June 19, 2016

 

 

Michael Routhier
Project Manager

U.S. Department of the Interior
Alaska OCS Region
2801 Centerpoint Drive Ste 500
Anchorage, AK 99503-5812

(907) 334-5200

 

 

Re: Comment Letter by Roy David Walker, Fort Lauderdale, Florida, Opposition to the Final Second Supplemental Environmental Impact Statement (EIS) of the Chukchi Sea Planning Area, Oil and Gas Lease Sale 193

  

Dear Mr. Michael Routhier: 

 

 

In reviewing the proposed plan, we agree with Alaska's indigenous people in opposing the Final Second Supplemental Environmental Impact Statement for the Chukchi Sea Planning Area, Oil and Gas Lease Sale 193 (EPA Project #05-049-MMS).

The Chukchi Sea buffers the marine ecosystem, which contains fragile animals under great stress due to climate changes, high toxins accumulated in indigenous animals, and irreplaceable wildlife sensitive to oil spills, ecological mishaps, and global warming. The abundance of microorganisms of the Chukchi Sea comprises much of the food chain's underpinnings for temperate oceans off the East and West Coasts, including the support of fisheries. The Chukchi Corridor, Barrow Canyon Complex, and Hanna and Herald Shoals are critical to this ecosystem's health and will provide resilience in the face of climate change.

 

 

The Chukchi seas is a part of America's Artic Oceans, which is a vulnerable region, and home to indigenous Alaskans, but also to polar bears (Ursus maritimus), walrus (Odobenus rosmarus), seals (Phocidae), bowhead whales (Balaena mysticetus), and over 200 species of birds that will migrate to and thought the East coast of the United States of American. Florida skies and waters are filled with bird species that breed in the Arctic. These exquisite species provide a direct and living connection between Florida and the Arctic, including Alaska's Arctic National Wildlife Refuge. Some birds that are commonly found in Florida are the:

 

• Northern pintail (Anas acuta),
• American golden plover (Pluvialis Dominica),
• Semipalmated sandpiper (Calidris pusilla),
• Lesser scaup (Aythya affinis),
• Peregrine Falcon (Falco peregrinus)

 

 

The Chukchi Sea Program Area is rich in natural resources, including recoverable oil and gas resources, available to be extracted. It consists of 34 million acres within the Chukchi Sea. In the proposed action area, there are 25 miles of buffer area designated by the Secretary in the Final OCS Oil and Gas Leasing Program for 2007-2012. The Second SEIS addresses deficiencies identified by the U.S. Court of Appeals for the Ninth Circuit of Lease Sale 193, which has already occurred. The Second SEIS will also inform the Secretary of the Interior of the decision to affirm, modify, or vacate Chukchi Sea OCS Oil and Gas Lease Sale 193. (OCS EIS/EA BOEM, 2015, p. 57)

 

 

The Five-Year OCS Oil and Gas Leasing Program for 2007–2012 identified certain areas of the Chukchi Sea Planning Area suitable for leasing to develop OCS oil and gas resources. The proposed plan "Alternative I" entailed offering the entire Chukchi Sea Program Area for leasing. This area consists of approximately 34 million acres within the Chukchi Sea, excluding the 25 Statute Mile (40 kilometers (km)) Buffer implemented by the Secretary in the Final OCS Leasing Program for 2007–2012. (OCS EIS/EA BOEM, 2015, p. 57)

 

 

Alternative II plan is the "No Action" Alternative. This plan offers no area of the Chukchi Sea Program Area for leasing and would end Lease Sale 193. (OCS EIS/EA BOEM, 2015, p. 20).

 

 

In Alternative III, the plan offers the entire Chukchi Sea Program Area minus Corridor I. Corridor I extends 60 miles offshore along the Program Area's coastward edge. The lease area will total 24 million acres in the Chukchi Sea and protect the critical bowhead whale habitat. (OCS EIS/EA BOEM, 2015, p. 20).

 

Alternative IV entails leasing the entire Chukchi Sea Program Area minus corridor II. Corridor II is a subset of covered Corridor I, and the total area for lease total is 29.4 million acres. (OCS EIS/EA BOEM, 2015, p. 21).

 

 

Importance of Chukchi Sea Planning Area:

·      Marine mammals: 

·     The Chukchi Corridor is a significant migration passageway for marine mammal species in the U.S. Arctic Ocean. It is a critical passageway for Arctic wildlife migrating north and south during spring, and fall, respectively (Stirling 1997). Except for polar bears and some seals, most marine mammals live in the Chukchi and Beaufort seas during the summer and spend the winter south of the Bering Strait. During the spring period, they disperse northward through the Strait into the Chukchi Sea and beyond (Smith 2010). As the ice begins to thin and break apart, a majority of all species of marine mammals move north in spring, navigating the Chukchi lead system. The Chukchi Corridor is crucial for endangered migrating bowhead whales. During April through June, almost the entire population of bowhead whales travels along the Chukchi Sea coast to approximately 60 miles from shore (Quakenbush et al. 2013).

 

·      Coast and marine birds:

·       

 

The Chukchi Sea is an essential region for marine birds migrating, nesting, foraging, and staging through spring, summer, and fall. Multiple Important Bird Areas (IBAs) line the Chukchi Sea coast stretching into the offshore waters out to about 40 miles. In the Lisburne Peninsula alone, nearly 250,000 colonial nesting seabirds were foraging during the breeding season. Leasing Sale 193 involving the Chukchi Sea Program Area will have great potential to harm marine and coastal birds; potential harms can occur due to Impact Producing Factors (IPF). IPFs are organized by phase of oil and gas activities (OCS EIS/EA BOEM, 2015, p. 305).

 

 

·     This can occur during exploration, development, production, and decommissioning. Each phase can produce noise, physical presence, discharges, habitat alteration, and accidental oil spills. (OCS EIS/EA BOEM, 2015, p. 305).

 

·     Noise has the potential to displace birds from important locations such as foraging areas. There is an energy cost to repeatedly moving away from disturbances (OCS EIS/EA BOEM, 2015, p. 305).

 

·       

The physical presence of vessels, aircraft, and field crews could impact marine and coastal birds, including listed species. Birds typically move away from these activities but could be displaced from essential locations such as foraging areas or nests. Besides, there is an energetic cost to move away from disturbance, loss of opportunities by moving to lower prey availability, disturbance at nest sites could decrease nest productivity due to abandonment or predation (OCS EIS/EA BOEM, 2015, p. 307).

 

·     Structure presents a hazard to flying birds while exploratory drilling could directly affect a very small area of benthic habitat with increased turbidity and discharge of drilling muds and cuttings. These discharges could make it more difficult for foraging birds to locate foods, especially benthic prey. In addition, contamination may impact individual birds either through direct contact or indirectly due to effects on prey populations or important habitats (OCS EIS/EA BOEM, 2015, p. 307).

 

 

·     Direct habitat loss includes the size of the facility footprint and associated sites such as gravel pits and transportation/access routes and indirect habitat loss due to degradation that could occur adjacent to filled areas via dust accumulation hydrological alteration that could alter plant communities. These activities can directly and/or indirectly affect marine and coastal birds by filling or excavating nesting, resting, or foraging habitat (OCS EIS/EA BOEM, 2015, p. 307).

 

 

·     Impacts on birds from oil spills may include fouling of feathers, ingestion, skin irritation, etc. They range from acute exposure, where a bird may be covered by a lethal amount of oil, to chronic exposure, where a bird may be exposed to smaller amounts of oil over a longer period of time. Direct oiling would likely result in loss of feather insulation and acute or chronic toxicity from ingestion and absorption. Oiled birds could also carry oil to nests where eggs and young could be oiled. All birds contacted by spilled fuel are assumed to die. (OCS EIS/EA BOEM, 2015, p. 312-315).

 

 

All proposed actions, except alternative II, will be harmful to marine and coastal birds to some degree, with Alternative I having the most negative impact, followed by IV, and then III. These proposed actions will create varying degrees of morbidity and mortality combined with habitat loss and long-term disturbances from pipeline corridor maintenance. These impacts are expected to have long-lasting changes in the resources of the ecosystem. When added to past, present, and reasonably foreseeable future actions, the effects of Alternatives I and IV would result in a major level of impact on marine and coastal birds. The action alternatives would be the primary driver of impact to this resource over the life of the scenario, particularly to spectacled eiders, king and common eiders, and seabirds, including the short-tailed shearwater and common and thick-billed murres.

 

• The Chukchi Corridor is also a major migration passageway for birds nesting on the North Slope in summer. Birds follow the Chukchi Corridor to northern waters and inland to the North Slope. The corridor contains globally important hotspots for several bird species, including yellow-billed and red-throated loons (Schmutz and Rizzolo 2012); spectacled, Steller's and king eiders (Martin et al. 2009, Oppel et al. 2009, Sexson et al. 2012); black brant (Johnson 1993); common and thick-billed murres (Hatch et al. 2000); glaucous gulls; pomerine jaegers; and black-legged kittiwakes (Smith et al. 2014b). 

 

 

• Aside from its importance during migration, the Chukchi Corridor is an important place for resident animals. Many bird species migrate to the North Slope for summer, travel past Point Hope, through the Chukchi Corridor, then around Point Barrow (or travel the reverse route in the fall). Spring and fall migration and staging corridors are used by the entire breeding population of king eiders in Western North America (Oppel et al. 2009), which is on the Audubon WatchList species due to its depressed population numbers (Kirchhoff and Padula 2010). Kasegaluk Lagoon and Ledyard Bay host post-breeding staging and migration concentration for threatened Steller's eider (Martin et al. 2009). It is a migration area for as much as half of the Pacific brant population, which visits Kasegaluk Lagoon during its fall migration (Johnson et al. 1993). Yellow-billed and red-throated loons migrate to and from wintering grounds in Russia through this corridor between May and October (Schmutz and Rizzolo 2012). In addition to being critical for endangered and depressed bird species, the corridor is used by a variety of shorebirds as they stopover along the Chukchi coast and barrier islands in concentrated groups (Taylor et al. 2010), including tens of thousands of dunlin and red phalarope in the spring, summer, and autumn (Alaska Shorebird Group 2008). It is also home to 19 shorebird species during fall migration and a vital area for molting waterfowl. Kasegaluk Lagoon is a potential Western Hemisphere Shorebird Reserve Network (WHSRN) site (Alaska Shorebird Group 2008).

 

 

• Footprints of some facilities would result in permanent loss of birds nesting habitat, including spectacled eider nesting habitat. Long-term operation of pipelines and access disturbance could displace nesting birds away from the pipeline corridor. Oil and gas activities, not including oil spills, can have the greatest amount of direct harm; vessels and platforms are obstacles to birds in the marine environment and are a long-term bird mortality source. A major impact is anticipated to many species, including coastal and marine birds, during exploration drilling and many offshore platforms. Several species (e.g., king eiders, common eiders, short-tailed shearwaters) could experience mortality exceeding 100 birds per season. The level of potential mortality to marine and coastal birds, combined with habitat loss and long-term disturbances from pipeline corridor maintenance for the entire scenario, is anticipated to impact marine and coastal birds, especially seaducks and seabirds. These impacts are expected to have long-lasting changes in the resource's function in the ecosystem. (OCS EIS/EA BOEM, 2015, p. 312-315).

 

 

• The Chukchi Area is also an Endangered Species Act (ESA) critical habitat for threatened spectacled eiders. Spectacled eiders migrate from the wintering area and use the spring lead system, which includes the Ledyard Bay Critical Habitat Unit (LBCHU); it represents the only open-water area along their path. In 2001, the U.S. Fish and Wildlife Service designated Ledyard Bay as critical habitat for spectacled eaves (Federal Register 2001). This is the principal molting and staging area for more than 10,000 females nesting on the North Slope (Petersen et al. 1999). A large oil spill contacting the LBCHU (ERA10) late in the open-water period could contact and impact tens of thousands of molting eiders. Since the Spectacled eider is considered threatened, this bird's critical territories should be considered protected, which includes the Ledyard Bay Critical Habitat Unit.

 

• The Chukchi nearshore waters provide a network of globally significant Important Bird Areas (IBAs) (Smith et al. 2014a, Smith et al. 2014b). Lisburne Peninsula Marine IBA is a feeding hotspot for black-legged kittiwakes nesting on the peninsula's cliffs. Common and thick-billed murres forage in the IBA and much farther out, over 100 miles offshore (Hatch et al. 2000). Icy Cape Marine IBA was established for significant numbers of foraging glaucous gulls and pomerine jaegers. Nearly a quarter of North America's long-tailed ducks and king eiders use the Barrow Canyon & Smith Bay IBA. The Chukchi Sea Nearshore IBA hosts 15% of the North American population of glaucous gulls. These two IBAs, along with the Beaufort Sea Shelf Edge 152°W 71°N IBA, also have globally significant numbers of Arctic terns, black-legged kittiwakes, glaucous gulls, ponerine jaeger, red phalaropes, red-throated loons, and Sabine's gulls. Using the most recent satellite telemetry data, Ledyard Bay IBA was designated for concentrations of spectacled eiders (Sexson et al. 2012), black-legged kittiwakes, and common murres. Kasegaluk Lagoon IBA also contains a significant breeding population of Pacific brant and the highest diversity and abundance of birds of any lagoon system in Arctic Alaska (Johnson et al. 1993). The Point Lay Marine IBA is home to more than 10,000 long-tailed ducks in summer. The Chukchi Sea Nearshore IBA hosts as much as 15% of the global population of glaucous gulls and 2% of Sabine's gulls' population.

 

 

• Contamination of this nearshore water through oil spills can cause significant long terms morbidity and short-term mortality. Protections of these critical water areas are needed to protect the diverse species of coastal and marine birds. This entails preventing the construction and drilling of oil and natural gases around these waters. (OCS EIS/EA BOEM, 2015, p. 315-325).

 

 

• The Chukchi is ground for nesting colonies that support one quarter million breeding birds (World Seabird Union 2011). From Point Hope to Point Barrow, 31 known nesting colonies along the coast of Point Hope to Point Barrow. The Lisburne Peninsula cliffs host approximately 245,000 seabirds, primarily thick-billed and common murres, black-legged kittiwakes, and horned puffins. Kasegaluk Lagoon is home to 1700 nesting birds, mostly common eiders, glaucous gulls, and Arctic terns. These birds forage in the offshore waters of the Chukchi Sea. Murres and kittiwakes forage over 100 miles offshore (Hatch et al. 2000, Smith et al. 2014a).

 

 

• The only way to prevent contamination and destruction of the natural environment, loss of habitat, prevent loss of threatened species like the spectacled elders, loss of nesting grounds and oil spills prevents Lease Sale 193. Besides, installing 300 miles, onshore pipelines will persist across seasons and cause chronic disturbances to nesting Arctic bird species. The OSRA modeling indicates that the chance of a large spill to marine and coastal birds is relatively low, but the possibility does exist. If such contact occurred, it would result in a clear, long-lasting change in the resource's function in the ecosystem, causing a major impact on various marine and coastal bird populations in the Chukchi Sea. Chronic disturbances to nesting spectacled eiders would be widespread and would persist throughout the 15 years. Oil and gas activities, not including a large oil spill, can moderate marine and coastal birds, including threatened and endangered marine and coastal birds. They are long-lasting and widespread but less than severe. (OCS EIS/EA BOEM, 2015, p. 315-325).

 

 

• The Chukchi is a summer (May through October) core area for Watch-List bird species of concern (Audubon Alaska 2014). Based on Audubon analysis of the North Pacific Pelagic Seabird Database (Drew and Piatt 2013) and the Alaska Water-bird Dataset (Walker and Smith 2014), the Chukchi Corridor is a 50% core use area for brant. Northern migration corridor for marine birds, as they migrate through this corridor, including Steller's eiders (Martin et al. 2009), king eiders (Oppel et al. 2009), ivory gulls (Mallory et al. 2008, Drew and Piatt 2013), and Ross's gulls (Blomqvist and Elander 1981, Drew and Piatt 2013). The area is a major migration passageway for birds nesting on the North Slope in summer. Many bird species migrate to the North Slope for summer breeding migrate through the Chukchi Corridor, then around Point Barrow, or in reverse in the fall. Based on satellite telemetry, the Barrow area is a Steller's eider concentration area (Martin et al. 2009, Smith 2010). King eiders concentrate in Peard Bay and nearshore Beaufort waters during spring and fall staging and migration (Oppel et al. 2009). Spectacled eiders move through the area from June through October in significant concentrations (Sexson et al., 2012). Yellow-billed and red-throated loons migrate to and from wintering grounds in Russia through this corridor between May and October (Schmutz and Rizzolo 2012). A variety of shorebirds stopover along the northeast Chukchi coast in concentrated groups (Taylor et al. 2010). At Peard Bay, upwards of 56,000 shorebirds, mostly red phalaropes, move through during the post-breeding season. At Elson Lagoon, as many as 418,000 post-breeding shorebirds stop during fall migration (Alaska Shorebird Group 2008).

 

 

• Lease Sale 193 can have negative impacts on coastal and marine birds. In addition to the loss of bird nesting habitats, the introduction of pipelines, vessels, and offshore platforms, oil and gas activities will harm multiple species of short-term and long-term birds. Due to the large migration pattern of birds, it is difficult to isolate a given territory for oil and gas lease, exploration, and activities. Although there is a mitigating factor such as Lease Stipulation 7 (lighting protocols, monitoring, recording, and reporting events), the ability to carry out this stipulation is doubtful and tedious, requiring close monitoring by agencies. The only way to prevent the loss of negative impacts on coastal and marine bird species is to prevent the leasing of Lease Sale 193 by choosing Alternative II.

 

 

In Summary, the impact of Proposed Leasing Sale 193 (Alternative I, III, AV): The leasing of the Chukchi Sea Program Area can have many negative impacts. Depending on the alternative picked, except Alternative II, the impact will vary. Negative impacts are variable and can occur to lower trophic organisms, fishes, vegetation and wetlands, subsistence-harvest, public and community health, environmental justice, marine mammals, and marine and coastal birds. In oil spills, marine mammals can be highly impacted if there is large oil spill. The same can be said with large oil spills affecting marine and coastal birds. There is a potential for high mortality in combined habitat loss and long-term disturbances to major pipeline corridors. This will result in major impacts to marine, and coastal birds as large populations of birds depend on these corridors for migration, breeding, feed, and shelter. The effect will be long lasting and will have major consequences to the resource's function in the ecosystem.

 

 

Alternative II (No Action) is the only option to prevent damage to tropic organisms, fishes, vegetation and wetlands, subsistence-harvest, public and community health, environmental justice, marine mammals, and marine and coastal birds. By picking the No Action option, Lease Sale 193 will be terminated. This will save the land and water from contamination, save depletion and loss of resources for mammals, marine and coastal birds.

 

 

In reviewing the proposed plan, we agree with Alaska's indigenous people in opposing any oil and gas leasing, exploration, and development. It will permanently harm the wildlife and wilderness values of these refugees. Our recommendation is to the U.S. Department of the Interior to take Alternative II (No Lease Sale), which is the "No Action" Alternative. This alternative offers no area in the Chukchi Sea for leasing as the Lease Sale 193 has already occurred. Selecting Alternative II based on this Second SEIS process would not affirm the lease sale and vacate the lease. With that said, it would keep the Arctic National Wildlife Refuge and the Arctic Ocean free from drilling and oil spills. It would help save vital Native culture and protect one of the last great American Wilderness Areas. If the U.S. Department of the Interior has any questions, comments, or would like more information on this topic, please feel free to contact me.  

 

 

Sincerely,

 

Roy David Walker

Fort Lauderdale, Florida

 

This email address is being protected from spambots. You need JavaScript enabled to view it.

 

 

References:

 

Alaska Shorebird Group, 2008. Alaska Shorebird Conservation Plan. Version II. Alaska Shorebird Group, Anchorage, AK. 

Audubon Alaska, 2013. Analysis of Survey Effort for Marine Birds, 1974-2009. Audubon Alaska, Anchorage, AK. 

Federal Register, 2001. Endangered and threatened wildlife and plants; final determination of critical habitat for the spectacled eider; final rule, pp. 9146-9185.

Hatch, S.A., Meyers, P.M., Mulcahy, D.M., Douglas, D.C., 2000. Seasonal movements and pelagic habitat use of murres and puffins determined by satellite telemetry. The Condor 102, 145-154. 

Drew, G.F., Piatt, J., 2011. North Pacific Pelagic Seabird Database, v 2.0. US Geological Survey,Anchorage, AK.

Johnson, S.R., Wiggins, D.A., Wainwright, P.F., 1993. Late-summer Abundance and Distribution of Marine Birds in Kasegaluk-Lagoon, Chukchi Sea, Alaska. Arctic 46, 212-227

OCS EIS/EA BOEM. (2015). Final Second Supplemental Environmental Impact Statement (2). Retrieved from U.S. Department of the Interior Bureau of Ocean Energy Management Alaska OCS Region website: http://www.boem.gov/About-BOEM/BOEM-Regions/Alaska-Region/Environment/Environmental-Analysis/Environmental-Impact-Statements-and--Major-Environmental-Assessments.aspx

Oppel, S., Dickson, D.L., Powell, A.N., 2009. International importance of the eastern Chukchi Sea as a staging area for migrating king eiders. Polar Biology 32, 775-783. 

Hatch, S.A., Meyers, P.M., Mulcahy, D.M., Douglas, D.C., 2000. Seasonal movements and       pelagichabitat use of murres and puffins determined by satellite telemetry. The Condor 102, 145-154. 

Kirchhoff, M., 2010. Alaska WatchList: Highlighting Declining and Vulnerable Bird Species in Alaska. Audubon Alaska, Anchorage, AK.

Martin, P.D., Douglas, D.C., Obritschkewitsch, T., 2009. Distribution and movements of Steller's eiders in the non-breeding period. Unpublished manuscript and data. U.S. Fish and Wildlife Service and U.S. Geological Survey.

Schmutz, J.A., 2012. Monitoring Marine Birds of Concern in the Eastern Chukchi Nearshore Area (Loons). U.S. Department of the Interior, U.S. Geological Survey, Alaska Science Center, Anchorage, AK.

Sexson, M.G., Petersen, M.R., Powell, A.N., 2012. Spatiotemporal distribution of Spectacled Eiders throughout the annual cycle, In 15th Alaska Bird Conference. Anchorage, AK 

Stirling, I., 1997. The importance of polynyas, ice edges, and leads to marine mammals and birds. Journal of Marine Systems 10, 9-21 

Schmutz, J.A., 2012. Monitoring Marine Birds of Concern in the Eastern Chukchi Nearshore Area (Loons). U.S. Department of the Interior, U.S. Geological Survey, Alaska Science Center,Anchorage, AK. 

Smith, M.A., 2010. Arctic Marine Synthesis: Atlas of the Chukchi and Beaufort Seas. Audubon Alaska and Oceana, Anchorage.

 

Smith, M., Walker, N., Free, C., Kirchhoff, M., Warnock, N., Weinstein, A., Distler, T., Stenhouse, I., 2012. Marine Important Bird Areas in Alaska: Identifying Globally Significant Sites Using Colony and At-sea Survey Data. Audubon Alaska, Anchorage, AK. 

Smith, M.A., Walker, N.J., Free, C.M., Kirchhoff, M.J., Drew, G.S., Warnock, N.D., Stenhouse, I.J., in review. Identifying marine important bird areas using at-sea survey data. Biological Conservation 

Taylor, A.R., Lanctot, R.B., Powell, A.N., Huettmann, F., Nigro, D.A., Kendall, S.J., 2010. Distribution and community characteristics of staging shorebirds on the northern coast of Alaska. ARCTIC, 451-467. 

Quakenbush, L.T., Small, R.J., Citta, J.J., 2013. Satellite tracking of bowhead whales: movements and analysis from 2006 to 2012, ed. B.o.O.E.M. U.S. Department of the Interior, Alaska Outer Continental Shelf Region, p. 60pp plus appendices, Anchorage, AK.

World Seabird Union, 2011. Seabird Information Network: North Pacific Seabird Data Portal.

World Seabird Union, www.seabirds.net.