While the nation waits in collective anxiety to learn who will be the next President, the Bureau of Land Management, in keeping with its Trump-era tradition of attempting to push through major projects on OUR public lands with minimal public notice, quietly released a plan late Friday October 23 to initiate seismic exploration for oil & gas in the Arctic National Wildlife Refuge, beginning NEXT MONTH.

Despite offering a paltry 14-day comment period, BLM has done virtually NOTHING to solicit public input on this proposal, which would expose almost 850 square miles of the Refuge’s delicate tundra ecosystem and wildlife on the Coastal Plain to a checkerboard of heavy machinery tracks, ‘temporary’ airstrips, and a huge mobile basecamp servicing up to 180 people. The plan is not on the Department of Interior news page (nor was it in the weekly newsletter), not in the BLM Alaska blog, not even on the BLM Alaska home page.

COMMENTING ON THIS PROPOSED ACTION CLOSES FRIDAY, NOVEMBER 6.

Your comment may be submitted via e-mail to: blm_ak_rdo_cp_2020_seismic@blm.gov  Or, skip to the end for links to some form options. However, when commenting on federal land management actions, a non-form letter is always best. You are welcome to use any part of this article in forming your own comment!

What’s going on?

From the BLM Project Page: ‘Kaktovik Iñupiat Corporation (KIC) has requested authorization to conduct 3-dimensional winter seismic activities on the eastside of the Arctic National Wildlife Refuge Coastal Plain for the winter season of 2020-2021. Seismic exploration generates acoustic waves that are picked up by sensors as the waves bounce off subsurface formations. From this information, images can be created that show subsurface topography and formations including those areas of potential hydrocarbons.’

What does that mean?

In a nutshell, it means THIS IS THE BEGINNING OF DRILLING in the Arctic National Wildlife Refuge.

Specifically, it means a fleet of 95,000-pound vehicles that will (very loudly) create a checkerboard of compression tracks on the Refuge’s delicate tundra ecosystem. This will occur 24 hours a day throughout the winter, covering 542,592 square acres with almost 10,000 MILES of line in an effort to find oil & gas deposits. This will be supported by a moving ‘sled camp’ serving up to 180 people that will also move every 2-7 days (depending on which of the submitted plans you choose to believe as there is a discrepancy). An unidentified quantity of ‘temporary’ airstrips will also be built to accommodate re-supply and crew changes that will occur 2-4+ times per week.

Despite the submitted plans placing an emphasis on ethical and responsible care for wildlife and the environment, the corporation who will be conducting this operation is currently in bankruptcy, and also facing accounting fraud charges by the Securities and Exchange Commission (SEC). Additionally, the (now-former) CEO of SAExploration Holdings, the designated project operator, was indicted less than two months ago by the Department of Justice (DoJ) on multiple fraud charges and arrested in Alaska.

BLM is currently preparing an Environmental Assessment (EA) regarding this proposal. If they make a Finding of No Significant Impact (FONSI) on the environment, which seems EXTREMELY likely, given the timeframe, THIS WILL BE THE ONLY OPPORTUNITY THE PUBLIC HAS TO COMMENT.

Specific Issues & Concerns

Drilling in ANWR

If you believe that the Arctic National Wildlife Refuge should be left intact and not opened for oil and gas extraction that will benefit a few, and do nothing to ensure our energy independence, because there is nothing preventing private corporations from exporting their US-extracted oil, this may be your LAST opportunity to share your opinion with decision-makers.

Harm to Wildlife

ANWR supports more than 270 species, including polar bears, whose numbers are already in decline, and the Porcupine caribou herd, upon which local indigenous communities rely for subsistence hunting and survival. ALL of the wildlife in the target area is likely to be negatively impacted by loud, around the clock operation of almost 50-ton vehicles vibrating the earth EVERY 27.5 FEET along 3,237 MILES of source line within an almost 850 square mile area of operation. The proposed plan states, ‘[u]p to 12 fibrosis vehicles, spaces at least 1,320 feet apart, could collect data at the same time.’ This video shows just THREE vibroseis vehicles simply driving along a road, without stopping every 27.5 feet to shake the earth, and yet you still may want to turn your speakers down.

Imagine three times as many vehicles operating in the otherwise mostly-silent tundra, and the effect this will have on native wildlife, including denned and hibernating bears. Then imagine a mobile camp consisting of 40-50 trailers with as many as 180 people in it being dragged around the same area, a fleet of heavy machinery and support vehicles, and an incinerator burning waste twice daily. And then imagine the additional disturbance associated with the camp receiving 2-3 resupplies per week by ground or air, crew change flights twice weekly, and the delivery of fuel & water by ground 2-3 times per week (not to mention the construction of an undetermined number of temporary airstrips, also on the tundra, or on frozen lakes).

Bears

ANWR is home to all three kinds of bear found in North America: black, grizzly, and polar. Despite this, the proposed action focuses almost solely on polar bears, and to little extent, as evidenced by this statement in the Plan of Operation: ‘Although encounters with polar bears or grizzly bears are unlikely, the operator and its contractors will exercise caution during the project.’ While it is true that this survey would occur during the typical hibernation season, because it is occurring on the Coastal Plain and the operation itself will cause great noise and ground disturbance, it seems foolhardy to imagine that there will not be any encounters. The plan calls for a buffer of one mile around known polar bear den sites, but only 330 feet of buffer around ‘polar bear critical denning habitat.’ It also states that no aircraft will operate within a half-mile of polar bears, and planes will (when possible) remain at least 1500 feet off the ground in efforts to not disturb or molest polar bears. Considering the fact that an adult polar bear can run up to 25 mph, a buffer of only a half-mile to a mile seems negligible. And frankly, considering the level of noise and ground disturbance this project will cause, it seems likely that denned and hibernating bears will definitely be impacted negatively, regardless of the one-mile buffer (that is for polar bears ONLY).

Damage to the tundra ecosystem

As a result of the survey

This article gives a great overview of the potential damage and negative impact that may result from this project.

A 2009 study published in the academic journal ‘Arctic, Antarctic, and Alpine Research’ suggests that winter seismic exploration results in negative effects on native vegetation, and that modern exploration techniques are similarly or more harmful than methods used 30 years ago. ‘The exploration for, and development of, buried petroleum resources is one of the largest sources of anthropogenic disturbance across the circumpolar Arctic. To date the most extensive type of disturbance associated with petrochemical exploration in the western Canadian Arctic has been two-dimensional (2D) winter seismic exploration, in which heavy vehicles are driven single-file across the tundra.’ Although the current proposed action is to use three-dimensional (3D) exploration, the method remains the same: heavy vehicles driven single-file across the tundra.

A 2019 white paper from the University of Alaska, Fairbanks looked specifically into the 3D method of seismic exploration, projected their findings to the specified region of ANWR, and concluded: ‘Based on the authors’ knowledge of the 1002 Area, the available literature, and our observations of impacts from previous seismic surveys, the proposed seismic program will have extensive short-term and long-term direct, indirect, and cumulative impacts to the 1002 Area. A thorough review is required in light of what is already known about the detrimental impacts of seismic surveys in the Arctic and to identify gaps in our knowledge.’

A 2020 review of landscape impacts and analysis of a proposed 3D seismic exploration program in the same area concludes: “current regulations are not adequate to eliminate impacts from these activities. We address issues related to the high-density of 3D trails compared to 2D methods, with larger crews, more camps, and more vehicles.’ The article suggests that impacts from 3D exploration are actually worse than the damage described in the 2009 study focused on 2D surveys.

This 2018 article shows the blight of prior seismic explorations, written by an Alaskan PhD in geophysics, who despite thinking ‘seismic data is cool,’ states, ‘[s]o as much as I would like to see 3D seismic done in the 1002 area, I am adamantly against using the methods used earlier this year just outside the Refuge boundary which leave what appear to be permanent scars on the landscape, as I show in this blog.’

As a result of the support camp and related activities

In addition to the potential damage by the survey process alone, there is the additional impact and damage that will result from the mobile base camp supporting it. According to the proposed action document, the camp will move 1-2 miles every 5-7 days. However, the plan of operations indicates that the moves will occur every 2-5 days. As noted above, an undetermined number of temporary airstrips will be built around the target area to support resupply flights and crew changes.

The project anticipates using 6,000 GALLONS of fuel per day. The proposal states ‘[t]he operator would have a [fuel] Spill Countermeasure Control (SPCC) plan in place,’ that would be amended from a SPCC Plan designed for a different site. As of this time, there is no Plan available to the public for review and thus no way to determine if it is reasonable or will be at all effective.

Reliability of a Corporation mired in federal fraud charges and bankruptcy proceedings

Any and all plans for mitigating harm to wildlife and preventing damage to the ecosystem are contingent on the reliability, responsibility, and ethical activity of the designated operator, SAExploration.  However, as noted above, SAExploration is currently the subject of civil litigation by the SEC ‘over an alleged multi-year accounting fraud that falsely inflated the company’s revenue and concealed the theft of millions of dollars.’ Additionally, despite receiving MILLIONS of dollars in coronavirus aid earlier this year, the Corporation filed for bankruptcy protection in August. As such, it is impossible to muster any level of confidence in the integrity of this operation or the corporation that is to undertake it.

ACT NOW! COMMENTS ARE DUE BY FRIDAY, NOVEMBER 6.

Send an e-mail comment to blm_ak_rdo_cp_2020_seismic@blm.gov and let BLM know you oppose drilling operations of any kind in ANWR!

It would be helpful to additionally insist that the BLM at the very least not allow this project to go forward without preparing a FULL Environmental Impact Statement subject to the requisite public comment period.

Use any of the above points to emphasize that an Environmental Assessment is insufficient, and a Finding of No Significant Impact is an unacceptable outcome as evidenced by multiple scientific and scholarly articles.

Short Cuts:

The National Wildlife Refuge Association has an action page to send a form-based comment letter here.

The Center for Biological Diversity has an online action page to create a form-based comment letter here.

Access the BLM Project Planning page with supporting documents here.

For more information on ANWR and why it merits our support and protection:

The Wilderness Society has an extensive informational and action center where you can learn more about the importance of this wild public space here.