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Friends: Assisting Alaska’s Refuges Via Membership Fees, Donations, and Grants

by Betty Siegel, Volunteer Coordinator

Village kids on the Tetlin Refuge will be peeking under the ice next winter and learning to fish this summer with equipment purchased through a grant Friends secured from the National Fish and Wildlife Foundation.  Friends were awarded a $6800 grant for a special initiative to enhance fishing and hunting on refuges.  Tetlin Environmental Educator Tim Lorenzini sought the Friends help:
  • to expand his school field trips
  • increase the courses he could offer at Native Culture Camps, and
  • create new Refuge sponsored community events. 
In addition to the fishing equipment, the grant purchased a regulation teaching archery set complete with targets, and the all-important ice fishing tents in a climate where school field trips often take place in below zero temperatures. Competing for grants is one thing Friends can do to help refuges but it takes volunteer grant writers and volunteer refuge liaisons to work closely with “their” refuge to make this happen.  If you have these skills, or would like to learn, contact us at info@alaskarefugefriends.org.

According to Tetlin Refuge Liaison, Poppy Benson, “The grant writing seemed like a huge amount of work but now that it is done, I feel like I really accomplished something. I have great confidence that the Tetlin Refuge will put the equipment to good use to strengthen their relationship with their communities and how can that not be good for wildlife?!”


But grants aren’t the only way Friends helps refuges financially.  With our membership fees and generous individual donations at the $100, $500 and $1000 level, Friends have been able to donate $1000 to help the Kenai Refuge fund school buses to bring kids to the refuge for field trips, fund all the prizes for the Migratory Bird Calendar contest which is so important to rural schools, buy wood chips for a new trail at Tetlin Refuge Headquarters, bring a dozen urban youth to Homer for the Kachemak Bay Shorebird Festival, send volunteers to science camps, and pay for travel for Artist in Residence Lindsay Carron to capture in paintings the Yukon Flats Refuge.

And then there is the cookie money.  What is cookie money you ask?  Well the Fish & Wildlife Service cannot legally buy food for a public event but if a Refuge Manager is flying into a village to have a meeting with the elders, he or she had better be bringing coffee and cookies!  Last year we provided funds for refreshments for six refuge events. Friends is able to do this because of your membership fees and donations. You can be confident we use your money for the refuges wisely and generously. To join, renew, or make a donation, CLICK HERE .Thank you on behalf of Friends and the 16 Alaska Refuges!



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2019 June Advocacy Report

Advocacy Update

by David Raskin, Friends Board President

The battles continue to save the Izembek and Arctic Refuges from destructive developments and limit the impact of the expected predator control regulations for the Kenai Refuge.

Izembek NWR

The Department of Justice has appealed the decision by the Anchorage Federal District Court that granted the motion for summary judgment in our lawsuit that challenged the legality of the land exchange and road through the heart of the Izembek Wilderness. This decision had halted all activity related to the transfer of Refuge land and the construction of a road. The defendants have now appealed that decision to the Ninth Circuit Court of Appeals. Our most recent information indicates that the DOI may be working on a plan that could impact the status of the entire lawsuit and may have instructed the USFWS to continue some work in anticipation of  their possible success in overcoming trying to figure out how to respond to the court order and explain their decision process to satisfy the court. Our conservation partners and legal team are closely monitoring any such actions and will mount all available legal and legislative challenges to counter any attempt by the Department of Interior (DOI) to revive the unacceptable land exchange and destructive road.

(photo by Alaska Wilderness League/ Izebemek NWR)

Arctic NWR

The DOI continues to press forward with plans to sell leases for oil and gas development in the Coastal Plain of the Arctic Refuge. A major national effort resulted in an extensive set of technical comments that were submitted by Trustees for Alaska citing numerous, serious deficiencies in the Draft Environmental Impact Statement issued by the BLM. BLM is in the process of preparing a final EIS, which is expected to be released in August and a decision soon after the close of the 30-day comment period. Since the DEIS was so hastily done and grossly inadequate, without a new DEIS process it is likely that a Final EIS will be insufficient to withstand legal challenges. Lease sales are planned this year.

A related activity is the proposed seismic exploration and a recently-proposed low-altitude aerial survey. These require a plan that would satisfy the Incidental Take Regulations (ITR) regarding denning polar bears and marine mammals. The conservation community is closely monitoring these developments and will take whatever actions are necessary to prevent the undesirable impacts of seismic exploration.

A positive development is the Restore Protections Bill (HR 1146) that would remove the tax bill provision that authorized the sale of leases in the Coastal Plain. The bill was introduced by Representative Jared Huffman and had a record 180 cosponsors. It was reported out of committee and a full House vote is expected soon. Although expected to pass the House, the Senate is not expected to pass it.

Kenai NWR Predator Control Regulations

The proposed Kenai Refuge predator control regulations have not been released, but are expected very soon. The most serious threat to wildlife is the expected regulation that will allow hunting of brown bears over bait.  At a minimum, we will urge the Kenai Refuge to develop a permit process to limit the areas of the Refuge and the number of bears to be taken consistent with mandated management practices and potential threats to the brown bear population. The conservation community is closely monitoring any developments and is prepared to provide the responses necessary to protect the integrity and biological diversity of the Kenai Refuge wildlife.




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2019 Kachemak Bay Shorebird Festival Recap

Friends of Alaska National Wildlife Refuges and Alaska Maritime National Wildlife Refuge co-sponsored the 27th Annual Kachemak Bay Shorebird Festival in Homer, Alaska, May 9-12, 2019. The combination of new Coordinator Mallory Primm and outgoing Coordinator Robbi Mixon was magical! Registration was up by over 100 participants from the previous year and the Keynote speaker, Jennifer Ackerman, sold out for both talks and her workshop. Mark Omascik shared his new book on the Battle of Attu and feature presenters Raymond VanBuskirkand the Tropical Birding Crew led field trips and talks. The stunning artwork by Valisa Higman sold for a record bid, along with over 30 donated 6×6 Alaskan bird art pieces and trips. Much of our merchandise sold out quickly – stop by Islands and Ocean in Homer to see what’s left. Around 100 volunteers donated their time and talents to make this event successful along with the huge contributions of many sponsors and supporters.

Congrats to Mallory on her first year as coordinator, and to Robbi on her last!

We hope you’ll save the date for next year’s event: May 7-10, 2020!




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2019 – May Advocacy Report

Advocacy Update

by David Raskin, Friends Board President

We are pleased to report the exciting developments in the battles to save the Izembek and Arctic Refuges from destructive developments. These and other issues are discussed below.

Izembek NWR

On 29 March 2019, Friends and eight national conservation organizations scored a major victory when the Federal District Court in Anchorage granted the motion for summary judgment in our lawsuit that challenged the legality of the land exchange and road through the heart of the Izembek Wilderness. In her opinion that invalidated the land exchange, Judge Gleason ruled that the process for land exchange authorized by the Secretary of Interior was “arbitrary and capricious.” This decision halted all activity related to the transfer of Refuge land and the construction of a road. We are all extremely indebted to the staff of Trustees for Alaska who did an amazing amount of superb legal work that resulted in this wonderful victory after decades of battling to protect Izembek from this proposed destruction. However, this is not the final event, as the road proponents will continue to develop legal and legislative approaches to undue this rejection of the road. We and our conservation partners and legal team will closely monitor any such actions and will mount all available legal and legislative challenges to counter any attempt by the Department of Interior (DOI) to revive the unacceptable land exchange and destructive road. Check out the Trustees for Alaska press release for more information.

Arctic NWR

The DOI continues to press forward with plans to sell leases for oil and gas development in the Coastal Plain of the Arctic Refuge. A major national effort resulted in an extensive set of technical comments that were submitted by Trustees for Alaska on behalf of the numerous, serious deficiencies in the Draft Environmental Impact Statement issued by the BLM. Friends also submitted more general comments.  We await the release by BLM of data concerning the number and nature of comments received in response to the national campaign by conservation organizations, including Friends, to encourage their members and the general public to express their concerns about the hurried and flawed process by which the BLM and DOI are attempting to ram through this prosed desecration of the Coastal Plain.

A parallel campaign has been spearheaded by the Gwich’in people of the United States and Canada to prevent the desecration of this Sacred Land and their subsistence culture and way of life. They and scientists and conservationists recently provided powerful testimony on the Arctic Cultural and Coastal Plain Protection Act, H.R. 1146 introduced by Representatives Huffman and Fitzpatrick to prevent the proposed oil and gas development in the Coastal Plain. In furtherance of these goals, the Alaska Wilderness League lured our longtime refuge champion Desiree Sorenson-Groves from the National Wildlife Refuge Association to head the national coalition to protect and preserve the Arctic Refuge. We welcome her able and energetic leadership will continue to work closely with Desiree and the coalition.


The other dangerous aspect of the proposed oil and gas development is the plan to conduct an extensive and disruptive seismic exploration of the Coastal Plain. In spite of their frantic rush to further this program, those involved were unable to perform the necessary analyses required to obtain authorization for the seismic activity in time for 2018-2019 winter season. The current plan is to do the required analyses and issue findings to support seismic exploration in the coming winter season. The conservation community will closely monitor these developments and take whatever actions are necessary to prevent the undesirable impacts of seismic exploration. Interestingly, a recent New York Times investigation revealed that the closely-held and secret data from the only test well ever drilled on the Coastal Plain found little support for the presence of recoverable oil to justify oil and gas development.

Kenai NWR Predator Control Regulations

The proposed changes to the Kenai Refuge predator control regulations have not been released. Information from the FWS indicates that proposed drafts have gone back and forth between the Refuge, Regional Staff, and DOI regarding the extent to which the undesirable State demands will be incorporated into the published draft of the revised regulations. We anticipate that proposed regulations will soon be published in the Federal Register, and the conservation will closely monitor any development and be prepared to provide the responses necessary to protect the integrity and biological diversity of the Kenai Refuge wildlife.

 




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2019 April Membership Meeting

Please join us on Tuesday, April 16, 2019, 5-6pm, for the Friends membership meeting.

In person: Homer (Alaska Maritime), Fairbanks (Watershed School, 4975 Decathlon), or Soldotna (Kenai NWR) Call in a few minutes before 5pm: (866) 556-2149, code :8169747#

Guest Speaker Presentation: John Morton, Kenai National Wildlife Refuge –

Effects of a Rapidly Warming Climate on the Kenai National Wildlife Refuge
The Kenai Peninsula is one of the best-studied parts of the state for climate change effects and John Morton, a supervisory biologist for the Kenai Refuge,  has been a key part of that.  Managing the effects of rapid climate change on the 2 million-acre Kenai National Wildlife Refuge will be a challenge to its primary purpose of conserving natural diversity.  In 50 years, the treeline rose 50m in the Kenai Mountains, wetlands decreased 6-11% per decade, the Harding Icefield lost 5% in surface area and 21m in elevation, and available water declined 62%. Late summer canopy fires in spruce are being replaced by spring fires in bluejoint grasslands. Water temperatures in nonglacial streams already exceed physiological thresholds for salmon during July. Bird species are moving north and more than 130 exotic bird species have become established. Climate-envelope models portray a very different future landscape with alpine tundra replaced by forests and lower elevation forests replaced by hardwoods or possibly catastrophic deforestation.  How can the Refuge or any of the refuges manage for biodiversity under this scenario?

Download Presentation

Agenda:

Introductions and Discussion (5 minutes)
  • Introductions: Where do you live? (Tara)
  • New People: Why did you join the call today?
  • Reminder to please mute yourselves when you aren’t talking
Board Activities/Decisions
  • Refuge Projects and Reports (Betty)
Committee Reports (2-5 minutes each): Volunteer Report – (Betty) Membership/Outreach Events: Upcoming events (Tara) Advocacy Updates (David, Dave)
Speaker/Presentation (30-40 minutes) –
  • John Morton, Kenai National Wildlife Refuge
  • Topic: “Effects of a Rapidly Warming Climate on the Kenai National Wildlife Refuge”
Next Meeting: Tuesday, September 10th, 5-6pm Guest Speaker: TBA
SIX meetings yearly: January, February, March, April, September, October



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2019 – April Advocacy Report

Advocacy Update

by David Raskin, Friends Board President

We are pleased to report the exciting developments in the battles to save the Izembek and Arctic Refuges from destructive developments. These and other issues are discussed below.

Izembek NWR

On 29 March 2019, Friends and eight national conservation organizations scored a major victory when the Federal District Court in Anchorage granted the motion for summary judgment in our lawsuit that challenged the legality of the land exchange and road through the heart of the Izembek Wilderness. In her opinion that invalidated the land exchange, Judge Gleason ruled that the process for land exchange authorized by the Secretary of Interior was “arbitrary and capricious.” This decision halted all activity related to the transfer of Refuge land and the construction of a road. Click on the link to view the press release and court opinion. We are all extremely indebted to the staff of Trustees for Alaska who did an amazing amount of superb legal work that resulted in this wonderful victory after decades of battling to protect Izembek from this proposed destruction. However, this is not the final event, as the road proponents will continue to develop legal and legislative approaches to undue this rejection of the road. We and our conservation partners and legal team will closely monitor any such actions and will mount all available legal and legislative challenges to counter any attempt by the Department of Interior (DOI) to revive the unacceptable land exchange and destructive road.

Arctic NWR

The DOI continues to press forward with plans to sell leases for oil and gas development in the Coastal Plain of the Arctic Refuge. A major national effort resulted in an extensive set of technical comments that were submitted by Trustees for Alaska on behalf of the numerous, serious deficiencies in the Draft Environmental Impact Statement issued by the BLM. Friends also submitted more general comments [please add link].  We await the release by BLM of data concerning the number and nature of comments received in response to the national campaign by conservation organizations, including Friends, to encourage their members and the general public to express their concerns about the hurried and flawed process by which the BLM and DOI are attempting to ram through this prosed desecration of the Coastal Plain.

A parallel campaign has been spearheaded by the Gwich’in people of the United States and Canada to prevent the desecration of this Sacred Land and their subsistence culture and way of life. They and scientists and conservationists recently provided powerful testimony on the Arctic Cultural and Coastal Plain Protection Act, H.R. 1146 introduced by Representatives Huffman and Fitzpatrick to prevent the proposed oil and gas development in the Coastal Plain. In furtherance of these goals, the Alaska Wilderness League lured our longtime refuge champion Desiree Sorenson-Groves from the National Wildlife Refuge Association to head the national coalition to protect and preserve the Arctic Refuge. We welcome her able and energetic leadership will continue to work closely with Desiree and the coalition.

The other dangerous aspect of the proposed oil and gas development is the plan to conduct an extensive and disruptive seismic exploration of the Coastal Plain. In spite of their frantic rush to further this program, those involved were unable to perform the necessary analyses required to obtain authorization for the seismic activity in time for 2018-2019 winter season. The current plan is to do the required analyses and issue findings to support seismic exploration in the coming winter season. The conservation community will closely monitor these developments and take whatever actions are necessary to prevent the undesirable impacts of seismic exploration. Interestingly, a recent New York Times investigation revealed that the closely-held and secret data from the only test well ever drilled on the Coastal Plain found little support for the presence of recoverable oil to justify oil and gas development.

Kenai NWR Predator Control Regulations

The proposed changes to the Kenai Refuge predator control regulations have not been released. Information from the FWS indicates that proposed drafts have gone back and forth between the Refuge, Regional Staff, and DOI regarding the extent to which the undesirable State demands will be incorporated into the published draft of the revised regulations. We anticipate that proposed regulations will soon be published in the Federal Register, and the conservation will closely monitor any development and be prepared to provide the responses necessary to protect the integrity and biological diversity of the Kenai Refuge wildlife.




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Fairbanks Art Crowd Loves Refuges – 4th Annual Art in the Arctic

Event report filed by Poppy Benson, Friends Vice President

Art in the Arctic in its 4th year was a big hit once again drawing a younger and diverse crowd of 250 on March 7.  Friends cosponsored this art show showcasing works highlighting the three northern refuges – Arctic, Yukon Flats, and Kanuti.  This year’s theme was “Public Lands – Open to all Americans to Use and Enjoy“.  Various works portrayed hunting, fishing, hiking, wildlife viewing, river-floating, photography, sightseeing and other uses of public lands.  Eight artists were selected to exhibit in the show which will be up for the entire month at the popular coffee house and art gallery, VENUE, located at 514 – 2nd Avenue Fairbanks, Alaska.  Mediums ranged from wood carvings to oil to photography, fabric art, and large-scale watercolors.  It was a lovely evening with great food, good messaging about the refuge system and high visibility for the three refuges.  Featured artists included Lindsay Carron who has completed two Artist in Residence programs at the Arctic Refuge as well as spent time on the Yukon Delta Refuge.  Special Tee shirts were created for the event – one Art in the Arctic Tee and one – Find Your Refuge Tee.  Both are available for sale online and 10% of the proceeds go to Friends.  

Fairbanks Friend Jeff Walters and Homer Friends Poppy Benson and Frank Cloyd were on hand to greet and orient attendees and recruit for Friends.  Several new members signed up at this event and at the Alaska Bird Conference which was also held in Fairbanks earlier in the week.  At the end of the week, plans were afoot for a face to face meeting of Fairbanks Friends during our April 16 monthly membership meeting.  Contact Poppy Benson, poppyb.ak@gmail.com for more details.







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2019 March Membership Meeting

Please join us on Tuesday, March 19, 2019, 5-6pm, for the Friends membership meeting.

In person: Homer (Alaska Maritime) or Soldotna (Kenai NWR) Call in a few minutes before 5pm: (866) 556-2149, code :8169747#

Guest Speaker Presentation: Ray Born– “Yukon Delta NWR – A Complex and Wonderful Place”

Birds fill the skies of the watery vast world of the Yukon Delta. The 19.3 million acre refuge is the country’s most important shorebird nesting area. Add in a million ducks and half a million geese plus 40,000 loons and 100,000 swans and you can see why it is considered one of the world’s largest aggregations of nesting waterbirds. But it isn’t just about birds. The refuge is famous for trophy rainbow and salmon fishing since the Yukon, the Kuskokwim and their tributaries such as the Kisaralik flow through the refuge. Even muskox are found on Nunivak Island. The Delta is also noted for its thriving Native villages where the Yupik language and subsistence culture flourish. Come discover the Delta and learn what Refuge projects we Friends may be able to help with.   DOWNLOAD PRESENTATION

Agenda:

Introductions and Discussion (5 minutes)
  • Introductions: Where do you live? (Poppy)
  • New People: Why did you join the call today?
  • Reminder to please mute yourselves when you aren’t talking
Board Activities/Decisions
  • Refuge Projects and Reports (Betty)
Committee Reports (2-5 minutes each): Volunteer Report – (Betty) Membership/Outreach Events: Upcoming events (Poppy) Advocacy Updates (David, Dave, Mallory)
Speaker/Presentation (30-40 minutes) –
  • Ray Born, Yukon Delta National Wildlife Refuge
  • Topic: “Yukon Delta NWR – A Complex and Wonderful Place”
Next Meeting: Tuesday, April 16th, 5-6pm Guest Speaker: John Morton/ Kenai NWR
SIX meetings yearly: January, February, March, April, September, October



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Submit Arctic Refuge Public Comments by March 13th!

The Bureau of Land Management’s Draft Environmental Impact Statement is our last chance to directly voice concern over the impacts of oil and gas drilling in the pristine Arctic Refuge. Continue reading to find out how to write a comment and what the major concerns with the DEIS are.  Or download the document here. How to submit public comments
    1. Write your comments (see Template below)
    1. Submit your comments to BLM  
        • Online
        • Attn: Coastal Plain Oil and Gas Leasing Program EIS
        • 222 West 7th Avenue, Stop #13
      • Anchorage, Alaska 99513 -7504
  1. Send your comment along to your Representatives and Senators to show your concern

Tips for submitting public comments

    1. Use a word processor – Write, compile and edit your comments in a word processor, then cut and paste your comments into the BLM Website to insure your work is not lost in case of a web error, and it allows you to use the letter again to alert your representatives in Congress of your concerns.
    1. Be specific – BLM suggests that “substantive comments should be as specific as possible.”  This public comment period is focused on objections to and inadequacies with the Draft Environmental Impact Statement.  While you can voice opposition to oil and gas development in the Arctic Refuge overall, specific comments on the Draft EIS is most helpful.
  1. Speak from the heart – The Arctic National Wildlife Refuge is important.  The Refuge is your public land to celebrate and protect.  Using your own words creates a unique, substantive claim that BLM is required to consider and gives your comments more weight.

Template for Composing Public Comments

**Use/Edit/Cut/Paste the following text to create your own public comments on the DEIS for oil and gas lease sales on the Coastal Plain of the Arctic National Wildlife Refuge**

The Arctic National Wildlife Refuge is a unique national treasure and is no place for oil and gas development. The Friends of Alaska National Wildlife Refuges stands with Alaskans and Americans in opposing oil and gas lease sales in the Arctic National Wildlife Refuge.   The Draft Environmental Impact Statement (DEIS) by the Bureau of Land Management (BLM) is  insufficient in its analysis of the effects of oil and gas leasing in the Arctic National Wildlife Refuge Coastal Plain and does not fulfill its legal obligation to propose a full range of alternatives to the proposed gas leasing.

The Purpose of the Arctic Refuge

The established purposes of the Arctic National Wildlife Refuge are “to conserve animals and plants in their natural diversity, ensure a place for hunting and gathering activities, protect water quality and quantity, and fulfill international wildlife treaty obligations.”  The 2017 Tax Act (Law No: 115-97) added a fifth purpose of the Refuge  “to provide for oil and gas program on the Coastal Plain” Oil and gas is entirely inconsistent with the purposes of the Refuge because it will cause lasting damage to the animal and plant diversity, disrupt subsistence activities, upset water quality and quantity, and disregard international wildlife protection obligations.  The DEIS fails to analyze  how the oil and gas development will interfere with the originally stated purposes of the Refuge.    

Rushed and Faulty DEIS Process

BLM’s rush to a hold lease sale this year has resulted in an inadequate Draft EIS and limited public participation.  BLM is legally obligated to thoroughly analyze the effects of oil and gas in the Arctic Refuge.  Instead, the scoping review and DEIS process was compressed to just five months, which prevented a thorough analysis.  Work on the DEIS continued through the recent government shut-down even though the Arctic Refuge staff and other BLM employees were not available for consultation.  Public comment periods and notice of public meetings were abbreviated. For example, the Fairbanks community had only 5 days notice of their local meeting on the DEIS.   The DEIS fails to uphold BLM’s legal obligations to offer an adequate range of alternatives.  The DEIS offers only three alternatives, all of which allow full oil and gas development.  These alternatives fail to adhere to the limits for development and lease sales set by Tax Act.  Additionally, the proposed alternatives fail to protect the stated purposes and biological resources of the Arctic Refuge.  The DEIS does not offer reasonable alternatives to the proposed oil and gas leasing, nor does it sufficiently analyze the impacts of the alternatives.   The DEIS is deficient both legally and substantively.  It  failed to include: the required analyses, the necessary mitigation measures and alternatives necessary to protect the resources mandated by the established purposes of the Arctic National Wildlife Refuge.  BLM must thoroughly and objectively analyze the 680,000 public comments submitted during the scoping process (which ended in June, 2018), carefully consider the concerns expressed by the Gwich’in Nation that will be adversely impacted  by the proposed drilling, and conduct the necessary analyses to understand the impacts of oil and gas leasing in order to comply with federal and international legal obligations.

Harm to Wildlife

Caribou: The Coastal Plain  of the Arctic National Wildlife Refuge that is proposed for oil and gas leases provides vital calving and post-calving habitat for the 200,000 animals of the Porcupine Caribou Herd.. The Porcupine Caribou Herd depends on  the unique ecological resources of the entire Coastal Plain during its annual migration and calving. BLM acknowledged that oil and gas activities will likely disturb and displace caribou, especially sensitive mothers and their young.  However, BLM failed to adequately address the impacts on caribou and failed to consider the full range of areas and habitats that are vital to caribou during their annual migration. Polar Bears: 77% of The Arctic Refuge Coastal Plain is designated Critical Habitat for Polar Bears, which are listed as threatened under the Endangered Species Act.  The Southern Beaufort Sea population of polar bears, which den on the Coastal Plain of the Refuge, have lost about half their population since 1980.  Nearly one third of these bears depend on the Coastal Plain to den and give birth to their cubs.  This area of the Refuge is one of the world’s largest polar bear denning sites.  The DEIS acknowledged that oil and gas activities could cause injury or death to polar bears and that all alternatives would also affect large areas of Critical Habitat.  However, BLM failed to identify and analyze mitigation measures that are sufficient to protect the bears, and it did not identify how many bears would be impacted or how the impacts to these bears will affect this threatened species. Birds:  The Arctic Refuge Coastal Plain is an essential nesting, foraging, and migratory stopover  for millions of birds each year. Over 200 species of birds from every US state and six continents nest on the Refuge Coastal Plain.  The BLM analysis of effects on birds is inadequate and contains large loopholes that would allow oil and gas activities to move forward regardless of harm to birds.  A thorough analysis of direct and cumulative impacts on world bird populations that spend their summer on the Coastal Plain is necessary to determine the environmental impacts of oil and gas leasing in the Arctic National Wildlife Refuge.

Disregard for Human Rights and the Gwich’in people

The Gwich’in people of Alaska and Canada are culturally and spiritually connected to the Porcupine Caribou Herd, which in turn relies on the Arctic Refuge Coastal Plain for calving and post-calving habitat. Because of this connection, the Gwich’in consider the Coastal Plain to be sacred and believe that protecting the Arctic National Wildlife Refuge is vital to their human rights and food security. A significant portion of Gwich’in subsistence comes from the Porcupine Caribou Herd, BLM concluded that there will be no impact on the Gwich’in subsistence food source, even while acknowledging oil and gas impacts on caribou.  BLM asserted that the Gwich’in do not qualify for an 810 hearing (necessary under the Alaska National Interest Lands Conservation Act), which is required for development that will substantially affect subsistence. The DEIS ignored the traditional knowledge and human rights of the Gwich’in.

Harmful Impacts to Water Resources and Air Quality

Water: One of the specific purposes of the Arctic National Wildlife Refuge is to “protect water quality and necessary water quantity.” The DEIS acknowledged that drilling an oil well could use 2 million gallons of water and each mile of ice road uses 1 million gallons of water in this Refuge which has] few fresh water sources, especially in winter.  The  DEIS does not clearly depict how much water oil and gas activities could use and how this will affect the Arctic Refuge.  In their comments on the Notice of Intent, Fish and Wildlife Service, which administers the Arctic National Wildlife Refuge, stated, “Water withdrawals from the streams, rivers and springs could have significant and detrimental implications to the populations and habitats of fish and wildlife.” The DEIS failed to fully evaluate the impacts of oil and gas development on the already scarce water resources and the effects on  fish, habitat, vegetation, and hydrology. Air: The DEIS failed to meaningfully evaluate potential impacts of oil and gas activities on  air quality in the Arctic Refuge. The BLM concluded i that future projects on the Coastal Plain of the Arctic National Wildlife Refuge would be “unlikely” to exceed important air quality standards, but it failed to support this conclusion with sufficient analysis.  The DEIS did not quantify pollution emissions nor did it assess the air quality impacts of oil and gas development on the environment and on human health.   

False Limit on Developed Acreage

The Tax Act that allowed  oil and gas leasing requires that only 2,000 acres of the Coastal Plain be impacted by oil and gas development and production.  However, BLM interpreted this restriction too narrowly. BLM did not count acreage affected by pipelines, gravel mines, ice roads, or other industry activity (such as seismic exploration) that the agency recognizes will have significant impacts. Areas that supposedly would be “reclaimed” also are not considered in the 2,000-acre limit. Thus, the cumulative footprint of development would be much greater than the 2,000 acre restriction with far more actual development and greater impacts].  The narrow definition of the 2,000 acre limit would permit greater impacts on the Arctic National Wildlife Refuge than allowed in the 2017 Tax Act.

Other Areas of Concern:

  • The DEIS failed to consider proposed seismic surveys. SAExploration LLC plans to conduct seismic exploration surveys on the Coastal Plain during the winters of 2019 and 2020, but the DEIS fails to analyze the impacts of their proposed seismic exploration.  The scope of the DEIS is too limited and did not consider the full range of oil and gas activities. BLM is required to consider all of the environmental impacts of the proposed oil and gas program.
  • The DEIS failed to identify the economic value of the Arctic Refuge. The DEIS recognized that the Arctic Refuge has significant ‘ecosystem service values’, that is, the biological resources of this land are highly valuable.  BLM recognized that their value would be harmed by oil and gas leasing, but it did not conduct an economic analysis to quantify or identify these values or impacts.  The DEIS failed to include an economic projection of revenue from lease sales. The DEIS failed to assess the immense value of wilderness and Refuge lands to air and water quality, wildlife, scientific inquiry, human well-being, and America’s natural and cultural  heritage.
  • The DEIS failed to offer effective mitigation.  The DEIS acknowledged that the proposed oil leasing could disrupt 633,000 acres of caribou habitat, 40% of the Coastal Plain, but its proposed mitigation strategy — to continue drilling and suspend “major construction activities” for only a single month of the year — is insufficient.  Likewise, the DEIS acknowledged its own proposed action alternatives could cause injury or death to polar bears and would affect large areas of polar bears’ Critical Habitat. However, BLM failed to identify and analyze sufficient mitigation measures to protect the bears nor did it identify how many bears could be impacted or how impacts would affect this threatened species.  BLM is reliant on lease stipulations and operating procedures to mitigate impacts to the Refuge and the DEIS fairs to show how it can enforce any mitigation requirements.
  • The DEIS failed to address climate impacts. The DEIS fails to provide any analysis of how expanding fossil fuel development in the Arctic Refuge would exacerbate the impacts of climate change already occurring across the Arctic.  The DEIA fails to address how to minimize the impacts on climate. Developing oil and gas in the Arctic Refuge is inconsistent with the urgent need to address climate change.
  • The DEIS lacks scientific integrity. The BLM is required to ensure scientific integrity, acknowledge where it lacks information, and obtain that information. BLM did not acknowledge missing or outdated information in the DEIS and failed to identify the source of the information in analyses. BLM did not conduct any new studies or obtain the missing information.This lack of scientific integrity is evident in its use of outdated studies of polar bears, lack of analysis of caribou calving habitat, and the potential impacts of oil and gas development to birds.   
Download resources to help compose your public comments on the DEIS for the Arctic National Wildlife Refuge.



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