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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, [email protected] 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 [email protected]. 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 .!@[email protected],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 [email protected] 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 [email protected] 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@[email protected] 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. 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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) [email protected].. 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. @[email protected]@@ 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 [email protected] 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 [email protected] 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 [email protected] 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 [email protected] 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. 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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,([email protected]@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 [email protected] 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,[email protected] 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 [email protected] 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-. 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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 [email protected],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