This post is part two in a series on the Draft EIS. Our goal is to explain and contextualize the Draft EIS to allow our readers to take effective and informed action. We will also be looking at the public comment process and explaining how readers can best make a difference regarding drilling in the Arctic National Wildlife Refuge. Thanks again to Dan Ransom for sharing his beautiful photos from a trip to the Refuge last summer.
The goal of the Draft EIS is, among other things, to identify the environmental risks that drilling would pose and to propose strategies (the “Alternatives” and their stipulations) for managing and mitigating them. In the Draft EIS, the BLM has summarized a number of the issues at play and laid out the ways that different stipulations and alternatives would impact those concerns. The point of the public comment process is actually not to comment on whether or not you feel we should be drilling in the Arctic — that’s not the BLM’s decision, thanks to Congress — but rather on if and where they went wrong in the science and the calculus of impact mitigation. The BLM has covered many of the issues, and we’ll go through what they talk about in this article, but ultimately we feel that the “mitigations” proposed are not sufficient to deal with the environmental harm that any degree of oil and gas extraction in the Refuge stands to cause.
Climate Change
The BLM begins their analysis of the environmental impacts of oil and gas leasing in the Refuge by discussing the impacts on global-scale climate change, asserting that micro-climate changes due to construction and operation equipment are insignificant. Looking primarily at greenhouse gas emissions (GHGs), they divide the impacts into direct and indirect — direct meaning produced by the process of exploring for and extracting oil and natural gas, indirect meaning GHGs produced by the burning of the extracted fuels on the global market. They base their calculations of direct impact on the results calculated for another Alaskan oil EIS, the Greater Moose’s Tooth 2 EIS. They estimate annual direct GHG emissions for the Coastal Plain oil production at 50,000 to 400,000 metric tons of CO2 equivalent. For perspective, that’s a range equivalent to what’s emitted by producing electricity for 6,400-51,200 US households in a year.1 The range is so broad because they aren’t sure exactly how much oil and gas will be extracted from the Refuge — they estimate between 1.5 and 10 billion barrels of oil.
Their analysis of the indirect emissions of the Coastal Plain gas leasing program is really interesting. Based on their estimates, the Coastal Plain could supply 0.1-0.5% of global oil once it reaches peak production. Natural gas estimates are much more uncertain, but also potentially significant: they estimate the area could yield anywhere from 0 to 7 trillion cubic feet of gas. The study used a market simulation model to estimate how the increased supply would impact demand for oil and found that the Coastal Plain oil and gas production is projected to increase US demand for oil by 3.4-3.9% of the total amount produced. With those models, the study estimates annual indirect GHG emissions as ranging from 0.7-5 million metric tons of CO2 equivalent. Overall, the oil and gas leasing program will cause an increase of between 0.011% and 0.086% over 2015 US GHG emissions.
Caribou
There are four caribou herds in northern Alaska; the EIS addresses two that seasonally inhabit the Coastal Plain area. These are the Central Arctic Herd (CAH) and the one you’ve probably heard of, the Porcupine Caribou Herd (PCH). Both herds use the Coastal Plain program area in a typical year. The PCH uses the program area for calving — giving birth to their young. The BLM found that between 1983 and 2001, 42.7% of calving PCH females used the program area. There’s a fair amount of literature about the interactions between caribou and oil and gas exploration and infrastructure from other areas in northwestern Canada and Alaska. The EIS tries to summarize the existing research and estimate the potential effects on the herds. Unfortunately, there are a lot of potential issues: changing snowmelt patterns due to snow compaction by vehicles in winter; vegetation damage due to the same vehicles; physical alteration of habitat from dust deposition and other issues near gravel infrastructure; behavioral disturbances from human activity and infrastructure. All of these can affect caribou during both normal activity and during calving (which is a more critical period as far as herd population dynamics are concerned).
In terms of calving habitat, the BLM presents their development alternatives in a way that emphasizes only areas that have been used for calving in at least 40 percent of recent years. Even with that condition, those areas cover 49% of the region. If you lower your threshold to “used for annual calving grounds at least 20 percent of years,” that number rises to 69.4% of the program area. Some of the proposed stipulations and regulations have been shown to mitigate caribou response to infrastructure, but others have not. Alternatives D1/D2 have the most stipulations in place to protect caribou calving habitat, though many of those stipulations and regulations remain untested. A group of scientists put together a vulnerability study in response to the Draft EIS that identifies a number of ways the EIS falls short with regards to the PCH, emphasizing the uncertainty in many of the mitigation strategies proposed by the BLM. They also say that the EIS failed to quantify cumulative effects on the PCH and suggest that the probability of a major decline in the herd would be increased by 10%-18% compared to baseline by the oil and gas leasing program.
Polar Bears
Polar bears have been listed as a threatened species under the Endangered Species Act since 2008. Polar bears live much of their lives on sea ice, but come to land for a number of reasons including “denning,” the process in which female polar bears give birth to their young. Basically, the bears dig a hole in a snow drift, give birth, and hang out in said hole with their cubs for three months. According to the US Fish & Wildlife Service, 77% of the leasing program area is classified as Terrestrial Denning Critical Habitat. There are a number of other studies showing that the program area is an important denning area for polar bears and that, as sea ice continues to diminish due to climate change, it will become more important. The BLM suggests that most habitat loss effects will be caused by the construction of ice roads and drill pads and will be temporary. Longer term behavioral impacts may occur, but they state that since most of the oil and gas activity will be inland, those impacts will be small. Ultimately, the BLM asserts that most negative impacts on the polar bear population can be mitigated through lease stipulations and regulation
One major aspect of that mitigation is identification of denning sites before winter seismic exploration occurs. The BLM says that surveys using a technology called FLIR (forward-looking infrared) sensors and trained dogs “have proven to be an effective means of locating dens,” but some experts in the field disagree and suggest that FLIR typically only detects about half the polar bear dens in a given area.2 Failure to properly identify dens in these surveys could lead to den disturbance and abandonment which would significantly damage cub survival rates and could possibly lead directly to the death of some mothers and cubs.
Other Species
156 species of birds have been identified in the northern foothills of the Refuge, both migratory and permanent residents. It’s a critical area for many species to nest and rear their young. A number of the species in the program area are classified as some degree of at-risk — with a threatened or declining population. The BLM cites a few ways in which oil and gas leasing will impact the birds of the Refuge including through direct habitat destruction or alteration, behavioral reactions to human disturbance, and impacts from helicopter work. They also document similar impacts on fish and marine life, including bow whales. In general, they point out that Alternative D has the largest setback requirements for rivers and streams and thus the lowest impact on these species.
Gwich’in Nation
The Coastal Plain program area is considered sacred by the Gwich’in nation, a group of Native Americans / First Nations that live in northwestern North America (in both Canada and Alaska). They refer to the Coastal Plain as “The Sacred Place Where Life Begins.” This belief is centered around the migratory species that use the area to reproduce — caribou, waterfowl, polar bears, etc. Caribou, in particular, are culturally important to the Gwich’in and the BLM states that any impacts on the caribou herds in the area should also be considered an impact on the cultural value for the Gwich’in people. According to the BLM, a comprehensive identification of cultural sites has not been completed and that consultation with the tribes of the Gwich’in will allow development to proceed while avoiding adverse impacts on cultural resources. Despite that, the BLM points out that Alternative D is the least likely to have major impacts on undocumented cultural resources because it has the most stipulations and largest setbacks from areas with higher likelihood of cultural importance. They also point out that the land as a whole has cultural importance to the Gwich’in and that cumulative impacts of development will damage that.
Those Gwich’in who specifically live in or near area — in the communities of Kaktovik, Nuiqsut, Arctic Village, and Venetie — will be more directly impacted because of their subsistence use of the region. Additionally, because of the migratory nature of the caribou (and other species), groups outside the immediate area will be impacted by changes to caribou herd sizes. The BLM states that many communities across northeastern Alaska and northwestern Canada are likely to be impacted by oil and gas leasing because of the impacts on caribou calving in the Refuge. 85% of the subsistence harvesting of Porcupine caribou occurs in Canada by Gwich’in people and Inuvialuit people; as a result, Canadian user groups are the most likely to have their subsistence lifestyles impacted by damage to the herd. There’s also the potential for more direct conflict and overlap between resource development areas and subsistence use; residents of Kaktovik regularly use much of the high hydrocarbon potential coastline on the west side of the Refuge.
What Does This All Mean?
If you read the Draft EIS, you’ll see that every step of the way, the BLM makes clear that there will be major impacts as a result of drilling in the Refuge. Many of those impacts are lessened by Alternative D which has the most significant restrictions on leasing, but lessened is far from eliminated and much of the impact is common to all alternatives (except the not-considered “Alternative A” — not drilling). There are a few issues where other scientists suggest the BLM does not fully understand the scope of the impact, but for the most part, they aren’t downplaying things. Unfortunately, whether or not we drill in the Refuge isn’t up to the BLM. Check out Part 3 (coming this afternoon) for more information about the public comment process and how you can have an impact when it comes to drilling (or, ideally, not drilling) in the Refuge.
Other Resources
Want to learn more about some of the issues at play here? Check out these resources: