By: David Raskin, Friends Board President


The Arctic Refuge drilling proposal continues front and center on the national stage, and the administration’s numerous assaults on the environment remain bogged down under the pressures of time, resources, and inadequate scientific studies!

Arctic National Wildlife Refuge

There is some news concerning DOI plans to sell leases for oil and gas development in the Coastal Plain of the Arctic Refuge. The Record of Decision (ROD) continues to be delayed for unannounced reasons and is now delayed until at least sometime in January. Since the lease sale had been planned for December 2019, the delay of the ROD and the necessary waiting periods after its release have pushed any possible lease sale farther into February at the earliest.

There is no word about plans for seismic exploration, which likely cannot occur before the 2020-21 winter, if at all. A recent report published in the Journal of Wildlife Management describes the potential impacts of various seismic scenarios. Even the most restrictive alternative would risk some polar bear mortality. So far, we have not seen a proposed plan for exploration. The warming arctic temperatures have narrowed the window of opportunity for such activities on frozen tundra. However, the State of Alaska appears to be moving forward with seismic exploration on State lands immediately adjacent to the Canning River in the Arctic Refuge.

Our conservation and Native Alaskan partners continue to hold successful outreach events throughout the country, and there have been many great pieces in various media. The campaign’s meetings with executives of oil companies and financial institutions concerning the dangers of Arctic drilling and the financial risks of supporting such efforts are producing impressive results. Bernadette Demientieff, Executive Director of the Gwich’in Steering Committee, is spearheading this campaign and has recently received national recognition for her great work. We will win this latest in the decades-long battle to save and preserve the Arctic Refuge and its subsistence and cultural values!

Izembek National Wildlife Refuge

There is no significant development in the suit filed on August 7, 2019 in federal district court that names Friends as the lead plaintiff along with eight conservation partners. We have not received a ruling from the Court, and we will provide updates as this lawsuit works its way through the legal process.

Kenai Predator Control and Hunting Regulations

The proposed Kenai Refuge predator control regulations have not been released, but we continue to expect them soon. It is likely that the new regulations will allow hunting of brown bears over bait, as well as loosened restrictions on hunting in the Skilak Wildlife Recreation Area and 4-wheel drive access to frozen lakes. It appears that there will be a 30-day comment period, but no public hearings. Recently, the State of Alaska and the Safari Club filed their motion for summary judgment challenging the Kenai National Wildlife Refuge’s rule that bans brown bear baiting (among other things). The Friends and other organizations are intervenors in this lawsuit and are closely following these developments. If the DOI adopts new predator guidelines, this lawsuit may be rendered moot. 

Ambler Road

The has not been any significant development on the proposed 211-mile long Ambler industrial road even though it is on an “unprecedented, extreme fast track,” according to a BLM official. Trustees for Alaska assembled detailed, comprehensive comments on the DEIS that were submitted on behalf of numerous organizations, including Friends. We await information on the comments that were submitted and the issuance of a Final EIS. As with the many hurried and poorly supported BLM assaults on public lands, this process seems to have slowed.

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.

ACTION ALERT: ATTENTION ANCHORAGE AREA FRIENDS OF ARCTIC NATIONAL WILDLIFE REFUGE

Take time on Tuesday, February 11^th to tell the Bureau of Land Management why the rushed and irredeemably flawed oil and gas leasing process needs to be stopped in its tracks!

The Bureau of Land Management will hold an OPEN HOUSE from 1 pm to 7 pm on Feb 11^th at the Dena’ina Center, 600 W. 7^th Ave. with information boards and subject matter experts available to provide information and answer questions one-on-one.

At 2 pm and 5 pm BLM will give a PRESENTATION providing an overview of the DEIS. Beginning at 1 pm, individuals wishing to provide PUBLIC TESTIMONY, may do so, with breaks occurring at 2pm and 5pm for the BLM presentation.  The microphone will be available on a FIRST COME FIRST SERVE basis. A court reporter will be available to capture these comments. There will also be a court reporter available if individuals wish to provide their testimony ONE-ON-ONE throughout the public meeting period.  Comment stations with computers will also be available if attendees would like to submit comments ELECTRONICALLY.

If you are unable to attend, you can submit comments on proposed Arctic Refuge leasing alternatives presented by the BLM  at blm.gov/alaska, or by mail to Coastal Plain Oil and Gas Leasing Program EIS, 222 W. Seventh Ave., Stop #13, Anchorage, Alaska 99513. The deadline for comments was recently extended to March 13th.

YOUR COMMENTS

Be prepared to tell the BLM WHY the lease sale process needs to be stopped. Your comments might include:

• Your assessment of the value of the Refuge, including its importance as one of America’s last wild places.
• Your concerns regarding the leasing process. You might include:
  • The Administration’s failed promise to Americans that the permitting would include a robust, scientifically sound review process with public comment and full tribal consultation.
  • The BLM’s disregard for the serious biological, cultural, and climate impacts fossil fuel extraction will have in the rapidly-warming Arctic.
  • The DEIS’s unacceptable deficiencies in current information about the impacts of oil and gas on the Refuge’s irreplaceable ecosystem, wildlife, and the people who depend on those resources
• Your specific concerns regarding species, ecosystem functions, the potential contributions of greenhouse gases to global climate change, etc.

The Bureau of Land Management’s website includes additional information on the leasing program, including the EIS.

Photo Credit: Peter Mather/Minden Pictures, via Getty

The Department of Interior continues its race permit oil and gas leasing on the 1.6 million acre coastal plain of the Arctic National Wildlife Refuge. While 800,000 “nonessential” Federal employees were idled by the recent government shutdown, the Bureau of Land Management continued work to complete the Draft Environmental Statement (DEIS). However the news isn’t all bad as public comment deadline on the DEIS has been extended from February 11^th to March 13^th.

As part of the public comment period, BLM has launched a rushed round of public meetings. The format of these “open house” meetings (as reported by Alaska Public Media here) includes a slide presentation from the agency and opportunities for the attendees to provide testimony via computers and court reporters, DOES NOT include opportunities a forum for the public to speak out. Meetings have already occurred in Fairbanks, Kaktovik, Utqiagvik, and Fort Yukon.  Meetings are scheduled at Arctic Village (Saturday, Feb. 9), Venetie (Sunday, Feb 10), Anchorage (Monday, February 11), and in Washington DC (Wednesday, Feb 23).  Your attendance and participation in these meetings is important and valuable – in spite of the shortcomings of the meetings’ format and opportunities for public engagement.  More information about these meetings is available here.

If you are unable to attend, you can submit comments on proposed Arctic Refuge leasing alternatives presented by the BLM before March 13th at blm.gov/alaska, or by mail to Coastal Plain Oil and Gas Leasing Program EIS, 222 W. Seventh Ave., Stop #13, Anchorage, Alaska 99513.

This comment period is the last opportunity for the public to wade in on the BLM’s rushed and highly flawed process. Your comments might include:

• Your assessment of the value of the Refuge, including its importance as one of America’s last wild places.
• Your concerns regarding the leasing process. You might include:
  • The Administration’s failed promise to Americans that the permitting would include a robust, scientifically sound review process with public comment and full tribal consultation.
  • The BLM’s disregard for the serious biological, cultural, and climate impacts fossil fuel extraction will have in the rapidly-warming Arctic.
  • The DEIS’s unacceptable deficiencies in current information about the impacts of oil and gas on the Refuge’s irreplaceable ecosystem, wildlife, and the people who depend on those resources
• Your specific concerns regarding species, ecosystem functions, the potential contributions of greenhouse gases to global climate change, etc.

The Bureau of Land Management’s website includes additional information on the leasing program, including the EIS.

(photo credit: National Geographic)