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“If there is oil, it’ll be gone in a generation. But the damage would last for thousands of years.” – Adam Kolton, executive director of the Alaska Wilderness League.
Comment to stop the drilling TONIGHT March 13, deadline 10:59 PDT here.
PDF versions of planning documents here.
USE YOUR OWN WORDS. IDENTICAL scripts will not be counted!!! Length not important but if you’re composing your comment the site, note that you have 60 minutes before it will close on you.
Comment: I strongly oppose any option but Alternate A – do nothing. Studying the Environmental Impact Studies, full of unverifiable assumptions and unwarranted trust in the benevolence of oil industry employees as defacto national park officials, has convinced me that there will be unmitigable damage to a national treasure. The only winners here will be politicians who can crow over delivering our refuge to a cadre of international fossil-fuel interests, who will extract as fast as they can with little oversight and walk away from the damage they leave behind.
Comment: I strongly oppose any option but Alternate A. So much unavoidable damage to a fragile landscape, and animals already struggling with the effects of global warming. And for what? A quote from their own Environmental Impact Study: “Coastal Plain oil production will not significantly increase the global market, that is, it would not significantly alter global demand and consumption of fossil fuels.” For what, indeed?
Comment: I strongly oppose opening the Arctic National Wildlife Refuge to oil drilling. Extreme conditions in the Arctic — icebergs, freezing weather and deep water — make drilling highly risky. An oil spill or undersea leak could result in unprecedented damage, for which we are unprepared. Sea ice that has absorbed oil could travel up to 1,000 miles to remote or inaccessible areas, severely damaging ecosystems and wildlife. More drilling will also increase greenhouse gas pollution. We are headed toward a climate catastrophe if do not take action to develop a future of clean energy. Do not hand over one of our last pristine environments to Big Oil. Alternate A only!
Comment: The Arctic Refuge is one of our nation’s most majestic places, home to the Porcupine Caribou Herd, musk oxen, wolves, imperiled polar bears, and nearly 200 species of migratory birds that migrate to six continents and all 50 states.
On April 4, Senators Ed Markey (D-MA) and Michael Bennet (D-CO), and Representatives Jared Huffman (D-CA) and Brian Fitzpatrick (R-PA) introduced bills in the Senate and House to designate the Coastal Plain of Alaska’s Arctic National Wildlife Refuge as Wilderness.
Even though Alaska lawmakers and the oil and gas industry are interested in drilling the Refuge for short-term gains, we have a right to weigh in on how our public lands are used. In fact, a recent poll by the Center on American Progress shows that nearly 2/3 of Americans oppose drilling in the Refuge, with a majority ‘strongly opposed.’
The Arctic Refuge is too special to drill and our representatives should do everything they can to protect this wild and wonderful place. Alternate A only!
Comment: I am writing you with regard to the DOI-BLM-AK-0000-2018-0002-EIS (Coastal Plain Oil and Gas Leasing EIS), Alaska, to register my opposition to the sale of any oil or gas leases in the Arctic Wildlife Refuge Coastal Plain. While the Notice of Intent claims to “limit the footprint of production and support facilities on Federal lands to no more than 2,000 surface acres” of the 1.6 million acre Coastal Plain, and the recent GOP Tax Cuts and Jobs Act may have included a mandate of the sale of at least two such polluting leases by 2024, new partisan plans for profit do not change facts supporting the need for these lands to remain protected. Science dating back decades establishes that extraction of the oil and gas in the coastal plain would cause permanent irreparable damage to wildlife and local ecology. Birds, polar bears, wolves, caribou and more rely upon the integrity of the Arctic Wildlife Refuge for sanctuary, safety and breeding space. I implore the Bureau of Land Management to cease all prospective oil and gas lease sales in these life-sustaining protected areas. The tax royalties desired by Alaskans from these projects may be able to come from more hydroelectric projects around Alaska; encourage those in areas outside the refuge instead. Alternate A only! Thank you.
Comment: I vehemently oppose the proposed oil and gas leasing program for the coastal plain of the Arctic National Wildlife Refuge. Oil and gas development does not belong in the Arctic Refuge, and I urge you not to move forward with this program. I am also deeply concerned that this process does not include a serious study of the significant impacts that oil and gas development will create for birds and other wildlife.
The Arctic Refuge is home to nearly 200 species of migratory birds. Vast numbers of birds migrate from every state and six continents to nest in the rich habitat of the coastal plain. It is also the critical calving area for the Porcupine caribou herd, providing vital insect relief and summer habitat. And this landscape is the most important onshore denning habitat for polar bears in the United States.
The Arctic National Wildlife Refuge was established to conserve these birds and wildlife, and to preserve wilderness and recreational values, subsistence use, and more. Oil development is entirely inconsistent with the original purposes of the Refuge, and it will cause lasting damage to wildlife and wilderness characteristics, and to the people who depend on them. Moreover, the fast-tracked process toward a lease sale will not allow for the full accounting of the significant impacts that will result.
I am deeply concerned about this proposed leasing program, and urge you to halt this process and end the rush to drill in the Arctic Refuge. Alternate A only!
Comment: I vote for “Alternative A” only. The consequences of all other alternatives, even those so tepidly discribed in the EIS, are too severe for such a fragile wilderness area. The EIS itself is inadequate, incomplete, lacking citation and scientific basis to support its conclusions. It fails to seriously grapple with global warming and how it is already affecting human, vegetation and animal life in the area. The EIS has no mechanism to identify and punish polluters or animal “incidental takers” who stray from the “guidelines” other than to ask them to do their best. It described plenty of “unavoidable adverse effects” but no assurance that the corporations themselves, who damage the environment or who wander away from their facilities without adequate closing mitigation due to “financial hardship”, will be brought to account. It does not tell us how much American tax money will be necessary to monitor, inspect, protect and serve these new corporations at the end of the world in hostile weather, and no estimate on what we will have to pay to remediate what is left behind. Least of all concerns, but truly insult to injury, it’s a terrible financial deal for us. The EIS probably didn’t feel it was their purview to analyze the the value of tearing this area apart for oil and gas, but it would have been nice if the government had done some basic due diligence. Based on current lease sales in Alaska, a estimated leasing of under 50% of available area, and Alaska’s 50% off the top, ….numerous estimates are coming in at $37 – $45 million over 10 years, tops. That’s a rounding number for our budget – why are we even discussing this? That other GOP senators were “taken in” with a wink and crossed fingers by Senator Murkowski’s promise of $1 billion dollars in revenue over 10 years in the rush to pass their #TaxScam? Why? To pay off their fossil-fuel donors? Didn’t they get enough in tax cuts? It would be a better deal to PAY THEM a $45 million dollar subsidy over 10 years NOT to drill, just like we pay Devon Nunes, Chuck Grassley, and Doug LaMalfa millions of dollars not to farm. We, the American people, are not fooled. We will not forgive destroying a thing of incomparable beauty, while the world leaves us behind, sitting in our new and permanent gravel bed scars, as they turn to renewable energy.
How did this happen?
The Arctic National Wildlife Refuge , described as the crown jewel of all our refuges,was created in 1960 by President Eisenhower and bipartisan Congressional support. 57 years later, Alaska’s Senator Murkowski, presenting the a drilling bill within its boundaries as a revenue raiser — with a target of $1 billion for the Treasury over 10 years (a lie, btw, see below)— slipped it into Mr. Trump’s 2017 #taxscam, finally ending the GOP’s 20-year failure with stand-alone bills. The administration is moving quickly so as to get leases out before the 2020 election, making stopping them harder if they lose at the polls.
In keeping with the general dumbing down of America, Deputy interior secretary, David Bernhardt, a former oil lobbyist, called for even the most complex environmental impact statements to be finished within a year and be no longer than 300 pages, Environmental groups and some former Interior Department officials criticized the accelerated timetable, saying it relied on earlier studies that were outdated, particularly in terms of the rapid climate change affecting the Arctic. Scientists were given as little as 48 hours to provide expert comment on draft sections of the environmental reviews and their comments were sometimes not acknowledged. They pointed to damage done to the tundra by seismic testing in the mid-1980s; some vehicle tracks from that work remain visible more than 30 years later. And they worry about the disruption to polar bears, caribou, birds, fish and vegetation. Susan Culliney, policy director at Audubon Alaska, wrote:”The [document] is abysmal. It is inadequate, incomplete, lacks citation and scientific basis to support its conclusions, fails to grapple with the relevant information, and does not connect the dots between the wildlife and the impacts from the planned development.”
Since this is all about the money, let’s go there first.
In 2017, David Yarnold of the Audobon Society wrote this great article on the real economics, not the political charade that got this bill caboosed onto an equally destructive tax scam. The Center for American Progress wrote this one.
Assumptions made: Murkowski told the Senate that ANWR drilling would bring in $1 billion dollars!!! And UNICORNS!!!
- Trump administration (TA) anticipated oil leases selling for 10 times what they sold for last year, with no data to support that hypothesis. In fact, experts see oil demand and prices falling in the face of renewable technology.
- Companies will have to bid an average of $2,400 for every single one of the 1.5 million acres that they propose opening in the refuge. In 2016, Alaskan oil lease sales netted $28.17/acre. In 2018, a North Slope sale “shattered” the bid per acre record, netting an average of $121!!! $121…not even the same number of digits as $2,400!
- (TA) anticipated selling nearly every oil lease that would become available — a goal that is more than double what even the most optimistic recent experience shows would be likely.
- The between 2010 and 2015, industry bid on only 1.5 percent to 5.5 percent of the acres offered in the National Petroleum Reserve — an area that’s five times the size of Massachusetts. Even in the 2016 NPR lease sale — touted as a banner year — industry leased just 42 percent of the acres offered.
- The Trump budget assumed that oil company leases in the Arctic Refuge will generate $1.8 billion in revenues and the Senate budget anticipated revenues of at least $1 billion, sounding very much like Trump’s alleged antics with inflating his income when applying for bank loans.
- This all despite the simple math that Alaska will take half of all revenues off the top, meaning that somehow, the oil leases would have to make $2 billion.
(from the EIS vol. 1, page 3-38) “Due to high costs associated with operating in the Arctic it is extremely unlikely that all technically recoverable resources would be produced.”
- Oil companies will export the oil, fueling the economies of China, Mexico (still not building the wall) and two dozen other countries, not making us more energy independent.
Let’s redo the math with optimistic numbers.
[750,000 acres (50% of the acres offered) x $121/acre]
2 (50% to Alaska off the top) = ± $45 million.
The Center for American Progress is less optimistic, coming in at 37.5 million over 10 years.
Conclusion: We’re going to destroy the largest unbroken stretch of wilderness in America for the prospect of oil companies buying less than half of the available leases at a tenth of the budgeted amount, and then shipping that oil overseas because there’s already a glut in the U.S., for the amount of money Trump would consider a budgetary rounding error.
Now, let’s talk about the documents.
There are 4 main documents to the environmental impact statement (EIS),
EIS vol. 1, EIS vol. 2, EIS vol 2 (app A) and EIS, vol. 2, (App. B – O)
OK, DEEP DIVE AHEAD! GET SOME COFFEE. SIT DOWN AND SEE WHAT YOUR GOP HAS WROUGHT.
Highlights of EIS volume 1: It describes the 4 things that can happen to the ANWR. The BLM laid out one “non-action” option and three “action alternatives” for leasing between two-thirds and all of the coastal plain’s 1.5 million acres. The report acknowledges that energy development could degrade habitat for caribou, migratory birds, polar bears, and other wildlife. Susan Culliney, policy director at Audubon Alaska, wrote in an email. “Each “action alternative” in the EIS is a proposal for a massive new industrial complex in a pristine and cherished American landscape. There are so many problems, it’s hard to know what to mention first. The [document] is abysmal,” she continued. “It is inadequate, incomplete, lacks citation and scientific basis to support its conclusions, fails to grapple with the relevant information, and does not connect the dots between the wildlife and the impacts from the planned development.”
Alternative A: We want “Alternative A” – nothing!
For some reason, polar bear habitat isn’t tracked on the other “alternative” maps…
- “Under Alternative A (No Action Alternative), no federal minerals in the Coastal Plain would be offered for future oil and gas lease sales after the ROD for this EIS is signed. Alternative A would not comply with the directive under PL 115-97 to establish and administer a competitive oil and gas program for leasing, developing, producing, and transporting oil and gas in and from the Coastal Plain.” (We are not sad about this. It’s all a scam anyway.)
- No potential impacts on air quality or AQRVs from oil and gas development on the Coastal Plain would occur.
- no changes would occur to the ambient noise environment
- Topographic alterations: No potential impacts on physiographic features from future oil and gas exploration, development, and production would occur.
- Seismic impacts: No potential impacts on geology or mineral resources from future oil and gas exploration, development, and production would occur.
- Spill accidents: no accidents would occur.
- Paleotological resources: no impacts. (EIS vol 1, p 3-43)
- Biological Resources: no impacts. (EIS vol 1, p 3-71)
- Affects on fish: no impacts. (EIS vol 1, p 3-79)
- Affects on birds: no impacts. (EIS vol 1, p 3-84)
- Affects on terrestrial mammals: Thirty-nine species of terrestrial mammals are known or expected to occur in the Arctic Refuge. Only the polar bear is under federal ESA (Section 3.3.5 of EIS). There would be no impact for Alternative A. (EIS vol 1, p 3-110)
- Affects on marine mammals: All marine mammals found in US waters are protected under the MMPA. Some species receive additional protection under the ESA . Whales, seals, and porpoises are managed by the NMFS, whereas polar bears and walruses are managed by the USFWS. (See Table 3-20 for listing of mammals – EIS vol 1, p 3-123). There would be no direct or indirect impacts on marine mammals under Alternative A.
- The entire program area under Alternative B could be offered for lease sale, and there would be the fewest restrictions on activities. In addition to applicable lease stipulations, several ROPs would apply to post-lease oil and gas activities to reduce potential impacts. Approximately 1,563,500 acres would be offered for lease, 359,400 acres would be subject to a NSO stipulation, and 585,400 acres would be subject to timing limitations (TLs). Standard terms and conditions would apply to approximately 618,700 acres.
- Potential increases in pollutant emissions and associated impacts on air resources are expected to be similar across all action alternatives. While the locations of facilities would vary by alternative based on the lease stipulations that would be applied to protect other resources, the overall levels of surface disturbance and well development would be the same across alternatives (Appendix B)
- The primary noise sources associated with future oil and gas development would be ground-based equipment and aircraft. Median noise levels of drill rigs at 1,000 feet is estimated to be 52 dB, and maximum noise levels are estimated to be 84.4 dB. In a 35-dB ambient sound level, representative of the program area, both would be high-impact, dominant sounds. At a 50-dB ambient sound level, representative of developed coastal areas, the median noise levels would be marginally audible, but maximum sound levels would still be dominant. Assuming a diminishing rate of 6 dB per doubling of distance, sounds from onshore drilling 6 miles away would be below 24 dB at their median level. This median noise level would be inaudible in a 35- dB ambient sound level, but maximum noise levels would be audible and dominant from 6 miles away at that same ambient noise level.
- Topographical alterations: Future construction of infrastructure would affect topography in the program area and could reshape geomorphological features, such as water bodies and permafrost features. All the action alternatives would require placement of gravel fill, for pads, roads and airstrip(s)., which would have the potential direct impact of altering the topography within the development footprint. Sea barge landing and staging structures would affect the pattern of sediment erosion and deposition, which could result in local, long-term changes to the coastline configuration. (See more issues, page 3-26 EIS, vol. 1) Specific to B:
- 204 acres for 17 satellite drill pads
- 200 acres for four CPFs
- 1,560 acres for 208 miles of gravel roads
- Seismic Impacts: (EIS vol.1, pg. 3-34).
- Oil and gas exploration, development, and production could also affect the risk of several geologic hazards identified in the Affected Environment section, including seismicity, slope failure, subsidence, flooding, and river ice jams.
- Future development of petroleum resources would include injection of seawater or gas into the production field to maintain reservoir pressure. Also, wastewater, produced water, spent fluids, and chemicals would be disposed of in injection wells. Injection of large volumes of fluids into low permeability and brittle rocks has potential to trigger low level seismicity (earthquakes).
- Slope failure could be triggered or exacerbated by placement of gravel fill in the future.
- Subsidence associated with thawing permafrost could adversely affect oil and gas infrastructure.
- Warm production and injection wells can cause thawed areas around the well. In 2017, an oil well in the NPR-A suffered a cracked casing due to subsidence from thawing, which resulted in an oil spill. The government is sure all can be mitigated by the “design engineer”.
- Spill accidents: (EIS vol. 1 p. 3-38) “With an estimated 3.4 BBO of production anticipated from the Coastal Plain, and assuming the same spill rates as NPR-A, it is reasonable to anticipate a program area spill total of approximately 1,780 barrels of oil spilled in approximately 636 small spills and a total of approximately 2,716 barrels spilled in two or three large spills. Using a high case scenario and a USGS estimate that 9.3 BBO would be economically recoverable (Attanasi and Freeman 2009), it could be expected that there would be approximately 1,739 small spills with a total of approximately 4,869 barrels spilled, and approximately 6 large spills with a total spill size of 7,374 barrels, if the spill rate stays consistent over time. The rate of spills may decrease over time as industry practices improve.”
- Paleotological resources: (EIS vol 1, p 3-43) Changes to paleontological resources, such as increased exposure due to changes in permafrost, river bank erosion, coastal erosion, and weathering, would continue to occur along current trends. Improving access to areas with paleontological resources may increase unauthorized fossil removal, looting, and damage. Removal of ground cover that would expose fossil-bearing units would expose the unit to weathering influences, which may disturb the resource and its context.
- Biological Resources: Impacts as described. (EIS vol 1, p 3-73)
- Affects on Fish: Post-oil and gas leasing activities that could affect fish and fish habitat would occur under all action alternatives, though their locations could vary. Potential effects on aquatic species and habitats are summarized here; locations that would incur more or fewer impacts are described by alternative (EIS vol 1, p 3-80)
- Affects on birds: The following actions and types of potential effects would be common to all action alternatives, but the avian resources affected (e.g., total area, specific habitats, bird species, and bird densities) would vary based on the location of facilities in each action alternative. They include habitat loss and alteration (EIS vol 1, p 3-94), disturbance and displacement (EIS vol 1, p 3-96), mortality and injury (EIS vol 1, p 3-98), attraction to human activities and facilities, leading to increased mortality. (EIS vol 1, p 3-100).
- Affects on terrestrial mammals: So many adverse affects, they had to make a chart. (EIS vol 1, p 3-111). Includes habitat alteration, fragmentation, and loss of use because of disturbance and displacement. Eliminates below snow habitat for small mammals, reduces forage availability during winter through compaction of snow and underlying vegetation, and disturbs, possible fatally, denning grizzly bears and muskoxen. (EIS vol 1, p 3-117). The potential effects of habitat loss are long term and would continue throughout drilling and operations. Additional habitat alterations from the impacts of snowdrifts, dust, thermokarst, and ponding would continue during operations. Accidental oil discharges in the program area may affect terrestrial mammals, depending on the location and size of the spills.
- Affects on marine mammals:
Specific to alternative B: Because the entire program area is available to lease for oil and gas activity, Alternative B presents the greatest difference from Alternative A by enabling program activities and facilities in nearly all potential terrestrial maternal denning habitat for polar bears in the program area.
- General to all alternatives B-D – Polar bears: All the action alternatives would affect large areas of the designated terrestrial-denning unit of critical habitat for polar bears; any facilities constructed within 20 miles of the coast would be located in that critical habitat unit. Direct loss or alteration of maternal denning habitat would potentially result from gravel mining, gravel and ice road construction, changes in natural drainage patterns (impoundment), and off-pad snow disposal. The permanent, direct loss of polar bear habitat as a result of oil and gas leasing-related activities would primarily involve the terrestrial-denning unit of critical habitat (Map 3-24 in Appendix A) and constituting 77 percent (1,222,300 acres) of the program area. (EIS vol 1, p 3-133).
- Incidental take of polar bears: “Another result of climate change is increasing delays in formation of sea ice in the fall, forcing more bears to spend more time on land where they have difficulty catching prey and spend longer periods fasting and increasing the chance of interactions with humans, which increases the risk of bears being killed in defense of life or property.” (Amstrup 2000; Whiteman et al. 2015) So, for this already stressed population, this project will allow “industry operators to unintentionally take small numbers of polar bears provided that it results in negligible impacts on the species and does not have an unmitigable adverse impact on the availability of the species for subsistence use by Alaska Natives’ because “industry operators” are great judges of all this. (EIS vol 1, p 3-125). The EIS uses old data on kill counts of polar bears from years before the massive ice loss.
- Noise and disruption: Marine mammals, including polar bears, seals and whales would experience direct behavioral effects and indirect habitat loss from disturbance caused by human activities and noise
- Traffic disruption and deaths: “Small numbers” of accidental injury or mortality of marine mammals may occur under all of the action alternatives. Polar bears could be susceptible to vehicle strikes and other marine mammals to vessel/equipment strikes during barging and in-water work.
Accidental spills, leaks, and other sources of contamination. Additional injury or mortality of marine mammals may occur due to accidental spills or contamination. Polar bears are susceptible to thermal stress after fouling their fur by direct contact with spilled petroleum products. Spills associated with development projects on the mainland are of much less concern for polar bears than are marine spills.Three polar bears have died near industrial sites from chemical ingestion as a result of human activity (EIS vol 1, p 3-144)
- The entire program area could also be offered for lease sale under Alternative C; however, a large portion of the program area would be subject to NSO. The BLM would rely on the same ROPs as under Alternative B to reduce potential impacts from post-lease oil and gas activities. Approximately 1,563,500 acres would be offered for lease, 932,500 acres would be subject to NSO, and 317,100 acres would be subject to TLs. Standard terms and conditions would apply to approximately 313,900 acres.
- Pollutants similar to B
- Noise level similar to B but in fewer areas.
- Topographical alterations: Similar to B but
- 216 acres for 18 satellite drill pads
- 150 acres for three CPFs
- 1,598 acres for 213 miles of gravel roads
- Seismic Impacts: (EIS vol.1, pg. 3-34). Sim. to B.
- Spill accidents: (EIS vol. 1 p. 3-38) Sim. to B.
- Paleotological resources: (EIS vol 1, p 3-43) Sim. to B.
- Biological resources: Impacts as described. (EIS vol 1, p 3-73)
- Affects on fish: Sim. to B (EIS vol 1, p 3-80)
- Affects on birds: Sim. to B (EIS vol 1, p 3-101)
- Affects on terrestrial mammals: Sim. to B (EIS vol 1, p 3-119)
- Affects on marine mammals: Sim. to B (EIS vol 1, p 3-146) Most of the historical dens that have been documented in the program area occur in the zones of high and medium HCP, which would be open to development subject to only standard terms and conditions or under NSO stipulations.
- Under Alternative D, portions of the Coastal Plain would not be offered for lease sale to protect biological and ecological resources. In addition, a large portion of the remaining area would be subject to NSO. In some instances, more prescriptive ROPs are analyzed under Alternative D, than under Alternatives B and C. Alternative D1 would have no areas subject to TLs but would have approximately 204,700 acres subject to standard terms and conditions.
- Pollutants similar to B
- Noise level similar to B but in fewer areas.
- Topographical alterations: Similar to B but
- 242 acres for 21 satellite drill pads
- 100 acres for two CPFs
- 1,635 acres for 218 miles of gravel roads
- Seismic Impacts: (EIS vol.1, pg. 3-34). Sim. to B.
- Spill accidents: (EIS vol. 1 p. 3-38) Sim. to B.
- Paleotological resources: (EIS vol 1, p 3-43) Sim. to B.
- Biological Resources: Impacts as described. (EIS vol 1, p 3-74)
- Affects on Fish: Sim. to B (EIS vol 1, p 3-80)
- Affects on Birds: Sim. to B (EIS vol 1, p 3-102)
- Affects on terrestrial mammals: Sim. to B but less (EIS vol 1, p 3-120)
- Affects on marine mammals: EIS believes that this alternative would have the least affect on polar bears. Still is incredibly destructive overall. (EIS vol 1, p 3-147)
- Same as D1 but would have approximately 204,700 acres of TLs and no areas subject to standard terms and conditions.
- All other conditions, see references to D1.
- Interior Dept. Moves Toward Selling Oil Leases in Arctic Refuge (NYTimes)
- Donald Trump’s Extract-Everything energy policy dooms us all (Nation)
- In the blink of an eye, (NYTimes)
- Drilling in the Arctic. Questions for a polar bear expert (NYTimes)