Tues 12/8: Two actions to defend the Arctic Refuge from oil drilling! Deadline Dec. 17th.

“The Gwich’in have been fighting for decades to protect the coastal plain of the Arctic National Wildlife Refuge, known to them as “Iizhik Gwats’an Gwandaii Goodlit” (The Sacred Place Where Life Begins). The Trump administration is taking aggressive steps to fast track plans to give oil and gas companies the right to drill on these lands. Drilling will destroy intact wilderness and violate the human rights of the Gwich’in, who rely on this sacred place to sustain their culture and way of life.

The Gwich’in are fighting to protect their future, but they can’t win this battle alone.“

Action #1: Call or email your legislators.

Minimal phone script: I’m calling from [zip code], to ask [Senator/Rep.___] to stop oil extraction in the Arctic National Wildlife Refuge, an environmental disaster being forced upon us by the incredibly corrupt 2017 Tax act. I expect [him/her] to stand with Gwich’in and Inupiat land protectors to permanently protect the Arctic Refuge.”

Minimal Email/calling script: I’m writing to ask [Senator/Rep.___] to prioritize protecting the Arctic National Wildlife Refuge from oil extraction. The Arctic Refuge has been protected by Congress for 60 years and by Indigenous peoples for millennia before that. The climate impacts of fossil fuel extraction in the Arctic are not worth the risk–this is a sensitive ecosystem that sustains many lives, some endangered because of the climate crisis. We cannot afford to invest in dangerous extraction projects any longer. Please listen to the Indigenous land protectors who are leading the movement to protect the Arctic Refuge, along with businesses who’ve done their homework (https://www.sierraclub.org/sites/www.sierraclub.org/files/blog/Investor%20Arctic%20National%20Wildlife%20Refuge%20Letter%205.11.pdf) and do all that you can to stop oil extraction on the coastal plain. Please work to reverse the damage done by the 2017 Tax act and stand with Gwich’in and Inupiat land protectors to permanently protect the Arctic Refuge.”

Contacts:

• Rep. Julia Brownley: email, (CA-26): DC (202) 225-5811, Oxnard (805) 379-1779, T.O. (805) 379-1779
• or Rep. Salud Carbajal: email.(CA-24): DC (202) 225-3601, SB (805) 730-1710 SLO (805) 546-8348
• Senator Feinstein: email, DC (202) 224-3841, LA (310) 914-7300, SF (415) 393-0707, SD (619) 231-9712, Fresno (559) 485-7430
• and Senator Harris: email, DC (202) 224-3553, LA (310) 231-4494, SAC (916) 448-2787, Fresno (559) 497-5109, SF (415) 981-9369, SD (619) 239-3884
• Who is my representative/senator?: https://whoismyrepresentative.com

Action #2: EMAIL/Write the BLM! Deadline Dec. 17

(Note: To make it harder for us, the public, to fight back, the BLM had, UNTIL TODAY(!!!), refused to accept comments by email, forcing us to buy stamps and mail letters or postcards during a pandemic. This could have been considered discriminatory, as their actions are generally conducted with an email option, or exclusively by email. So now, they are accepting email comments.)

• Write a comment or a letter. (Letter sample below.)
• EMAIL: blm_akso_ak932_cpcomments@blm.gov
• MAIL: State Director, BLM Alaska State Office, 222 West 7th Ave., MailStop 13, Anchorage, AK 99513-7504. All mailed comments should be postmarked by Thursday, December 10, 2020.
• Currently, stamps for letters are 55 cents each and 39 cents for postcards. Please make sure that if you’re using an older non-Forever stamp, that your stamps will cover the current cost of postage. 
• Be aware that these comments will be posted on BLM’s website, so be careful what contact info or other personal info you include in your comment. 

“Build-a-Letter/email“

(Try to make your comment feel like your voice throughout by editing, changing words, etc.. The BLM keeps track of what they call “stock” letters, and they are discounted.)

Sample material for letters/emails and Tweets

(Unless marked otherwise, source material from here and here. Sierra Club letter here, here, and article here. Pick a few for any one comment. Don’t let yourself get overwhelmed. One short, focused phrase or paragraph is better than no comment at all.)

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.

#1 – General Fact

• The 19 million acre Arctic National Wildlife Refuge, originally set aside by President Dwight Eisenhower in 1960, is one of the wildest places left on the planet. The Arctic Refuge protects more abundant and diverse wildlife than any other conservation area spread amongst 5 nations in the polar north, including calving caribou, rare musk oxen, denning polar bears and millions of migratory birds that nest or stage in the Refuge before traveling through every U.S. state and five continents. Roads, pipelines, gravel mines, airstrips and other facilities that would be developed to support exploration and development on the coastal plain would undermine the wilderness character of the Refuge, fragment habitat and displace wildlife. Millions of gallons of fresh water, needed to support drilling activities, could be drained from fragile Arctic rivers. And oil spills, which already occur on the North Slope, would harm fish and wildlife.
• The Arctic National Wildlife Refuge is one of the last truly untouched wildernesses of North America.
• Every single one of the 32 tracts BLM is considering selling off for drilling in the Arctic Refuge coastal plain include sensitive resources that would be threatened by drilling.
• 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.
• Every single one of the 32 tracts under consideration in the Arctic National Wildlife Refuge for leasing contains sensitive habitat and resources that would be threatened by drilling. This includes habitat for threatened polar bears, countless bird species, and the Porcupine caribou herd, which the Gwich’in people rely on for their subsistence and culture. This rushed process has ignored concerns about threats to the Gwich’in people, threatened wildlife, and our climate. 
• The coastal plain is habitat for millions of birds which come from every continent, including off the coast of Antarctica, to breed, forage, and molt. BLM is disregarding impacts to birds by planning oil leases in the Arctic Refuge.
• One of our last truly wild places, the Arctic Refuge is no place for drilling, but the Trump administration’s wants to “get leases in the hands of the oil and gas industry, science and transparency be damned.” said Kate Kelly, public lands director for the Center for American Progress. “The result of that particular focus is ultimately a dishonest look at the impacts that drilling would have on the refuge, its wildlife and the indigenous populations that rely on it for subsistence.”
• The Arctic National Wildlife Refuge, which was established in 1980 by Congress, provides habitat for a wide variety of animals, including 45 species of land and marine mammals, 36 species of fish, and more than 200 species of birds that come from six continents to breed, rest or feed from April to July. The refuge’s coastal plain — stretching north from the Brooks Range to the Arctic Ocean — is home to endangered polar bears and is the calving ground of the Porcupine caribou herd. Christopher Moorman, professor and interim associate head in the Department of Forestry and Environmental Resources at NC State’s College of Natural Resources, stated that wild, undeveloped places such as the refuge are increasingly rare in the United States and the rest of the world. While strategies can be employed to mitigate or minimize the effects on wildlife, it is often difficult or impossible to reverse course once development occurs.
• I am gravely concerned about the climate, financial and reputational risks associated with pursuing a speculative fossil fuel source that will likely become uneconomical as the world rapidly shifts towards clean energy sources. Destroying this wilderness area would also have devastating human and ecological impacts.

#2 – Criticism of original report.

• The government’s report, which has downplayed or ignored serious environmental risks, has been criticized by specialists, scientists and environmentalists. Scientists were given less time than usual to provide expert comment on draft sections of the environmental reviews — just 48 hours in some cases — and that their comments were sometimes not acknowledged. This issue is too important for such slapdash procedures.
• The BLM decided conduct an environmental assessment of the seismic testing proposal, a less rigorous review than a full environmental impact statement. This was especially troubling for many drilling opponents. They point 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. This area is too fragile for anything less than a full environmental impact statement.
• Your agency’s report has been criticized by environmentalists  as insufficient, saying it was largely based on older research and failed to address several concerns. For instance, critics have noted, the environmental impact statement does not provide an estimate of how many polar bears could potentially be killed or harmed by exploration in the coastal plain. Before your can go forward, you need to produce a trustworthy, accurate report.
• Drilling opponents have stated that the Interior Department downplayed the risks of climate change in its review. For example, the agency estimated that the refuge could produce as many as 10 billion barrels of oil over its lifetime, but argued that the effect on greenhouse gas emissions would be minimal, since most of that oil would simply displace oil being produced elsewhere in the country. In comments submitted to the agency, the attorneys general from 15 states, including New York, called this displacement theory “completely unsupported.” This is 2020, not Reagan-land. We expect a thorough analysis of climate change issues before any development occurs.

#3 – Gwich’in-centric comments:

• This land has been stolen from Arctic people, and is crucial to local food security as well as the health of our planet. NONE of it should be subject to leasing or oil extraction.
•  The coastal plain is held sacred by the Gwich’in Nation, who have depended on this special place and the wildlife within it for their food security and way of life for generations. 
• Industrial development anywhere on the coastal plain poses an existential threat to the Gwich’in, threatening their food security and human rights, but the Department of the Interior has failed to adequately study the impacts of drilling on natural resources and the subsistence lifestyle of the Gwich’in people.
• This rushed process has ignored concerns about threats to the Gwich’in people, threatened wildlife, and our climate. This lease sale must not go forward.  
• Iizhik Gwats’an Gwandaii Goodlit, ‘The Sacred Place Where Life Begins,’ is the birthing ground for the Porcupine Caribou Herd, which Arctic peoples of North America have both protected and relied on for thousands of years. Trump’s administration is rushing through a sham of a process to officially “sell” parts of this sacred land to oil companies for profit. Meanwhile, the health of the Earth and our climate are deteriorating before our eyes. Arctic people’s ways of life are in danger as BLM moves forward with lease sales, planned for Jan 7, 2021. Follow @DefendTheSacredAK to take action and stand with Arctic peoples to #ProtectTheArctic. #StandwithTheGwichin #InupiatGwichinSolidarity
• Drilling in the #ArcticRefuge threatens Indigneous food security at the height of a pandemic. The #Trumpadmin and @BLMNational 11th hour push of illegal lease sales is criminal. Follow @DefendTheSacredAK to take action and stand with Arctic peoples to #ProtectTheArctic. #StandwithTheGwichin #InupiatGwichinSolidarity
• Arctic Peoples’ lives are in danger due to a rapidly warming climate. A rushed and illegal Arctic Refuge oil lease sale on their ancestral homelands–planned for January 7, 2021–is projected to emit an additional 4 million tons of carbon dioxide. Meanwhile, President Trump and Alaska’s Governor Dunleavy refer to this sacred land as “America’s Warehouse.” Stand with the Gwich’in and Inupiaq Protectors today–this land is #NotYourWarehouse. Follow @DefendTheSacredAK to take action and stand with Arctic peoples to #ProtectTheArctic. #StandwithTheGwichin #InupiatGwichinSolidarity
• For thousands of years, Gwich’in and Inupiat peoples have lived in relationship to the Sacred birthing grounds of the porcupine caribou herd, Iizhik Gwats’an Gwandaii Goodlit ‘The Sacred Place Where Life Begins.’ Sixty years ago, Congress granted federal protection to these Sacred lands that Indigenous people have protected for thousands of years. The Arctic Refuge is currently under attack as the Trump administration rushes lease sales on the coastal plain. Follow @DefendTheSacredAK to take action and stand with Arctic peoples to #ProtectTheArctic. #StandwithTheGwichin #InupiatGwichinSolidarity
• The Gwich’in peoples of Alaska and Canada are culturally and spiritually connected to the Porcupine caribou herd, which relies on the Coastal Plain for calving and post-calving habitat. The Gwich’in consider the coastal plain as sacred, and the place where life begins. It is vital to their human rights and food security. 
• Despite acknowledging that oil and gas can have impacts on caribou, BLM concludes that there will not be an impact on the subsistence resources for the Gwich’in and that the subsistence needs of the Gwich’in do not qualify for an 810 hearing under ANILCA (Alaska National Interest Lands Conservation Act) which is required for development that will substantially affect subsistence. Despite the fact that a significant percent of Gwich’in subsistence comes from the Porcupine Caribou Herd, which the BLM’s own analysis finds leasing will affect, they then find that Gwich’in subsistence use will not be affected. This ignores the traditional knowledge and human rights of the Gwich’in.

#4 – Caribou-specific comments:

• The Gwich’in Nation — Indigenous people of Alaska and Canada – consider the coastal plain sacred and have relied on the Porcupine Caribou Herd that migrates there for thousands of years for their primary food source and way of life.
• The Gwich’in people of  Alaska and Canada are culturally and spiritually connected to the Porcupine Caribou Herd, which in turn relies on the Coastal Plain for calving and post-calving habitat. The Gwich’in consider the coastal plain as sacred, and the place where life begins. It is vital to their human rights and food security.
• The Gwich’in have a deep cultural and spiritual connection to the caribou, and still rely on the herd for 80% of their diet. 
• The Porcupine Caribou Herd depends on the coastal plain as a safe place to calve their young, where baby caribou are protected from predators and insects that carry disease.
• It is well documented that oil and gas development and infrastructure impacts and displaces caribou, and that caribou mothers are particularly sensitive to disruptions. 
• Gwich’in traditional knowledge also tells us that industrial activity in the coastal plain will disrupt the sacred calving and nursing grounds of the Porcupine Caribou Herd.
• The entire coastal plain is critical for caribou, but BLM has failed to incorporate these concerns or adequately analyze or provide protections to address these impacts.
• The Coastal Plain provides vital calving and post-calving habitat for the Porcupine Caribou Herd (PCH). The Coastal Plain offers nutrient rich forage, protection from predators, and relief from the relentless insects of the Arctic. 
• The PCH use all of the Coastal Plain for various habitat needs during its annual migration. The BLM acknowledges that oil and gas activities will likely disturb and displace caribou, especially sensitive cows and calves. Map 3-21 shows PCH calving  and post-calving covering most of the Coastal Plain (Vol. 2, 3-21).
• BLM estimates that only 49% of the Coastal Plain is sensitive calving grounds for the PCH, but this vastly undercounts the value of the coastal plain to the caribou, who use essentially all of the Coastal Plain during calving and post-calving when they are sensitive to disturbance.The agency fails to adequately address these impacts and to consider the full range of areas that are important to caribou.
• A 2002 USGS modeling study estimated that if drilling on the coastal plain were as extensive as on the North Slope, the survival rate of caribou calves would drop by as much as 8%, depending on where most calving occurred, in part because of greater exposure to predators and lower-quality forage. Such mortality could ultimately cause herd numbers to fluctuate more dramatically, and make it harder to recover from declines, the study concluded.
• Anything that moves the herd away from the Coastal Plain has been shown to be detrimental to calf survival (Vol 1, p. 3-114) and in fact would likely halt population growth (Vol 1, p. 3-115). Additionally, other potential calving areas to the east have a higher density of predators and less suitable vegetation.
• The DEIS offers insufficient mitigation of the impacts to PCH. Even the most restrictive alternative only halts “major construction activities”–but not drilling–for a single month of the year when caribou are calving (Vol 1, 2-13).
• The energy industry represents that oil and caribou can mix, that it has been done before with success elsewhere on the North Slope. However Ken Whitten, who, for many years, was Alaska’s lead state biologist for the Porcupine herd states that the statement is misleading. Yes, caribou inhabit some areas around Prudhoe Bay, where the pipeline begins. But studies around the oil fields have found that pregnant females will avoid development. As development increased, calving caribou were pushed southward where the food wasn’t as nutritious, resulting in the mothers having lower-weight calves. These problems will likely be exacerbated in the refuge, said Mr. Whitten. A 2002 report by him and others predicted that extensive oil development would probably stop the growth of the herd, and perhaps worse. “We don’t think there’s any way you can have a large oil development on the 1002 and not have adverse effect on caribou.”

#5 – Polar Bear-specific comments:

• Almost all of the coastal plain is designated as critical denning habitat for polar bears under the Endangered Species Act, where mother bears give birth and nurse their newborn cubs. 
•  Keeping this area free from disturbances is essential to ensuring the survival of newborn polar bear cubs. 
• The U.S. Fish and Wildlife Service has admitted that leasing in areas where polar bears den will negatively impact polar bears. 
• BLM has failed to adequately analyze the impact of drilling on polar bears. 
• Environmentalists have criticized the agency’s review as insufficient, saying it was largely based on older research and failed to address several concerns. For instance, critics have noted, the environmental impact statement does not provide an estimate of how many polar bears could potentially be killed or harmed by exploration in the coastal plain.
• There are currently just 900 Southern Beaufort Sea polar bears, and the population has declined approximately 50% in the last 30 years (Vol 1, p. 3-125). The use of land in the Coastal Plain for denning and as summer refuge for polar bears in the region has and will continue to increase with the loss of sea ice, pushing more and more polar bears to require the Refuge for survival.
• Polar bear critical denning habitat constitutes 77% of the program area (Vol 1, p. 3-133) and maternal dens are disproportionately high in high hydrocarbon potential zones (Vol 1, p. 3-134).
• The DEIS acknowledged that “the potential for injury or mortality could be high when developing new oil and gas projects in polar bear habitat.” (Vol 1, p. 3-142) Nevertheless, there is no estimate of the number of bears that could be killed, injured or displaced by the leasing process or seismic testing.
• Steven C. Amstrup, chief scientist with Polar Bears International, a conservation group, said the coastal plain in the refuge “ “is the most important maternal denning area” for the southern Beaufort Sea population. Pregnant bears dig winter dens in the snow on the coastal plain, and if those dens are not detected during the seismic work, the mothers and their newborn cubs could be disturbed or endangered by the heavy trucks. Dr. Amstrup, a former United States Geological Survey zoologist who has studied the bears for three decades, said his research had shown that the heat-sensing technology used to detect dens would probably miss about half the dens, which would probably be disturbed during the seismic work.

#6 – Financial issues and Fake facts

• This whole venture of drilling in the Arctic refuge is based on made-up numbers to balance the GOP 2017 Tax Plan. There is no analysis of expected revenues, despite the projected $2 billion in revenue ($1 billion to the State of Alaska and $1 billion to the federal government) being a major factor in allowing attachment of this rider to the Tax Act. One source estimates that development would yield a tiny fraction of that, with one estimate being that of just $45 million over a decade. Larger firms with deeper pockets wouldn’t risk their reputation there, leaving the field open to for less monetized and inexperienced operators.
• I am gravely concerned about the climate, financial and reputational risks associated with pursuing a speculative fossil fuel source that will likely become uneconomical as the world rapidly shifts towards clean energy sources. Destroying this wilderness area would also have devastating human and ecological impacts.
• The report this venture is based on is woefully incomplete. Where is the discussion of how damage and reclamation costs will be covered by bankrupt or foreign companies? More petroleum firms are going bankrupt, and the costs to close and clean up sites may exceed an company’s assets. “Almost 250 oil and gas companies could file for bankruptcy protection by the end of next year, more than the previous five years combined.” We taxpayers will end up on the hook for restoration costs.
• The Sierra Club letter of 2018 states “We, the undersigned investors representing $2.52 trillion in assets under management, oppose any efforts to develop oil and gas in the remote and pristine Arctic National Wildlife Refuge in northeast Alaska, and we strongly urge oil and gas companies, and the banks that fund them, not to iniatie any oil and gas development in the Arctic Refuge.”
• The Sierra Club letter of 2018 states “Many corporations, governments and investors are developing business plans that assume a 2 degree Celsius climate risk scenario. Financial regulators, analysts and other experts have also endorsed the importance of climate risk analysis, noting that a carbon budget consistent with a 2°C target will render most fossil assets unburnable. Thus, making any capital investments to pursue Arctic Refuge oil would be an irresponsible business decision, at the very time when we are transitioning from fossil fuels. Oil company assessments and independent research analyses project that global oil demand will decline as electric cars and other clean technologies continue to increase market share and global economies work to keep within a 2 degree scenario carbon budget.“
• The Sierra Club letter of 2018 states “The majority of Americans oppose drilling in the Arctic Refuge. Research commissioned by the Yale Program on Climate Change Communication shows that 70% of American voters oppose drilling in the Arctic National Wildlife Refuge. Any oil company or bank that supports drilling in the Arctic National Wildlife Refuge faces enormous reputational risk and public backlash. Their brands would be associated with destroying pristine wilderness.“
• In addition to its impacts on wildlife, oil and gas drilling within the refuge could also lead to a decrease in tourism, according to Jonathan Casper, associate professor in the Department of Parks, Recreation and Tourism Management. A survey by Casper and other researchers, published in the Journal of Outdoor Recreation and Tourism in 2017, examined the impacts of hydraulic fracturing on park usage. Park users who participated in the survey expressed concern that fracking operations would hinder their ability to access parks and enjoy recreational activities. There is also evidence to suggest that park users would avoid parks near fracking operations, with more than half of all survey participants responding that they were willing to travel further to visit parks unaffected by fracking.
• The EIS this land leasing scheme is based on 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. 

#7 – Water Quality and Quantity

• One of the specific purposes of the Arctic National Wildlife Refuge as established in ANILCA is to ensure “water quality and necessary water quantity within the refuge” to conserve fish, wildlife and habitats. This DEIS must demonstrate adherence and that the lease sale will not negatively impact water quality and quantity.
• Water on the Coastal Plain of the Arctic Refuge is particularly scarce. There are few open lakes  and rivers compared to the Western Arctic and especially in winter when the surface is frozen there is very little free water available. The BLM does no new analysis of how much water is actually available on the Coastal Plain and therefore does an insufficient job of analyzing impact to that water quantity.
• The DEIS avoids providing a clear estimate of how much water will be required, but if you piece together the information in the document, the figure is staggering. Center for American Progress did this and found that: 
  • The DEIS estimates that drilling each well requires 420,000 to 1.9 million gallons of water. All of the alternatives have at least 17 ‘satellite pads’ and 1 anchor pad. (Volume 2, Table B-5). And the DEIS estimates that 30 wells will be drilled from the average pad (Volume 2, B-17). So at least 540 wells would be drilled, requiring a total of between 227 million and 1 billion gallons of water just to drill the wells.
  • PLUS, every mile of ice road requires 1 million gallons of water (Vol. 2, B-13), each ice pad requires 500,000 gallons of water (B-12), and daily production of 50,000 barrels of oil would require 2 million gallons of water per day. 
• In their comments on the NOI, US Fish and Wildlife Service emphasized concerns about the “cumulative impacts of all stages of oil and gas development” on water: “Water withdrawals from the streams, rivers and springs could have significant and detrimental implications to the populations and habitats of fish and wildlife.”
• Because the oil industry is the driver for this whole endeavor, there is language in the Wetlands section (p.30) allows weasel room: that the agency should avoid undertaking or providing assistance for new construction located in wetlands unless the head of the agency finds:
  • There is no practicable alternative to such construction, and
  • The proposed action includes all practicable measures to minimize harm to wetlands which may result from such use. In making this finding the head of the agency may take into account economic, environmental and other pertinent factors.

#8 – Infrastructure and the 2000 acre rule.

• The Tax Cuts and Jobs Act of 2017 stipulated a 2000 acre surface development limit on the Coastal Plain. However, the DEIS decided that that ice roads and pads, elevated pipelines, and gravel mines do NOT count as surface disturbance and, therefore, are not considered in the 2,000 acre limit of surface acres outlined in the PL 115-97 (Vol. 2, Appendix B-9). 
• BLM stated that “inclusion of such facilities would make Congress’s clear purpose – establishment of an oil and gas program on the Coastal Plain – impracticable” suggesting that they conducted their analysis in order to draw the desired conclusion (Vol. 2, Appendix B-9).
• Further, they rationalized excluding gravel mines as being infrastructure that “they supply raw materials for construction of oil and gas facilities but are not themselves oil and gas facilities (Vol. 2, Appendix B-9).” 
• BLM is also only counting 2000 acres “at any given time” (Vol 1, p. 3-221). This means that any land that is “reclaimed” can be deducted from the 2000 acre cap and credited toward more development. This rolling cap interpretation would allow for the entirety of the coastal plain to see the impacts of development over time.

#9 – Oil spills.

• The risks of oil spills are dramatically understated in the DEIS.
• The DEIS minimizes the potential for a spill by stating that “The probability of a spill over 100,000 gallons is low,” because on the North Slope,  “only three documented spills have been greater than 100,000 gallons.” (Volume 1, p. 132)
• According to Center for American Progress, oil fields on the North Slope have averaged more than 400 oil spills per year, and across Alaska, there were 16 major spills from 2002 to 2016 that released at least 10,000 gallons of oil into the environment. Five of those spills released more than 100,000 gallons of oil. Read more here.

#10 – Climate Change

• Expanding oil and gas development in the Arctic will further exacerbate climate adaptation and mitigation challenges in an Arctic that is warming at twice the rate of the rest of the country. The EIS for oil and gas leasing on the coastal plain downplays unacceptable climate impacts of extraction in the Arctic. 
• The BLM significantly underestimated carbon emissions that would result from drilling the Arctic Refuge, estimating only 56,739 to 378,261 metric tons of annual direct GHG emissions (from extraction, transport, etc) and  0.7 to 5 million metric tons of annual indirect GHG emissions (from combustion and downstream use of the oil) – measured in CO2 equivalent. (Volume 1, Table 3-5 p.78)
• This is a very misleading set of numbers and is calculated only from the increase from oil demand that the analysis predicts will result from developing the Refuge. It does not account for burning all of the oil they project will be extracted. That number is much larger. CAP estimates that the equivalent to the annual emissions of 16 coal fired power plants would be emitted – roughly 62 million tons.
• This document completely fails to assess how expanding oil and gas development in the Refuge will further exacerbate climate adaptation and mitigation challenges in an Arctic that is warming at twice the rate of the rest of the country.
• Drilling opponents have stated that the Interior Department downplayed the risks of climate change in its review. For example, the agency estimated that the refuge could produce as many as 10 billion barrels of oil over its lifetime, but argued that the effect on greenhouse gas emissions would be minimal, since most of that oil would simply displace oil being produced elsewhere in the country. In comments submitted to the agency, the attorneys general from 15 states, including New York, called this displacement theory “completely unsupported.”

#11 – Specific comments referring to specific tracts.

Better resolution map of tracts #1-32 up for lease here.

Tips for comments referring to tracts.

• Tracts #1-32 should be excluded from oil leasing, as the coastal plain provides critical habitat for denning polar bears. As sea ice recedes due to warming temperatures, land denning sites in the Arctic Refuge become increasingly important. According to Map 3-37, leasing this tract would have unacceptable impacts on denning polar bears and polar bear critical habitat. ( Map for reference: Polar bear critical habitat and denning sites ) 
• Tracts #1-32 should be excluded from oil leasing, as it holds critical calving and post-calving habitat for the Porcupine caribou herd. ( Map for reference: Post-calving movement of Porcupine caribou and Porcupine herd calving areas)
• Tracts #27, 7, 31, 29, 32 should be excluded from oil leasing to preserve critical fish habitat. According to FEIS Map 3-19, this tract includes essential habitat for Arctic Cod. (Tracts: 27, 7, 31, 29, 32. Map for reference: Essential fish habitat)
• Tracts #1-32 should be excluded from oil leasing, as the coastal plain is habitat for millions of birds which come from every continent, including off the coast of Antarctica, to breed, forage, and molt. BLM is disregarding impacts to birds by planning oil leases in the Arctic Refuge. 
• Tracts #4, 5, 7, 11, 12, 18, 19, 20, 21, 28 should not be considered for oil leasing, as it provides important habitat for Snow Geese, seeing more than 21 flocks of Snow Geese over 500 in number between 1982-2004 according to FEIS Map 3-26. ( Map for reference: Frequency of Occurrence of Snow Geese)
• Tracts #1-32 should be excluded from oil leasing, as an original purpose of the Arctic National Wildlife Refuge as established in ANILCA is to ensure “water quality and necessary water quantity within the refuge” to conserve fish, wildlife and habitats.  The BLM did no new analysis of how much water is actually available on the Coastal Plain in the coastal plain EIS and therefore does an insufficient job of analyzing impact to that water quantity. 
• Tracts #1-32 should be excluded from oil leasing, as all tracts (over 99% of the coastal plain) are visible from high points within the federally designated Wilderness portion of the refuge. The negative visual impacts on Wilderness recreation in the Arctic Refuge negate the original wilderness and recreation purposes of the Arctic Refuge as established in ANILCA. (Tracts: all)

Deep Dive Resources

This is an adaptation from our original post on 3/12/2019. It described the ramifications of the various scenarios that the BLM proposed, along with the most destructive one, “Plan B,” that they picked.

Trump is wrong about his disastrous tariff program, his malevolent border wall, and his back-to-the-1950’s-style environmentally disasterous  energy dominance program, which includes this drilling program in the ANWR.  The administration’s finalized Environmental Impact Statement and impending lease sale brings us to the brink of tearing open the Arctic Refuge’s pristine, publicly-owned land for fossil fuel extraction.

And for what? A quote from their own report: “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.”

“If there is oil, it’ll be gone in a generation,” says Adam Kolton, executive director of the Alaska Wilderness League. “But the damage would last for thousands of years.”
(PDF versions of planning documents here. EIS vol. 1, EIS vol. 2, EIS vol 2 (app A) and EIS, vol. 2, (App. B – O)_

Background

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, GET SOME COFFEE. SIT DOWN AND SEE WHAT OUR GOP HAS WROUGHT.

Highlights of EIS volume 1: It described the 4 things that could 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. 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.”

Note: Update: 2020. Crossed-off alternatives are no longer on the table.

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.

Update to 12/8/2020 – This is what Bernhardt picked – Alternative B:

• 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)

Alternative C:

• 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.

Alternative D1:

• 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)

Alternative D2:

• 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.

Reading

EIS vol. 1

• 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)