are to be found on the Coastal Plain,
                jobs and economic benefits throughout the entire United States.                                  this would represent a substantial contribution to the energy security of
                                                                                                                 our nation.
                Concerned Citizens,
                                                                                                                 A decision to open the Coastal Plain would also represent thousands of jobs
                                                                                                                 an: bi::i ns of dollars in business opportunities all across our nation.
                                                                                                                 h
                    /Zed-                Ant,   4(*401d@w                                                        T  PO n7ial benefits to our economic well-being make it unthinkable
                                                  ,,/,,c, *'*mA-' 49                                             that the Coastal Plain may be closed to development.
                                                                                                                 The petroleum industry's proven record in developing the super-giant Prudhoe
                                                                                                                 Bay field demonstrates that oil and gas development.can be undertakin while
                                                                                                                 still protecting wildlife and environmental resources.

                                                                                                                 S I ncere I y

                                                                                                                                       7@-

                                                                              Cf

                     eez

                   U.S. Fish and Wildlife Service
                   Attn: Division of Refuge Management
                   2343 Main Interior Building
                   18th and C Streets, N.W.                                                                                                                                                    January 28,1987
                   Washington, D.C.         20240

                               Re: ANWR Draft        Environmental Impact Statement

                   Dear Sirs:
                               We endorse the recommendations contained in the                                                       U.S. Fish and Wildlife Service
                                                                                                                                     ATTN: Division of Refuge Management
                   recently released draft Section 1002(h) Report and draft                                                          2343 Main Interior Building
                   Environmental Impact Statement that the Coastal Plain of                       the                                18th & C Streets, N.W.
                   Arctic National Wildlife Refuge (ANWR) should be opened to oil                                                    Washington, D.C. 20240
                   and gas leasing, exploration and development with environmental
                   safeguards.                                                                                                       RE: U.S. Department of Interior Draft Report and
                                                                                                                                           Recommendation to the U.S. Congress and Legislative
                               ANWR is the most probable place to find oil in North                                                        Environmental Impact Statement (i.e.. 1002 Report)
                   America in significant amounts. This is important to the nation
                   because of our strong current dependence upon foreign oil                                                         Gentlemen:
                   (approximately 43% of America's oil is imported in 1986) and
                   because, in the future, our reliance upon foreign oil will be                                                     1, am writing to express my full support for the Secretary of the Interior's
                   even more significant (by the year 2000, when ANWR production                                                     recommendation to open the Coastal Plain of the Arctic National Wildlife Refuge to
                   could be obtained, it is estimated that America will import                                                       oil and gas exploration, development, and production under reasonable measures
                   upwards of 65% of its oil).                                                                                       to assure the protection ofwildlife and the environment.
                               The environmental record of the oil industry on the                                                   The resource estimates ranging up to 29.4 billion barrels of oil and 64.5 trillion cubic
                   North Slope is spotless -- no significant environmental harm                       has                            feet of natural gas in-place, which are set forth in the Coastal Plain Resource
                   resulted from the major developments there so far.                     The oil                                    Assessment of November 14,1986, are very significant. If petroleum reserves of this
                   industry will operate safely in hNWR, without affecting the                                                       magnitude are to be found on the Coastal Plain, this would represent a substantial
                   Caribou and other wildlife which are present there, just like it                                                  contribution to the energy security of our nation.
                   has in Prudhoe Bay and Kuparuk, where the Central Arctic Caribou
                   herd has increased in size 5 times in the last 15 years.                                                          A decision to open the Coastal Plain would also represent thousands of jobs and
                                                                                                                                     billions of dollars in business opportunities all across our nation. The potential
                               Thank you for this opportunity to comment upon                   the                                  benefits to our economic well-being make it unthinkable that the Coastal Plain may
                   draft Section 1002(h) Report and Environmental Impact Statement.                                                  be closed to development.
                                                          Sincerely yours,                                                           The petroleum industry's proven record in developing the super-giant Prudhoe Ba
                                                                                                                                     field demonstrates that oil and gas development can be undertaken while stir,
                                                                                                                                     protecting wildlife and environmental resources.

                                                                                                                                                                                              Sincerely,

                                                                                 IA4-

    January 10,  1987

    Dear Secretary Hode,

    	I feel that the Department of Interior would be unconscionably

    wrong to develop oil an gas in the coastal plains of th Arctic National

    Wildlife Refuge.

    	First, it is an uneconomical plan. I understand that if you could

    recover the small amount of 600 million barrels it would be at a costa

    of $33. a barrel.

    	Secondly, and most important, this area is the calving ground of

    millions of caribou and building of roads, pipelines, machinery, and

    men would be irreparable in that fragile environment.

    	There would be tremendous decline of caribou, polar bear, musk

    oxen, arctic fox and millions of birds that utilize that coastal plain.

    	Lastly the Eskimo require these birds and animals for their

    survival. We have no right to convert their hunting lands for our own

    purposes.

    	Please abandon this very bad plan.

    Sincerely,

    Mrs. Miles O'Brien
    171 Kenwood Road
    Grosse Pointe Farms, MI
    48236

    U.S. Fish & Wildlife Service
    Division of Refuge Mgmt.
    2343 Main Interior Building
    18th and C Sts. N.W.
    Washington D.C. 20240

    532 S. Gramercy Pl.
    Apartment # 407
    Los Angeles, CA 90020

    14 January 1987

    Gentlemen:

    	I am appalled to learn that the Interior
    Department proposes to allow oil and gas development
    on the coastal plain of the Arctic National
    Wildlife Refuge.
    	I used to actually believe that the Department
    of the Interior was there to protect the land
    obviously you see your mission as one of rape
    and pillage.
    	For a 20% chance of finding a few months
    supply of oil, you and the oil industry are eager
    To damage ireeparably a unique and fragile ecosystem
    and decimate the diverse and, in some instances,
    endangered wildlife population which lives therein.
    	The spirit of James Watt lingers like the odor
    of land drains.
    	America's wildlife and wilderness areas belong
    to all Americans not solely to a handful
    of myopie bureaucrats and greedy oil tycoons.

    Rat another way, you are selling something
    which in not yours to sell, to people
    who have no right to buy.
    	Your collective job is that of caretaker.
    If you can't, or won't discharge your duties
    properly, you can all be replaced.
    	The Arctic National Wildlife Refuge and
    it's inhabitants must be protected at all costs.
    The coastal plain should be designated as
    wilderness. Anything less is unacceptable.
    	No exploration, no exploitation.

    Yours Truly,

    Lynn Mills

    January 14, 1987

    U.S. Fish & Wildlife Service
    Attn: Division of Refuge Management
    2343 Main Interior Building
    18th and C Sts., NW
    Washington, D.C. 20240

    Re: Proposed OIl Leases in the Arctic Coastal Plain in Alaska

    Dear Sir or Madam:

    	I am writing to express my disbelief and outrage
    with regard to the Department of the Interior's proposed
    exploitation of a national treasure, namely, Alaska's
    Arctic Coastal Plain, an awesome 1.5 million acre expense
    of American Wilderness.

    	This is an 111-considered development in that
    this refuge is one of the most expansive, fragile, and
    diverse areas that is still intact in this country --
    and which can be enjoyed by future generations of Ameri-
    cans. To allow oil and gas development in this area
    would mean the destruction of an internationally signi-
    ficant wildlife and wilderness resource for what amounts
    to an insignificant gain on the part of the oil and gas
    industry.

    	Although this letter of opposition against the
    interests of the oil and gas industry in the development
    of this area is similar to the efforts of David fighting
    Goliath, I still believe that in this country, the voice
    of the "little" people does matter. The beauty of the Arc-
    tic National Wildlife Refuge must be preserved in its
    natural state--to develop it in this fashion will rob us,
    and our children, of a unique national asset. The coastal
    plain should be designated as wilderness.

    Respectfully,

    cc: Hon. ALfonse M. D'Amato
        Hon. Daniel P. Moynihan

    Odvita M. Porter
    Champion International
    805 Third Avenue
    New York, NY 10022

            January 19, 1987                                                                                               Madison Audubon Society Inc.

            we do nOt believe it's worth endangering a fragile and diverse
            wildl  ife treasure for the chance of finding a few years' supply of
            oil. The unique wilderness and wildlife of the Arctic National
            Wildlife Refuge must take priority over oil development. Everday we
            are destroying the habitat of our wild animals, it must stop. This is
            the nation's opportunity to protect the wildlife left in this region.
           'This particular refuge comprises one of the most extensive; fragile
            and diverse ecosystems that we have and should be designated as                                     January 20, 1987
            wilderness. It should be the last place to go for oil and gas.
                                                                                                                    U.S. Fish A Wildlife Service
            We are writing today to let you know how very important it is to                                        Washington, DC
            INCLUDE THE ARCTIC NATIONAL WILDLIFE REFUGE IN THE NATIONAL
            WILDERNESS PRESERVATION SYSTEM. We must preserve this critically                                        Dear People#
            important habitat for so many of our beautiful wild animals, many               of
            which are already endangered.                                                                           be behalf of 2500 members in the Madison Aud
                                                                                                                    the developing plans to open the areas of the'
            NAME                                    ADDRESS                                                         oil and gas leases. In our opinion. this rep"
                                                                                                                    stewardship of our national resources. It Is Madison Audubon's understanding
                                                                                                                    that the draft report has misleading deficiencies in its data, We believe that

                                                                                                        the resource assessment should be redone and time should be given for public
                                                                                                                    input.

                                                                                                                    The" In no national need for the marginal amount of energy which is projected

                                                                                                                    to be available in this coastal area. Yet, the wildlife diversity is some of

                                                                           IN                                       the richest an earth, 0ur Interests are best served by the protection of this
                                                                                                                    diversity. We strongly urge that you realize that the suggestion to open the
                                                                                                                    coast to energy development Is Ill-advised and that you withdraw the plan.

                                                                                                                    Sincerely.

                                                                                                                    Sharon Clark Gaskill
                                                                                                                    president, Madison Audubon Society
                                                                                                                    III King St.
                                                                                                                    Madison, Wisconsin 53703

            cc:    Interior Secretary Donald Hodel
                   Senator Strom Thurmond
                   Senator Earnest F. Hollings
                   Congressman Floyd Spence
                   Defenders of Wildlife

                                                                                                                                      III lewd

    DONALD HODEL							25 NOVEMBER 1986
    SECRETARY OF THE INTERIOR
    18TH & C STREETS N.W.
    WASHINGTON, D.C. 20240

    MR. HODEL,
    									Oil Drilling
    									Proposed for
    									Alaska Refuge
    OIL DRILLING IN A WILDLIFE REFUGE
    IS A BLASPHEMOUS
    UPON NATURE AND THIS COUNTRY.

    YOUR SUGGESTIONS OF INCREASED USE
    OF ALTERNATE ENGERY SOURCES AND
    REDUCTION IN OIL CONSUMPTION ARE
    WONDERFUL. PLEASE PURSUE THEM!

    IF POSSIBLE, TAKE A TRIP INTO THE
    WILDERNESS AND SPEND SOME TIME BY
    YOURSELF WITH NATURE. YOU CANNOT
    HELP BU COME AWAY WITH A GREATER
    APPRECIATION FOR THE NEED TO PRE-
    SERVE THE LAND IN ITS NATURAL STATE.

    TAKE A STAND FOR CONSERVATION, NOPT EXPLOITATION!!
    CREATE, DO NOT DESTROY!!

    MOST SINCERELY,

    STEVEN BOSANAC
    78 MARS
    SAN FRANCISCO, CA 94115

    CC; WILLIAM P. HORN, ASST. SEC OF INTERIOR
    GEORGE KELLER, CHEVRON										Washington
    									The Interior Department
    									setting the stage for a battle
    									with conservationists, tenta-
    									tively proposed yesterday that
    									all drilling be allowed in a large
    									wildlife refuge on Alaska's art-
    									tic coast.

    									A draft report made public by
    									the department's Fish and Wildlife
    									Service recommended that the
    									coastal plain within the Arctic Na-
    									tional Wildlife Refuge be opened
    									for oil and gas development.

    									William P. Horn, assistant inte-
    									rior secretary for fish and wildlife
    									said that the wildlife refuge offers
    									the possibility of "a supergiant oil
    									field that does not exist anywhere
    									else in the United States."

    									The report said the
    									oil and gas potentials are needed for
    									the nation's economic well-being
    									and for national security.

    									"The numbers say that there is
    									a good prospect here of another
    									Prudhoe Bay," Horn said. Prudhoe

    w
    WASHINGTON, D.C. 20240

    MR. HODEL,

                               Carpenter St. Croix Valley Nature Center                                                  Carpenter SL Croix Valley Nature Center
                               12805 St. Croix Trail Hastings, Minnesota 55033 612-437-4359                              12W5 St. Croix Trall Hastings, Minnesota 5=1 612-437-4359

           December 9, 1986                                                                           page 2, continued
           Donald Bodel                                    DEPT OF 1HTt:.R1,1j@
           Department of the Interior                                                                 it .is possible and somewhat easy to    calculate the billions of
           Interior Bldg.                              1103   .86. DEC 15 Al :31,                     barrels of oil and the trillions of cubic feet of gas which lies
           C. Street NW                                                                               under the Refuge. What Is not an easy to compute, but even more
           Washington, DC      20240                                                                  important,IIs the wealth In biological diversity, the long term
                                                         FRECUfl@@L                                   effects of man's activity in the Arctic   and the need for wildlife
                                                                                                      to have wildeCness areas free from man's influence.
           Dear Secretary  Bodel:
           This letter is  in response  to the interior Department's call f or                        I urge..you to recommend that the-Arct:Lc National Wildlife Refuge
           public comments on                                                                         be designated as wilderness. Please include my thoughts in your
                                  the draft report regarding oil and gas                              final report to-Congress.
           potential on Arctic National Wildlife Refuge.
                                                                                                      Thankyou for  giving me the opportunity to comment On this     issue.
           wildlife refuges are extremely important sanctuaries for all
           wildlife species. During a time when nature, an unaltered by
           man, is being pushed onto smaller and smaller parts of our                                 Sincerely,
           planett the refuge system becomes of the utmost importance.

          i By opening the Arctic National WildlLf e Refuge to drilling oil
         .--,and gas, we are endangering wildlife in many ways.                                       Tom Lewanski
                                                                                                      Interpietive Naturalist
           First# in wildlife/man confrontations such as when    a human or his
           property is injured by a bear, It Is the animal which is removed
           or destroyed. if situations like this arose during construction
           or drilling exercises, how would the animal's refuge be upheld?                            cc$  J. Fitzpatrick, Director of  CHC
           Secondly, by moving man and his machines onto the Refuge, the                                   Congressman, Timothy Penny
                                                                                                           Congressman,.Vin Weber
           safety of refuges everywhere Is in jeopardy.      The refuge system                             Congressman, Bill Frenzel
           becomes something which can be altered and twisted to meet the                                  Congressman, Bruce Vento
           needs of people, instead of the plants.an4 animals which should                                 Congressman, Martin Sabo
           be the benefactors of the Refuge.                                                               Congressman, Gerry SikorskL
                                                                                                           Congressman, Arlan Stangeland
           Furthermore, while Bill Born stated that wDevelopment must result                               Congressman, James oberstax
           in no unnecessary adverse effects, and unavoidable habitat losses
           should be fully compensated.!', any habitat lose is an unnecessary
           .adverse effect.    After all the Refuge was set up for the
           wildlife.    What would compensation do if. an environmental
           catastrophe, like a major oil spill occured?             While the
           compensation may temper human concerne it could not return the
          .habitat or restore ecological balance.

                                                                   R-40

                                               As the Nation's principal conservation agency, the Department of the
                                              Interior has responsibility for most of our nationally owned public lands',,
                                              and natural resources. This includes fostering the wisest use of our land
                                              and water resources, protecting our fish and wildlife, preserving the,
                                              environmental and cultural values of our national parks and historical
                                              places. and providing - for the enjoyment of life through outdoor
                                              recreation. The Department assesses our energy and mineral resources
                                              and works to assure that their development is in the best interests of all
                                              our people. The Department also has a major responsibility for American
                                              Indian reservation communities and for people who live in island
                                              territories under U.S. administration.

                                                                   U. S. DEPARTMENT OF THE INTERIOR
                             U.&                                     BUREAU OF LAND MANAGEMENT                               OF
                       FISH &WILDLIFE
                           SERVICE

                                                                                                                             L

                          UNITED STATES
                DEPARTMENT OF THE INTERIOR
                      FISH AND WILDLIFE SERVICE
                    DIVISION OF REFUGE MANAGEMENT                                                        OSTAGEAN D FEES PAID
                     MAIN INTERIOR BLDG., ROOM 2343                                                 U.S. DPEPARTMENT OF THE INTERIOR
                         18TH & C STREETS, N.W.                                                             INT 423               U.SMAIL
                         WASHINGTON, D.C. 20240

                                                  Mr. Bill Milhouser
                                                  0CRM/N0AA
                                                  1825 Conn. Avenue, N.W.
                                                  Washington, D.C. 20235
                                                                                                                               L'4U @=SJAAIL

                                                          A
                                                               3666800001
                                                                                 7535
                                                                 NIM